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Though the Irish Hills is far removed from our idea of an urbanized community, there is a concentration of people living close to each other on public lakes. Many of the private lake lots have been leased for the mineral rights on waters used for public recreation. Oil and gas drilling around the Community's main source of economy, water, is underway. What is considered an individual’s right must take into account the health and well-being of others who equally have the right to be assured their health and well-being are not jeopardized. WELCOME TO THE IRISH HILLS Recreation website http://www.irishhillsrecreation.com/index.htm The inviting website hosts beautiful pictures of the Irish Hills-- highlighting the natural resources-- the 54 lakes in 15 minutes, the wetlands, vegetation-- all for the nature enthusiasts to enjoy, 365 days out of the year. The History of the Irish Hills dates back to the 19th century as a stopping point during the five-day stagecoach trip between Detroit and Chicago. The early 20th century saw the region develop into a popular tourist destination, a theme that continues today. The area features a unique combination of picturesque countryside, hometown charm and more than 50 lakes for recreation and enjoyment. Unparalleled water sports, fishing and hunting opportunities exist throughout the Irish Hills, making the area a popular destination for outdoor enthusiasts of all skill levels. A variety of accommodations exist from local hotel properties to a plethora of camping experiences and cottages along the miles of lakes. For information on where to stay, visit www.irishhills.com

Given this, how does the Irish Hills Community benefit from oil and gas drilling on and around public lakes? While oil and gas drilling is viewed in terms of environmental or public health interest, the economy of the Community is of equal concern. Tourism, and the drilling for oil and gas don’t mix. The success of the Irish Hills tourism economy is inexorably linked to water quality and scenic values, the laid back country life-style with minimal noise and air pollution. How would the Irish Hills Community insure the safety of tourists swimming in the lakes; eating local fish; breathing clean air; and enjoying the sounds of nature when oil and gas drilling and all that process entails, is allowed on and around the public lakes? What might have been considered an individual decision to lease the mineral rights of lake lot property, is obviously, not. It takes only one unfortunate accident to have an adverse impact affecting all. People who live in the Irish Hills have wells. Ground water contamination is a viable possibility because toxic chemicals are used throughout the drilling process and accidents routinely occur, whether they are reported or not. Highly corrosive hydrochloric acid is used both to remove rust and scale in oil wells to encourage the flow of crude oil or gas to the well. This use is called “stimulation”. An acid solution is injected into the formation, which dissolves a portion of the rock and creates a large pore structure in the formation, increasing its effective permeability and the flow of oil. Well bore damage allows seepage of toxic drilling mud, containing oil and synthetic bases, while drilling boreholes into the earth. The chemical drilling fluid also assists in sealing the sides of the bore and helps stabilize the borehole. However, an unexpected pressure in the subsurface can cause a blowout, resulting in ground contamination. Even though blowout preventers are installed on the equipment, the assurance that the situation is completely under control, is alarmingly naive. Either way, water transports contaminants affecting environment, wildlife and humans. The probability of one error impacting other environments is very real.


As pollutants from oil and gas drilling build up in the food chain, people who consume fish from the contaminated waters will be at serious risk of health problem such as genetic defects and cancers, states the authors of the report: Dirty Drilling, The Threat of Oil and Gas Drilling in Michigan‘s Great Lakes. The report states that routine discharge or accidental release of these materials (toxic chemicals from routine drilling wastes, such as drilling muds and cuttings) could be devastating in the densely populated areas of the Great Lakes watershed, having an immediate contaminating effect on local drinking water wells. Though the report details the hazards of oil and gas drilling in the Great Lakes, the Irish Hills, as the head water source of the River Raisin Watershed, shares the same probability. Both drilling and fracking requires chemical additives that serve as biocides, which is intended to kill living organisms in a selective way. Biocides prevent the fouling of water and oil pipelines. Because biocides are intended to kill living organisms, they pose significant risk to human health and welfare, and the environment including aquatic and wildlife. Hydrogen sulfide exposures usually occur during the drilling for or production of natural gas, crude oil and petroleum products, states OSHA. It is a highly toxic natural gas found not only in swamps and wetlands, but occurs naturally in crude petroleum and natural gas. When dislodged from the earth, through drilling, the noxious gas becomes airborne for up to 18 hours. Aquatic life is adversely impacted, as the gas is also water soluble. In February 2010, based on current evaluations, EPA has determined that hydrogen sulfide can reasonably be anticipated to cause serious or irreversible chronic human health effects at relatively low doses and thus is considered to have moderately high to high chronic toxicity. Hydrogen sulfide has also been determined to cause ecotoxicity at relatively low concentrations, and thus is considered to have high ecotoxicity. EPA believes that chemicals that induce death or serious adverse effects in aquatic organisms at relatively low concentrations (I.e., they have high ecotoxicity) have the potential to cause significant changes in the population of fish and other aquatic organisms, and can therefore reasonably be anticipated to cause a significant adverse effect on the environment of sufficient seriousness to warrant reporting. (Federal Register/Vol. 75, No. 38/Friday, February 26, 2010/Proposed Rules, p. 8893) The oil and gas extraction industry leads all other natural resource extraction industries in the total volume of air emissions each year. (U.S. Environmental Protection Agency, EPA Office of Compliance Sector Notebook Project: Profile of the Oil and Gas Extraction Industry, October 2000, p. 63.) During routine drilling operations, very large levels of air pollution are emitted by the large diesel engines that power the drilling equipment. these engines create significant amounts of particulate matter that can contain heavy metals, volatile organic compounds, and polycyclic organic matter. They also emit sulfur oxides, a chemical associated with acid rain, and oxides of nitrogen, which contribute to smog formation. The air pollution associated with drilling deep wells can be exacerbated by long-term, multisite drilling operations. (Oak Ridge National labs and Resources for the Future, Estimating Externalities of Natural Gas Fuel Cycles, January 1998, p.77.)

OSHA states that major sources of air, water and ground pollution in oil and natural gas production are from oil spills and gas leaks. Serious health concerns range from apnea; coma; convulsions; irritated eyes; conjunctivitis pain, lacrimation, photophobia, corneal vesiculation; respiratory system irritation; dizziness; headaches, fatigue, insomnia; GI disturbances, all listed by EPA. OSHA states that workers exposed to lower concentrations of hydrogen sulfide may develop chronic bronchitis while other studies attribute poor attention span, memory and motor function to the gas. Individuals living near a gas/oil drilling operation, may be exposed to higher levels of hydrogen sulfide because these areas are prone to spills and fugitive emissions and, if undetected, can cause extensive damage to the entire facility. Fugitive emissions can just as well emit out of pipelines. Hydrogen sulfide is a colorless, transparent gas with a characteristic of a rotten-egg odor at low concentrations and not detectable by odor at high concentrations. High airborne levels of the gas catch fire, if there is a source of ignition, producing the highly toxic chemical, sulfur dioxide.


Under current policy, the EPA can only call for safety testing after evidence surfaces demonstrating a chemical is dangerous. As a result, EPA has been able to require testing for just 200 of the more than 80,000 chemicals currently registered in the US and has been able to ban only 5 dangerous substances.

The drilling of a water well next to the drilling site is of environmental concern if the water used in the process is extracted from existing groundwater, lakes, rivers, and streams. If the extraction of the gas/oil slows down, water is injected into the formation building up pressure in the reservoir so that more oil and gas are forced out of the formation. This method could impact an already low water table, such as found in Sand Lake. An environmental concern is the adverse affects of oil and gas drilling in and around wetlands. Wetlands are transitional lands between aquatic and terrestrial systems where the water table is at or near the surface of the land. About half of Michigan’s wetlands have been drained, which as caused significant declines in many wildlife communities. Wetlands are deemed important enough to have the State of Michigan institute the “Southeast Lower Peninsula Landowners Incentive Program Priority Area Townships” maps which highlights the wetlands of Lenawee County: Cambridge, Clinton, Franklin, Raisin, Tecumseh, Woodstock. Currently, all but one of these districts have private land leased to the oil companies. Incentives to restore habitat for wetland wildlife is outlined on the Michigan government website. Reasons for doing so are noted for the wetlands value to the community-- in the functions as floodwater storage areas, for water purification, sediment filtration and aquifer recharge, to name just a few. Wetlands provide breeding, nesting, and feeding grounds and cover for many forms of wildlife, waterfowl, including migratory waterfowl, and rare, threatened, or endangered wildlife species. In accordance to the GeomareAnderson Wetlands Protection Act, 1979 PA 203, which is now Part 303, Wetlands Protection, of the Natural Resources and Environmental Protection Act, 1994 PA451, as amended, the Department of Environmental Quality (DEQ) has adopted administrative rules which provide clarification and guidance on interpreting Part 303. Wetlands are regulated if they are ’connected to an inland lake, pond, river or stream and/or located within 500 feet of an inland lake, pond, river or stream. That describes the Irish Hills. In the Michigan Legislature - Section 324.30302 of the Natural Resources and Environmental Protection Act (excerpt) Act 451 of 1994: The legislature finds that: (a) Wetland conservation is a matter of state concern since a wetland of 1 county may be affected by acts on a river, lake, stream or wetland of other counties.

The legislature also acknowledges the importance of maintaining healthy wetlands for a variety of reasons. (b) A loss of a wetland may deprive the people of the state of some or all of the following benefits to be derived from the wetland: (i) Flood and storm control by the hydrologic absorption and storage capacity of the wetland. (ii) Wildlife habitat by providing breeding, nesting, and feeding grounds and cover for many forms of wildlife, waterfowl, including migratory waterfowl, and rare, threatened, or endangered wildlife species. (iii) Protection of subsurface water resources and provision of valuable watersheds and recharging ground water supplies. (iv) Pollution treatment by serving as a biological and chemical oxidation basin. (v) Erosion control by serving as a sedimentation area and filtering basin,


absorbing silt and organic matter. (vi) Sources of nutrients in water food cycles and nursery grounds and sanctuaries for fish. C. Wetlands are valuable as an agricultural resources for the production of food and fiber, including certain crops which may only be grown on sites developed from wetlands. D. That the extraction and processing of non-fuel minerals may necessitate the use of wetland, if it is determined pursuant to section 30311 that the proposed activity is dependent upon being located in the wetland and that a prudent and feasible alternative does not exist. E. In the administration of this part, the department shall consider the criteria provided in subsection (1).

With the State listing the benefits wetlands offer to humans and wildlife, and as the State officially supports wetlands through the Wetlands Protection Act-MCL 324.303 and the Federal Clean Water Act - Section 404, why are mineral right permits on lake lot properties being issued to oil and gas companies when the lakes are connected to the wetlands? The Federal government defines a wetland as: Those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs and similar areas. Not all wetlands are regulated under the Clean Water Act. Only those meeting the definition of Navigable Waters are. Navigable Waters (are) waters of the United States…. EPA has defined “waters of the United States” to include: wetlands “which could affect interstate…. commerce” because they are used by travelers for recreation… Tourism, the economy of the Irish Hills, depends on the lakes and wetlands for recreational purposes. The State of Michigan administers the Federal Wetlands Program under section 1344(g) of the Clean Water Act. As a result, applications for wetland permits are submitted to the DEQ, who forwards copies to the EPA for review. EPA then chooses which permits to comment on and notifies DEQ. If the DEQ does not resolve EPA’s objections, the authority over that specific permit is transferred to the Army Corps of Engineers. The process for EPA review of DEQ permits is found in 33 USC 1344(j). If a person violates this Act, the DEQ must issue an order requiring the person to comply within a reasonable time, OR request the Attorney General bring a civil action against them for injunctive relief and a fine up to $10,000 per each day of violation. Court may order the violator to restore the wetland as nearly as possible to its original condition. A citizens group cannot prove a MEPA case based solely on the fact that someone is filling or using a wetland without a state permit. They can bring a MEPA case if the harm to the wetlands is significant enough as a factual matter, however. This information is law, but it does little to ensure the viability of a town’s economy and health of it‘s inhabitants, if the main resource, water, is compromised by accident, incompetence, or an unforeseeable natural occurrence that could impact an already tenuous situation. Oil/gas drilling does not mix with water and the subsequent activities related to the use of water. + The Irish Hills is made up of 54 lakes, the basis of a tourism economy. + People who live in and around the lakes depend on groundwater for drinking water. + Water transport of contaminants results in contamination of surface water bodies through surface water drainage and by way of groundwater aquifers.


+ The movement of contaminants from soil occurs through evaporation and dust generation, intake by plants through their roots, and flushing by or dissolution into water seeping through the soil. Toxic contamination through water or soil or air impacts quality of life. + As pollutants from oil and gas drilling build up in the food chain, people who consume fish from the contaminated waters will be at serious risk of health problems. + The Irish Hills is the main head source of the River Raisin Watershed that covers roughly 1,072 square miles and contains approximately 429 lakes and ponds, more than 3,000 miles of man-made drainage systems, and 22 mainstream dams and 38 tributary dams. Located in southeast Michigan, the River Raisin flows through northeast Hillsdale County, southeast Jackson County, southwest Washtenaw County, eastern Lenawee County, northern Fulton County in Ohio and mid-Monroe County before emptying into Lake Erie. What the Irish Hills does, matters. + The Nature Conservancy, a US charitable environmental organization, is quoted on their website: www.nature.org as saying ‘time is of the essence to protect what we can of one of the very best warm water rivers (River Raisin) in Michigan.‘ TNC continues, ‘At least 84 fish species feed off the 216 aquatic insect species the River supports. Another 21 species of freshwater mussels make the River Raisin one of the most productive mussel habitats in the State, reaffirming the River’s good ecological health, as mussels are indicators of a healthy river system. Rare and endangered species also live in and around the River Raisin…’ Endangered are Kirtland’s Snake (Dodge 1998), the Small-mouth Salamander and the Indiana Bat. The Michigan Natural Features Inventory lists the Blanchard’s Cricket Frog (Dodge, 1998), the Blanding’s Turtle, Eastern Box Turtle, Spotted Turtle, Black Rat Snake and the Eastern Massasauga Rattlesnake. + The River Raisin Watershed Management Plan by the River Raisin Watershed Council states on pages 57 - 58, Chapter 3: The headwaters of the River Raisin has been identified as a high priority conservation target for its prime stopover habitat for migratory birds. An analysis of the Western Lake Erie basin by Ewert et al., (2005) investigated habitat characteristics of portions of 32 counties in Michigan and Ohio and ranked land area according to its value as a stopover site for migratory waterfowl, shorebirds, raptors, land birds and water birds. The Upper River Raisin contained the highest quality and most abundant habitat patches of any inland area suitable for birds in all of the above categories. This habitat is especially important for Michigan’s threatened and endangered species such as the short-eared owl, red-shouldered hawk, osprey, common loon and trumpeter swan. This high priority area is concentrated in the portion of the watershed contained by Jackson County, but includes smaller contiguous areas of Hillsdale, Lenawee, and Washtenaw Counties. There are also several high quality, mesic hardwood forests, riparian and floodplain forests, prairie ferns and remnant oak barrens in the upper watershed that support rare species that have been listed above.

The River Raisin Watershed Management Plan by the River Raisin Watershed Council, which was partially funded by Clean Water Act Section 319 Grant administered by the MDEQ (tracking code 2005-0117) and was approved by the EPA and the State of Michigan, summarizes water quality related issues and problems confronting the River Raisin and all its inhabitants – human and otherwise. Over a two-year period (2006-2008) a group of volunteers spearheaded a Steering Committee to develop the plan with the emphasis of achieving sustainability by fostering sustainable ecological, economic and social systems. As stated in the report, the three points are non-exclusive-- all three must mesh in order to develop truly sustainable solutions. The Steering Committee along with input from the public meetings developed a vision statement and a set of guiding principles for improving the watershed’s future outcomes.


River Raisin watershed residents recognize and celebrate their reliance on the river, the surrounding land and its interconnectedness with the Great Lakes and the global ecosystem. Together, communities, organizations and individuals will educate, understand and actively participate in the stewardship, conservation and preservation of the River Raisin and its cultural, ecological, and economic resources.

The Management Plan distinguishes certain areas within the watershed that maintain a high level of water and habitat quality. Those areas are the Upper River Raisin, including Goose Creek, Iron Creek and Upper River Raisin sub watersheds, of which Brooklyn/Irish Hills is a part. The reason for the quality is the three highest quality sub watersheds have the lowest wetland loss and agricultural land use; thus, the three sub watersheds are high priority for protecting and conserving existing quality. A component of the highest priority protection and conservation projects include policy and ordinance changes that put in place new measures for assessing and regulating land protection, conservation and development. River Raisin Watershed Management Plan Chapter 5 pg. 9

  For the River Raisin Watershed Management Plan to have been undertaken in the first place, reflects commitment to the natural resources and diverse ecosystems found in Lenawee County-- the River Raisin Watershed. Michiganders are not alone in their commitment to a clean environment and a healthy economy. A recent national poll demonstrates that Americans strongly support increased protection of our environment in general and our precious natural treasures in particular. (League of Conservation voters Education Fund, Michigan Citizens Agree: Oil and Water Don’t Mix, Press Release, 28 August 2001.)

Americans also clearly indicated their belief that stronger environmental laws are necessary for, rather than an impediment to, a healthy, productive economy. (League of Conservation Voters Education Fund, American Voters Place A High Priority On Environmental Protections, Despite Concerns About Energy and the Economy, 2001.)

So the question is: Why jeopardize the health and well being of human, wildlife, aquatic life, water, air, and wetlands that depend on a life-sustaining equilibrium, when that is the identity of the Irish Hills? It occurs to me that this may be a wake-up call, requiring each and every person who has invested in the bucolic image of the Irish Hills, to take a stand on higher ground. There is something to be said about social responsibility and becoming stewards of our ecosystem and not abusing it at the expense of one’s own gain. This is even more so when the quality of life for all in the Community is at stake. Pamela Bacon Brooklyn, Michigan


Irish hills oil Pam Bacon