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Knoxville, TN 37902
I am writing about a proposal by the University of Tennessee Institute of Agriculture to use publicly-owned land in Scott and Morgan counties for an oil and gas research project involving hydraulic fracturing. The study area is listed by the Tennessee Department of Agriculture as a crucial conservation site, containing the headwaters for the Little Emory River Watershed and uncommon plant and animal species. Because of the risks of hydraulic fracturing, this proposal indicates poor stewardship of the land by the University.
The Little Emory River Watershed supplies the local water utility and many wells and creeks used for agriculture and livestock. Hydraulic fracturing for oil and gas production is so poorly characterized that its effects on water sources are unsure, making this technology an irresponsible risk. Additionally, the areas the fracturing wells will drill into have been documented by the Office of Surface Mining to be broken by joints and fractures, giving the high-pressure damage to shale beds a much greater risk for contamination. Even worse, if an accidental release or well blowout such as the recent well fire near Oliver Springs should occur, then toxic, carcinogenic and even radioactive byproducts of the well could pollute the water supply for decades to come.
The Chattanooga shale the wells would drill into contains radium-226 and radon gas. The USDOE has marked this shale bed as a potential source of uranium. The rock layers surrounding the shale, which drilling operations could disrupt, contain toxic materials such as selenium, which could contaminate groundwater if disturbed.
Unfortunately, hydraulic fracturing is exempted from federal regulations via the Halliburton Loophole, and state regulations are minimal.
While the proposal would net UTIA a portion of the natural gas production revenue, other universities that have undertaken similar research, such as the University of Texas and the State University of New York at Buffalo, have suffered conflicts of interest, forcing them to withdraw research findings and terminate staff. These universities also failed to remain transparent; the UTIA has bypassed a promised meeting with local residents and members of the environmental community, and quietly submitted a request for proposal to the State Building Commission to enter into a gas and oil lease agreement for a maximum period of 20 years “or as long as product is being produced in paying quantities.” Members of the State Building Commission are scheduled to meet January 31 in Nashville to make a decision on this issue.
There is simply too much risk to drill in the proposed areas, for the local environment and for UTIA with the risk of a conflict of interest. If UTIA intends “to investigate the impacts of natural gas and oil extraction,” as the fact sheet for the oil and gas research proposal states, why not leave the land as an untouched baseline, and compare that data to existing wells on state or publicly owned land? If UTIA is so interested in earning revenue from the land, they can always sell its carbon credits.