John Amos testifying before Congress in May on a proposed rule to regulate hydraulic fracturing (fracking) on millions of acres of public lands, and on the inadequacy of industry-funded FracFocus to serve as the outlet for data critical to inform academic research, regulation, and the public.

DEADLINE: All comments on the Bureau of Land Management’s (BLM) proposed rule – Oil and Gas: Hydraulic Fracturing on Federal and Indian Lands – must be submitted before midnight TONIGHT (11:59 pm EDT – August 23, 2013).
Access to spatial data about environmental issues is fundamental to SkyTruth’s work examining practices like fracking, and we are concerned that regulations proposed by the BLM fall short of the transparency necessary to understand the impacts of fracking that would potentially occur on millions of acres of public land. By designating FracFocus as the disclosure outlet for data about all fracking operations on over 750 million acres of federal and tribal lands, anyone wishing to examine the data and draw meaningful conclusions about the impacts of fracking on water quality and water use, public safety, and any other research purposes, will be restricted by the limitations of this industry-funded platform.

Early this year we estimated that the work we did to compile all of the data from FracFocus would have taken a layperson 6 years of full-time effort, almost $90,000 at minimum wage and no benefits, to copy and paste the whole database as it existed in April. We have written before about this disclosure issue, met in person with leadership at the BLM, and testified before Congress about the need to fix this shortcoming.

In short, we believe the following changes must be made to the BLM rule in order to comply with this administration’s Open Government initiatives and adequately inform the public about fracking on lands that belong to all of us:

• Minimum – Publish the entire collection in a simple standard text format (such as CSV) that can be imported directly into a spreadsheet or database.
• Better – Provide a way to bulk-download the disclosure data, in machine readable format, through a search query.
• Best – Automatically re-publish FracFocus disclosure data to Data.gov (a web portal providing public access to Federal government datasets) or a similar Open Data Initiative-compliant publication portal.

Based on our experience, an effective platform for the public disclosure of the chemicals used in hydraulic fracturing operations should, at a minimum:

• Enable the bulk download of data in a machine-readable (not PDF) format.
• Impose no intellectual property restrictions.
• Designate an official legal reference copy of all chemical disclosure reports.
• Identify an official publication date for all chemical disclosure reports.
• Incorporate a document change management system to clearly identify additions or revisions.

These recommendations are a bare minimum to understand the full scope of the issue; please consider including them in your own comment to BLM. Our comments are only one part of the big picture, but they are fundamental to addressing other issues such as industry’s use of trade secret exemptions to withhold data. Our interest is to inform the public and decision-makers about the environmental impact of these activities and produce scientifically robust images and resources. We encourage everyone to review our comments and resources on this issue, draw your own conclusions on the issue, and take an active role in the democratic process.

To review our full comments and recommendations, click here.