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Environmental and Public Health Implications of the TPP

By Dylan Lenzen

This past week, the House of Representatives failed to approve a measure that would provide President Obama with “fast-track authority” in negotiating the Trans-Pacific Partnership (TPP), a free-trade agreement between the U.S. and eleven other countries of the pacific-rim including Japan, Vietnam, Australia, Mexico, and Canada among others. The trade agreement has been negotiated in secret for three years, and beyond leaked documents, the American public will likely not be able to view the details of the agreement until after it is approved. While President Obama supports the trade deal, he failed to convince the necessary number of his fellow democrats in order to pass the measure. Many democrats, including Minority Leader Nancy Pelosi, have expressed concerns that the deal does not provide adequate protection for American workers. In addition, a number of environmental and consumer-advocacy groups have expressed their opposition to the trade deal for a number of reasons, including threats to the environment and public health.

Particularly alarming are the rights granted to corporations under the “investor-state dispute settlement system”. As a result, multinational corporations would essentially be given the right to sue governments before international tribunals regarding regulations they believe pose a threat to “expected future profits”. In cases where corporations win, the taxpayers of the losing country would be responsible for providing compensation. This has already been observed under past trade agreements such as NAFTA. An example was described by the Sierra Club, in which Lone Pine Resources, an oil and gas corporation, sued the Canadian government for $250 million after a fracking moratorium was passed by the Quebec National Assembly. According to consumer rights advocacy group, Public Citizen, over $3 billion has been paid out to corporations as a result of disputes under past free-trade agreements, a majority being related to environmental and public health regulation. Public Citizen goes on to state, “the mere threat of a case can put pressure on governments to weaken environment and health policies.” These policies represent important protections for the health of communities all over the world.

In addition to the threat posed by the investor-state system, others worry that hydraulic fracturing operations in the U.S. will expand due to increased natural gas exports. Currently, all natural gas exports are subject to analysis by the Department of Energy to ensure that exports do not threaten the interests of the American public. Under the TPP, this authority would be lost and all natural gas export permits would be approved, increasing pressure to expand U.S. fracking operations and infrastructure. This increases the environmental health threats already posed by the industry.

These represent but a small portion of a great number of concerns in regards to the Trans-Pacific Partnership. While the capacity of free-trade agreements such as this to promote economic development and job growth is up for debate, it is clear that these agreements pose significant risk to the health of communities and ecosystems around the world.

To find out more about the Trans-Pacific Partnership, please consider the following resources:
http://www.sierraclub.org/trade/trans-pacific-partnership
http://www.citizen.org/TPP

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Backyard Talk

EPA Takes Baby Steps in Acknowledging Fracking Dangers

The US EPA released a draft Assessment of the Potential Impacts of Hydraulic Fracturing for Oil and Gas on Drinking Water Resources earlier this month. Although still only a draft, the document marks a noticeable shift in how EPA views fracking – from basically denying that fracking posed any risk to drinking water and human health, to acknowledging that, “there are above and below ground mechanisms by which hydraulic fracturing activities have the potential to impact drinking water resources”. I, for one, cannot believe that EPA had the guts to do this.

Don’t get me wrong; the draft assessment still makes a weak statement with regards to the real impacts of fracking on drinking water. However, the statement carries major credibility and importance due to the fact that the draft assessment is the most comprehensive review of literature on the potential impacts of fracking on drinking water to date, having examined nearly 1,000 different science and engineering journals, federal and state government reports, nongovernmental organization reports, industry publications, and federal and state datasets.

Although EPA states that there is no evidence that fracking activities have led to “widespread, systemic impacts on drinking water resources in the United States”, they clearly acknowledge that they have the ability to do so at the local level. This is a bit obvious, since we are not experiencing massive water shortages or national pandemics due to fracking (at least not yet), yet it is well documented that millions of people across the nation have experienced water contamination due to fracking activities in their local environments. Therefore, if we take EPA’s statement into perspective, they are effectively saying that fracking can and has affected local drinking water sources across the country.

This is heresy for industry, and the full wrath of their criticism is sure to fall on EPA in the coming weeks. During the document’s public comment period, the oil and gas industry will move mountains to ensure that EPA’s modest claims attributing fault to fracking for drinking water contamination are removed from the final document.

As an idealist, I have hope that EPA will withstand the storm and stand up for what the science has revealed. However, in all likelihood, the billions of dollars at the disposal of industry will ensure that EPA softens their already weak stance or retracts it altogether.

My hope is that environmental organizations and the public at large fight this and tell EPA not to be bullied by corporate interests. Public comments on the draft assessment are open until August 28, so we can all weight in on the fight. EPA is taking baby steps towards finally accepting that fracking has huge inherent dangers to public health and this is among the first of these steps. It falls to us to take EPA’s hand and help it learn to walk.

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Backyard Talk

Fracking for Environmental Remediation

Most of us are familiar with hydraulic fracturing as a technique used for oil and natural gas drilling. The process uses a slurry of chemicals and sand to prop open rock fissures, allowing the release of fossil fuels. However, natural gas and oil are not the only constituents trapped in rock layers; these layers can also serve as a reservoir for contaminants. At Superfund sites and other polluted areas, the process of remediation, or cleanup, can be extended and expensive. Hydraulic fracturing has been utilized as an environmental cleanup method, where the same process is used to release trapped contaminants in rock layers. The EPA provides information on the process at

http://cluin.org/techfocus/default.focus/sec/Environmental_Fracturing/cat/Overview/

In fracking for environmental remediation just as in fracking for oil and gas drilling, a slurry of chemicals is pumped into the ground, typically containing a combination of water, sand to prop open fissures, detergent, and nutrients/amendments which stimulate the process of chemical breakdown. According to the EPA, “Environmental fracturing can be used to make primary treatment technologies…more efficient.” By enhancing the access of chemicals for pollution treatment to the rock layers where the pollutants are trapped, fracking has the possibility to decrease treatment times at polluted sites.

Fracking for fossil fuel extraction – specifically, horizontal drilling which uses a very large volume of chemicals- has been faulted for a number of high-profile instances of water contamination. When the process fails, the stakes are high for communities whose water supplies are in proximity to fracking wells. Through environmental hydraulic fracturing is intended to clean up already-polluted sites, the parallels between this process and fracking for natural gas are difficult to ignore. Is it possible for the process to further spread contamination in instances that pipelines or wells fail? The research is slim on this topic so far, but we do know that even with the best of intentions, remediation processes do not always go as planned. In my next post, I’ll explore the potential for unintended consequences from remediation.

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Backyard Talk

ATSDR Fails Community Once Again

In July of 2013, an explosion occurred at the WTI/Heritage Thermal Services (HTS) hazardous waste incinerator in East Liverpool, OH. Incinerator ash that had built up on the inside of the incinerator stack suddenly fell off causing a huge cloud of dust contaminated with heavy metals and other toxic substances to be released from the stack. An estimated 800 to 900 pounds of ash were released into the surrounding community. The plant manager advised residents to wash fruits and vegetables from their gardens and to replace food and water for pets and farm animals. Save Our County, a local group that has been fighting to shut down the incinerator for more than 20 years and other local residents were quite alarmed by what happened and asked whether this latest accident further put their health at risk.

The state regulating agency’s response was to invite the federal Agency for Toxic Substances and Disease Registry (ATSDR) to evaluate what risks the residents might have suffered. More than a year later, ATSDR released its report which concluded that the “trace amount of toxic metals in the surface and subsurface soils of the residential area west of the HTS facility affected by the July 2013 ash release are not expected to harm people’s health. The reason for this is that the concentration of these metals found in the soils are below levels of health concern.”

It’s not clear how ATSDR came to this conclusion when some of the data included in the report clearly show contaminant levels that exceeded levels of health concern. Two (of 13) soil samples, one on-site and one off-site, both downwind, had the highest levels of contaminants of concern (though they never disclosed what these levels were). The arsenic levels found in the surface soil of the surrounding community generally exceeded public health levels of concern, ranging from 14 to 57 parts per million (ppm), averaging 20 ppm. The public health level of concern is 15 ppm.

There is also data on two wipe samples (of 8) collected by HTS immediately after the accident that were found to contain 3,600 ppm arsenic; 13,000 ppm lead and 8,000 ppm nickel. These samples were collected from areas on-site where trucks at the facility were staged. These are all extraordinarily high and well above public health levels of concern.

Similarly, two wipe samples collected from the community had arsenic levels at 277 ppm and lead at 819 ppm, both levels well in excess of levels of public health concern. The report refers to a third sample collected from the surface of a black S10 pick-up truck with arsenic at 296 ppm and lead at 1,046 ppm also well above public health levels of concern.

Despite all of these results that exceeded public health levels of concern, ATSDR concluded that there is no cause for alarm and that the toxic metals released into the community “is not expected” to harm people’s health. It’s like someone at ATSDR wrote the conclusion without ever reading the report or looking at the data.

The ATSDR report simply ignores the data that exceeds public health levels of concern and draws its conclusions as though these high levels did not exist. How can anyone trust a government agency that operates this way?

This is what communities across the country have grown to expect from ATSDR – conclusions that are unresponsive to community concerns about potential health risks but protective of industrial pollution. Some things never change.


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Backyard Talk

Great Pacific Garbage Patch

By Michelle Atkin

The world’s largest landfill is actually floating in the middle of the North Pacific Ocean. It contains three million tons of plastic, in addition to other marine debris, and is often referred to as the Great Pacific Garbage Patch (GPGP). This drifting ocean litter or gyre is one of five major global garbage patches and was discovered in 1997 by Charles Moore, a California volunteer environmentalist and sailor who was so concerned he founded the Algalita Marine Research Foundation.

The size of this trash cluster is widely debated because it is difficult to measure as it shifts with the currents. While some say it is the size of France, others say it is twice the size of Texas, but it is a problem that is not going away.


Every year there are 280 million tons of plastic produced around the world, and 63 pounds of plastic packaging for each person ends up in landfills annually while only nine percent of it is recycled in the United States. Unfortunately, because plastic is not biodegradable, all of the fragments of plastic that have ever been produced still exist, excluding the small volume that has been incinerated, which releases toxic chemicals.

While water bottles and plastic bags contribute to the greatest percentage of plastic litter, a few of the many other items that can be found on the ocean’s floor or surface are buttons, fishing line, toys, cigarette lighters, PVC pipe or fragments, golf tees, gloves and markers. Over time, the sun, wind and waves can break down the plastic into millimeter sized flecks which creates a mess that is impossible to clean up. Scientists have found six times more plastic than plankton in GPGP ocean water samples, and it makes its way into the stomachs of birds, fish, whales and other marine life, which may eventually end up on our plates, along with the Bisphenol A (BPA) and other toxic chemicals found in some plastic.

The estimated 46,000 pieces of plastic per square kilometer in the world’s oceans kill millions of seabirds and 100,000 marine mammals each year from ingestion or entanglement. Half of the Earth’s wetlands have been destroyed and beaches like Kamilo Beach in Hawaii consist of more plastic particles than sand particles in the top twelve inches of the beach.

As stated by National Geographic, “because the GPGP is so far from any country’s coastline, no nation will take responsibility or provide the funding to clean it up,” but even if a net could collect the trash “the National Ocean and Atmospheric Administration’s Marine Debris Program has estimated that it would take 67 ships one year to clean up less than one percent of the North Pacific Ocean.”

The enormity of the ocean and this problem is difficult to grasp because like GPGP reporter Richard Grant wrote, “even if plastic production halted tomorrow, the planet would be dealing with its environmental consequences for thousands of years, and on the bottom of the oceans, where an estimated 70 percent of marine plastic debris ends up, for tens of thousands of years. It may form a layer in the geological record of the planet.”

Despite the damage that has already been done, the focus should be placed on reducing our footprint in the future. We need to work together and individually by volunteering to clean-up streams, rivers, lakes and beaches, so that we can limit the garbage that makes it into the ocean. We should also support environmental organizations and embrace environmental initiatives, reduce plastic use and recycle.

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Backyard Talk

Fracking Under Fire in North Carolina

North Carolina communities have gained a temporary reprieve from the threat of fracking. Last week, Wake County Superior Court Judge Donald W. Stephens ruled that North Carolina is not allowed to approve any applications for hydraulic fracturing until the state Supreme Court determines whether or not the North Carolina Mining and Energy Commission was formed constitutionally.

Legislators appointed the majority of the commission’s members when it was formed – an action that falls under the authority of the governor, not lawmakers. According to Therese Vick of the Blue Ridge Environmental Defense League, the decision “essentially puts a de facto moratorium on permitting activities in North Carolina until the case is heard in June or July.”

Areas of N.C. at risk from fracking. (http://rafiusa.org/issues/landowner-rights-and-fracking/fracking-map-in-nc)

N.C. governor Pat McCrory has challenged the formation of this and other commissions, claiming the appointment of commission members by lawmakers rather than the executive branch violates the constitutional requirement for separation of powers. According to Vick, this is one of the most surprising aspects of the case – that it was brought by a governor who has not been an outspoken opponent of hydraulic fracturing. Environmental groups have also challenged the Commission’s legality. The Southern Environmental Law Center brought a case on behalf of a Lee County landowner alleging the commission was formed unconstitutionally, and that it cannot legally process or approve any applications for fracking installations.

So far, the Commission has set fracking regulations but has not approved any drilling units in the state. It remains to be seen whether the forthcoming decision will keep things that way, but delay can often serve as a powerful tool in preventing harmful environmental actions. Vick thinks the case may very well be successful, and that any rules made by an unconstitutional commission could be “declared null and void.” Though we will have to wait until later in the summer for a decision, Vick says the BREL is “very pleased.”

Though the ultimate decision will rest in the legal realm, it is on-the-ground organizing that has made a major difference. Vick points out  that “the organizing and activism and resistance that held [fracking] off this long was what gave time for an opportunity to present itself for a legal hook.” According to Vick, any victories must be attributed to the hard work done by citizens across the state.

Though N.C. citizens may consider this a victory, the resistance to fracking is far from over. Says Vick, “It’s not a time to sit back and take a break – it’s time to push even harder.”

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Backyard Talk

NIMBY Versus NIMIC

Not In My Backyard vs Not In My Insurance Company

For many decades community leaders were called NIMBY (Not In My Backyard) when opposing a facility that would cause environmental and public health damages. They were told that they were reacting emotionally, stifling progress and or the waste/facility needs to go somewhere. Or local leaders hurting the economy, we need the jobs and so stop complaining about public health hazards or environmental destruction that community leaders are being just selfish.

There were full out attacks on innocent people trying to find a way to protect themselves from environmental chemicals and to convince corporations to look beyond the dinosaur aged technology and moved to other safer ways to provide the same goods or services.

Today the insurance agencies are working hard to stop, “to exclude” coverage from earthquakes in Pennsylvania caused by fracking. NIMIC stands for Not In My Insurance Company. The contrast in reactions from the public is striking with the exception of the State of Pennsylvania Insurance Department (PID) who is opposing such exclusions. Those with money and don’t live near such destructive practices say the insurance industry must protect themselves from huge liabilities. It make sense that they would want to create an exclusion in their policies.

Nationwide Mutual Insurance Co. has become the first major insurance company to say it won’t cover damage related to a gas drilling process that blasts chemical-laden water deep into the ground. Their memo reads: “After months of research and discussion, we have determined that the exposures presented by hydraulic fracturing are too great to ignore. Risks involved with hydraulic fracturing are now prohibited for General Liability, Commercial Auto, Motor Truck Cargo, Auto Physical Damage and Public Auto (insurance) coverage.”

Yet when innocent people with no stake in the leasing or process say it is too great of a risk to frack in or around our community they are dismissed as NIMBYs. The insurance industry did their studies assessed the risks and said no. Community leaders including the community in TX who banned the process entirely from their borders. State legislation was introduced to allow local bans on fracking only to be overturned by Republican Gov. Greg Abbott who signed a law that prohibits bans of hydraulic fracturing altogether and makes it much harder for municipal and county governments to control where oil and gas wells can be drilled.

This is a blatant contradiction that once again demonstrates the bias against the American People and for the corporate polluters and their associated family of corporations. There was no law passed that says insurance companies must provide coverage for associated damages from earthquakes, poisoned water, air and public health impacts. Maybe just maybe we should make a rule, decision or law that says if an insurance company does their risk assessment and finds that the risks are too great for them to participate or provide coverage then the facility, process . . . thing cannot move forward at any costs.

Since the majority of our stae and federal health departments or departments of environmental regulations can’t ever find a risk they can’t explain away, then we should follow the risk assessments of the Lloyd’s of London. If Lloyd’s of London says it’s too risky then it is. A simple way to protect the American People.

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Backyard Talk

It’s Time to Move Beyond Risk Assessment

Risk assessment is the standard method for evaluating exposure to toxic chemicals, despite the fact that it’s nearly impossible to do a risk assessment that is objective and accurate. There are just too many hard-to-measure factors affecting the chance that any one chemical will harm us and if so, how and to what extent, and too many ways for personal bias to change the results. For example, there’s been a long argument about whether arsenic causes cancer. We do know that it’s poisonous. It probably does cause cancer, but many people seem to be immune. So we’re not sure how many cases might occur, and what amount of arsenic might cause cancer. Also, it doesn’t seem to cause cancer in animals, so there’s no way to put the information together. When there are information gaps, the only thing we can do is build-in an extra safely factor, by making the “allowable” level a certain amount less than what we think the “safe” level is. But is that really the answer?

The public wants greater protection from exposure to toxic chemicals than provided by the traditional quantitative risk assessment approach which has many limitations and uncertainties. Instead, support has grown for use of a precautionary approach that promotes (1) preventive action, (2) democratic and transparent decision-making with the broadest possible public participation, and (3) a shifting of the questions being asked (e.g., instead of asking what level of risk is acceptable, asking how much risk can be avoided; what is the need; why is it needed; who benefits and who is harmed; and what are the alternatives?) as well as the presumptions used in decision-making (e.g., shifting the burden of proof to the proponents of potentially harmful activities, and placing public health above other considerations).

In its 2009 report, Science and Decisions, the National Resource Council (NRC) of the National Academies acknowledged that risk assessment is “at a crossroads” facing “a number of substantial challenges”, that “its credibility is being challenged”, and that the “regulatory risk assessment process is bogged down”.  The report made a number of recommendations that focused on improving the methodology of risk assessments (e.g., thorough evaluation of uncertainties and variability, unified dose-response approach to cancer and non-cancer endpoints, broadening the assessment of cumulative and interacting health risks and stressors), and improving the relevance or utility of risk assessments for decision-making (e.g., involving all stakeholders at the earliest stage of the planning, design and scoping of the risk assessment, and increasing the transparency of the assessment methods and process).

The NRC recommended two major shifts: (1) “that risk assessment should be viewed as a method for evaluating the relative merits of various options for managing risk”, with the risk management questions being “clearly posed, through careful evaluation of the options available to manage environmental problems at hand,” casting light on “a wider range of decision options than has traditionally been the case”; and (2) aligning closely the technical analysis with the problem at hand so that the risk assessment will be relevant to the needs of the decision-makers and stakeholders who are addressing the problem (e.g., a “one size fits all” approach to risk assessment will not be appropriate for such very different problems as regulating a chemical and deciding on a site remediation approach).

These recommendations are now more than 5 years old, and there’s little evidence that government is adopting these recommendations. Doing so should improve the ability to interpret hazards, contamination levels and population exposures, dose-response relationships, and cumulative risks (exposures from multiple pathways, complex mixtures, multiple stressors, and factors affecting vulnerability), as well as the evaluation of a wide range of alternative options (e.g., inherently safer technologies, alternative ways to achieve the same goal, etc.). It could also provide a way to integrate the risk assessment tool within a broader precautionary approach that seeks to reduce or avoid exposures to toxic chemicals, which the public is actively calling for. It’s time to stop accepting risk assessment as the best we can do to evaluate risks and adopt more a holistic approach to protecting public health and the environment.


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Technical Difficulties: The Long Road toward Superfund Site Remediation

Toxic environmental pollution is unfortunately widespread. If you follow Backyard Talk, by now you have probably heard the story of the West Lake Landfill near St. Louis, Missouri, a dumping ground for nuclear waste from the Manhattan Project toward which an underground fire is slowly creeping. Just last week a contingent from Just Moms St. Louis spoke at a D.C. press conference about the health challenges they and their children have faced while living near this polluted site. The following video shows footage from the press conference and the subsequent march: https://www.youtube.com/watch?v=XpSchIhnYdE.

One commenter on this video asked me whether homeowners could potentially avoid a situation like this through diligent research into the history of where they plan to live. Shouldn’t it be relatively easy to identify whether a site near your home is on the National Priorities List? The story of this site illuminates some common complications that arise during the process of identifying a toxic area and moving toward eventual remediation. It is exceedingly difficult for environmental scientists, let alone community members, to identify pollutants and quantify risks. This post summarizes just a few of the factors that make this process so complex.

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Just Moms St. Louis demonstrate outside EPA Headquarters

Many polluted sites go unrecorded and undetected. When you think of contaminated sites, what comes to mind? We might expect the ground under a former gas station to be loaded with organic contaminants, or predict pollution downstream from a factory. However, not all sites have a clear usage history with easily predictable exposures. This is especially true in the case of places like the West Lake Landfill where waste has been illegally dumped. Radioactive waste was illegally discarded in 1973, but wasn’t uncovered until 1977.

It’s a long road from detection to Superfund designation… The West Lake Landfill was discovered to be contaminated in the 1970s, but it wasn’t until 1990 that the site wound up on the National Priorities List, which designates it as a Superfund Site. How does a site end up on the NPL? There are several different mechanisms that the EPA uses to list sites on the NPL, all of which require extensive characterization of the hazards that are present, and of potential routes for human exposure. At the end of the day, not every polluted site ends up on the Superfund list – leaving still more undocumented but polluted areas. During these interim years, the West Lake Landfill was still polluted – it just wasn’t listed.

…And it’s an even longer road to remediation. Once the West Lake Landfill was placed on the National Priorities List, it was another 18 years until a cleanup plan was ultimately developed. The process of developing a remediation plan involves countless scientific studies, and meetings with PRPs (Potentially Responsible Parties) who are tasked with devising a cleanup strategy that makes sense for the site. During this time, communities are placed in limbo. They live in a documented toxic area, making it difficult to sell their homes, and while cleanup is planned or underway, their potential exposure to toxic compounds continues.

Even then, the unexpected can happen. Much of the current concern surrounding the West Lake site stems from the presence of a smoldering underground fire in an adjacent landfill, which is slowly making its way toward the radioactive waste. It took well over a decade for the EPA to reach a decision on what to do with the West Lake site, and now that this new factor has been introduced, the risks at the site have changed considerably. Any remediation will now have to account for the fire, and underground fires are notoriously difficult to stop.

It is difficult enough for environmental scientists and managers to detect environmental pollution, to determine the urgency of remediation activities, to decide on a plan, and to revise that plan if the unexpected occurs. It is nearly impossible for potential homeowners to keep abreast of the slow-moving yet unpredictable process of listing and remediating a Superfund Site.

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EPA Laws & Regulations Really Don’t Matter

How can ordinary people win justice from an agency that seems to care little about their own laws and regulations? Take for example the recent report that the hazardous waste incinerator (WTI) in East Liverpool, OH. It stands tall next to the Ohio River and has released toxic substances above allowable limits 195 times over 175 days. This is not new for this facility. In fact CHEJ years ago went all the way to the Supreme Court in the state of Ohio to have the incinerators permit revoked. At that time the incinerator was only within compliance (legal limits) two quarters over a number of years.

The area surrounding the incinerator was defined as an Environmental Justice community, by the Environmental Protection Agency. As such the community should have seen tighter enforcement, more access to information and new polluting industries proposed would be weighed against the already high pollution in the area before allowed to be built.

None of that happen. In fact, a freedom of information request was made on several occasion for information because no one would provide the information through a simple request. Those freedom of information requests were able to be fulfilled but not without the low wealth community paying about $1,500. EPA refused to waive the fee for compiling the information. Fracking and injections wells were welcome in the area and operating today with little regard to the existing community toxic burden.

When CHEJ fought in court for the renewal permit to be revoked the local group Save Our County, filled the court room with local people. Three judges sat in the front of the room and listened to arguments from both sides. The community argument was clear, the company is breaking the law and have been for years and no one will do anything about it except collecting on a small number of fines and penalties. To WTI those fines are predictable and just the cost of doing business. The community is suffering from a multitude of adverse health impacts.

Ohio has this regulatory system that allows innocent people to be poisoned. The court ruled against the community when CHEJ helped them to appeal the permit. The judge said he had nothing to hang his hat on and said he understands why his court room is full of unhappy people. The judge said that because according to Ohio regulations, if a company is out of compliance – but has a plan to come into compliance – than they are considered in compliance.

What if that was the rule for everyday people and laws. For example, if you were found to be driving while drunk (DUI), but have a plan to go to alcohol anonymous, then you are not considered in violation of the law – worst you can continue to drive while under the influence, possibly killing innocent people—just like WTI.

EPA and the state of Ohio among other states need to right this wrong. It is the innocent victims that suffer the diseases and taxpayers who are burdened with the cost of those diseases and destruction of the environment and all living things.