Dr. David Wheeler Nova Scotia Expert Panel on Hydraulic Fracturing Cape Breton University P.O. Box 5300, 1250 Grand Lake Road Sydney, N.S. B1P 6L2 Submission to the Nova Scotia Expert Panel on Hydraulic Fracturing April 24, 2014 Dear Dr. Wheeler and Panel Members, We are writing to you as concerned citizens about hydraulic fracturing in this province. As faculty and nurse educators in the School of Nursing at St. Francis Xavier University we have a broad perspective on health and the factors that determine health. We understand health as the physical, mental, social and spiritual well being of individuals, communities and populations which is determined by a range of factors known as the social determinants of health. It is from this perspective that we want to raise concerns about the potential effects of hydraulic fracturing on the communities and diverse populations of Nova Scotians. Following our preliminary review of the literature on hydraulic fracturing, including a number of articles listed on your website, we realized that there is a very significant lack of data about the potential effects of fracturing on the very complex interactions of physical, social, economic and environmental aspects of communities. 1,2,3,4. As Dr. Cleary emphasizes in her report to the government of New Brunswick, “Few studies have been undertaken that consider the overall potential impacts on health and the physical and social environments over the entire lifetime of the industry”, pg 204. A glance at the Research Reports and Documents section of your website indicates that there is growing anecdotal evidence of the impact of hydraulic fracturing on the water, air quality and physical health of people. Some common symptoms identified among people who live close to fracking sites include fatigue, burning eyes, dermatological irritation, headaches, upper respiratory, gastrointestinal, musculoskeletal, neurological, immunological, sensory, and vascular, bone marrow and urologic problems, and risk of endocrine disruption.5 However, there are to date no comprehensive epidemiological studies planned or underway that will conclusively verify or deny that the full hydro fracturing process harms humans, animals or the environment.6 While drilling companies argue that there are significant positive economic effects for hydraulic fracturing, some authors argue that the cost for the state, social services and the impacts on the environment have not been considered.7 It has been identified by a number of authors that the impact of the “Boom Bust Cycle” or “Boomtown Effects” has not been taken into consideration from a health or economic perspective. 8,9. There are numerous social problems that can arise such as sexually transmitted diseases, domestic violence, lack of sufficient decent housing and increased cost of living, as well as the effects on the noise and pollution levels due to increased traffic. The potential for unequal distribution of the benefits of unconventional gas extraction can lead to conflicts in the communities. Since there are many gaps in the data on the effects of hydraulic fracturing on the natural environment and on human physical, social, mental, and economic health, many authors argue that the “precautionary principle” should be applied to any future decisions about fracking in Nova Scotia. Many more longitudinal epidemiological studies on the physical and social environments should be conducted by independent researchers. In addition there needs to be more comprehensive analysis and forecasting of potential health effects in communities that are close to drilling sites. As the Chief Medical Officer for New Brunswick recommended, a Health Impact Assessment (HIA) should be conducted to identify these potential impacts on the health of the communities and states. We would also recommend, in addition to the HIA, a community driven health impact assessment, which is a method that allows the voice of the community to be heard in decisions about fracturing in or near their communities. This methodology, which was developed in Northeastern Nova Scotia in the mid 1990s by the People Assessing Their Health (PATH) network, has been used by communities around the globe and across Canada to determine the potential positive and negative effects of a policy or program. 10 As has been noted in this letter, there is significant concern among many groups and authors about the complex nature of this industry on the health of people, communities and the environment that hydraulic fracturing should not occur in Nova Scotia until much more data is collected by various methods. For this reason we implore you to consider a recommendation for a 10 year legislated moratorium to be imposed until the potential effects of this unconventional method of gas extraction is fully understood. The risk to the health of people, the environment and future generations of proceeding with the development of fracking is far too great for the purported benefits. Thank you for allowing us to put forth our concerns to this panel and for the work that you are doing on this contentious issue. Sincerely yours, Colleen Cameron Nurse Educator accamero@stfx.ca 867-3895 Yvonne Fraser Nurse Educator yfraser@stfx.ca 867-3879 Ellen MacFarlane Professor emacfarl@stfx.ca 867-2487 Patti Hansen-Ketchum Professor phketchu@stfx.ca 867-5027 Marian MacLellan Professor mmaclell@stfx.ca 867-5081 Marie Arnott Professor marnott@stfx.ca 867-4981 Wendy Panagolopoulos Nurse Educator wpanagop@stfx.ca 867-3391 Barb Sproull-Seplaki Professor bseplaki@stfx.ca 867-3449 Ann Marie Dobbin Nurse Educator adobbin@stfx.ca 867-3390 Cathy MacDonald Professor cdmacdon@stfx.ca 867-4537 Hope Graham Professor hgraham@stfx.ca 867-2434 Jane Moseley Professor jmoseley@stfx.ca 867-3582 Susan Wood Nurse Educator swood@stfx.ca 867-5354 Elizabeth McGibbon Professor emcgibbo@stfx.ca 867-5429 Karen Briand Lecturer kbriand@stfx.ca 867-5852 Patsy MacDonald Program Coordinator pmacdona@stfx.ca 867-5186 Joanne Whitty-Rogers Professor jrogers@stfx.ca 867-3629 1 M. L Finkel, J. Hays, The implications of unconventional drilling for natural gas: a global public health concern, Public Health 127 (2013) 889 - 893 2 American Public Health Association Policy Statement Database, the environmental and occupational health impacts of high-volume hydraulic fracturing of unconventional gas reserves. (2012). 3 J. L., Adgate, B. D. Goldstein, & L. M. McKenzie, Environmental Science & Technology, Potential public health hazards, exposures and health effects from unconventional natural gas development 4 Cleary, E., Chief Medical Officer of Health’s Recommendations Concern Shale Gas Development in New Burnswick, Office of the Chief Medical Officer of Health New Brunswick, Dept of Health, 2012. 5 MacDermott-levy, R., Katkins, N., Sattler, B., Fracking, the environment and health; New energy practices may threaten public health. American Journal of Nursing, 2013, Vol 113, No. 6. 6 Bernard D. Goldstein, E. Ferrell Bjerke & Jill Kriesky, Challenges of Unconventional Shale Gas Development: So What's the Rush, 27 Notre Dame J.L. Ethics & Pub. Pol'y 149 (2013). Available at: http://scholarship.law.nd.edu/ndjlepp/vol27/iss1/7 7 Bernard D. Goldstein, E. Ferrell Bjerke & Jill Kriesky, Challenges of Unconventional Shale Gas Development: So What's the Rush, 27 Notre Dame J.L. Ethics & Pub. Pol'y 149 (2013). Available at: http://scholarship.law.nd.edu/ndjlepp/vol27/iss1/7 8 Cleary, E., Chief Medical Officer of Health’s Recommendations Concern Shale Gas Development in New Burnswick, Office of the Chief Medical Officer of Health New Brunswick, Dept of Health, 2012. 9 American Public Health Association Policy Statement Database, the environmental and occupational health impacts of high-volume hydraulic fracturing of unconventional gas reserves. (2012). 10 C. Cameron, Community Driven Health Impact Assessment, Coady International Institute, St. Francis Xavier University, Antigonish, NS, B2G 2W5. Found at http://www.coady.stfx.ca/education/certificates/health_2014/