I am writing on behalf of the Oil and Gas Accountability Project to provide an impartial analysis of the adequacy of the actions proposed in the subject report. I am a practicing hydrogeologist; I spent 32 years at the U.S. Geological Survey in both management and research positions. I left the USGS in 1995 to become a consultant. I have published more than 100 papers in the refereed scientific literature on various groundwater problems. My resume is attached to this comment.
Coal-bed methane is an energy source that in many places in the United States is associated with underground sources of drinking water (USDW). In some places the coal beds are the best aquifers in the area. In these places the development of CBM is incompatible with the continued use of the coal beds as an aquifer.
There is a direct conflict between national/state energy policy and the preservation of USDW. For example, in the Powder River Basin of Wyoming and Montana the Bureau of Land Management predicts, in their Final Environmental Impact Statement for CBM, that the development will lower the water levels in the coal measures by 600 to 800 feet over much of the basin.
This will make unusable several thousand private water wells that are completed in the coal beds. The law favors the development of the methane over the continued use of the coal beds as aquifers—in this case the best aquifers in the area.
...EPA discounted problems associated with hydraulic fractures based upon a limited sample of identified problems. They relied upon citizen reports almost exclusively. There were no independent surveys, no independent field investigation or other well sampling. The EPA exercise is incomplete at best.
...EPA seems caught up in the conflict between the National Energy Policy of the Bush Administration and the EPA mandate to protect USDW.
Letter written by Hydrology expert, John D, Bredehoeft, to Joan Harrigan-Farrelly: Chief Underground Injection Control, Prevention Program Office of Ground Water and Drinking Water Environmental Protection Agency.
RE: EPA draft study report:Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs: Subject: Federal Register August 28, 2002, Volume 67, Number 10, Pages55249-55251 (water Docket Id no. w-01-09-11).
See also: Bredehoeft, J. (2003). " From Models to Performance Assessment: The Conceptualization Problem." Ground Water, Vol. 41, No.5 pp 571-577.