For those concerned about the prospect of an oil well adjacent to the Florida Panther National Wildlife Refuge in southwest Florida – and in close proximity to the rural community of Golden Gate Estates – three meetings will be held this Tuesday, March 11th, at the Golden Gate Community Center, 4701 Golden Gate Parkway, Naples, Florida 34116-6901. Map to the location is here:
Meetings are scheduled as follows:
4 to 6 PM (Room A-B) – An informational meeting will take place on a Class II injection well for waste water disposal – to be built if and when the proposed oil well goes from exploration to production (meaning a commercially viable amount of oil has been found). Florida Department of Environmental Protection (DEP) has already approved this well and the U.S. Environmental Protection Agency (EPA) has approved it in draft form. The purpose of this part of the meeting is to provide information to the public on Class II injection wells, the laws and regulations which govern them, and the permitting process.
4 to 6 PM (Auditorium) – A meeting of the Big Cypress Swamp Advisory Committee will take place. This is the new kid on the block and needs a bit of explanation. Florida Statute 377.42 provides the following rationale for this committee: “To ensure compliance with all requirements for obtaining a permit to explore for hydrocarbons in the Big Cypress Swamp area, each application for such permit shall be reviewed by the Big Cypress Swamp Advisory Committee.” The statute goes on to explain how the committee will function: “If site-specific conditions require, the committee may recommend that additional procedures, safeguards, or conditions which are necessary to protect the integrity of the Big Cypress area be required as a condition to the issuance of a permit to drill and produce.”
This meeting was inserted into the day’s schedule (simultaneous with the above informational meeting on the Class II injection well) only after we (and our co-petitioners in this case “Preserver Our Paradise”) complained to the DEP at the administrative hearing which took place two weeks ago in Ft. Myers. We carefully explained that the committee’s review was mandatory and required by statute BEFORE a permit is signed. While DEP originally took the position that the committee did not have to meet – since their choice of a cleared piece of land for the well meant no new land impacts (and that is hardly accurate – there will indeed be new impacts – see below) – they finally decided to hold the meeting (although how they do that after a permit is signed and is under review by an administrative law judge remains an open question).
Given the broad nature of this committee’s work – a review of “all requirements for obtaining a permit to explore for hydrocarbons in the Big Cypress Swamp area” – we strongly felt this meeting should take place by itself and with sufficient time for the committee and the public at large to examine all relevant information. After much and back forth with the agency – we received the following reply from the DEP Counsel’s office at the end of last week: “Your comments are noted. However, the committee meeting will be going forward as scheduled.”
Finally, at the conclusion of the Big Cypress Swamp Advisory Committee, the EPA will move into the auditorium and take formal public comment on their Class II injection well draft permit from 6:30 to 8:30 as originally scheduled. If this sounds like a lot to cover – it is. But there was just no way to budge DEP from the fast-track they wanted to put the Big Cypress Swamp Advisory Committee on.
So be it. Lots of folks are going to be converging on Naples from around the area and state and there will be an opportunity for public comment. We will give it. Here are some issues to consider. A look at this aerial map of the well location will definitely help:
With regard to the oil well (and South Florida Wildlands’ focus on impacts to the Florida panther and other wildlife) – the following issues came out during the administrative hearing:
– The exploratory oil well is located in the primary zone of the Florida panther – and telemetry (electronic readings from collared panthers) show it to be an area of high level panther activity. This is not surprising considering the site is located on a piece of undeveloped land next to the Florida Panther National Wildlife Refuge (with the highest density of panthers in the state).
– The area just outside the pad contains extremely important wetlands. “Stumpy Strand” flows east of the site in a generally north to south direction. It connects with “Lucky Lake Strand” which flows into the Merritt Canal and into the Picayune Strand State Forest – site of an Everglades Restoration Project (at a cost of hundreds of millions of public dollars) currently in progress. The Panther Refuge boundary was expanded to encompass Lucky Lake Strand and prevent its future development. Considering the importance of these still pristine and irreplaceable wetlands to our wildlife and ecosystems, even small spills of oil or other fluids from this operation can have enormous implications.
– A road and drill pad will be constructed requiring over 14,000 cubic yards of fill material. If large dump trucks capable of carrying 20 cubic yards each are used, that would amount to approximately 700 truck loads. Additional equipment will be needed to move the fill around. Noise, vibrations, and dust will all be impacting the surrounding wildlife habitat, wetlands, and vegetation.
– The pad and 150 foot drilling tower will be lit up at night. Drilling will be going on around the clock. Three generators will be powering this massive industrial operation. Noise, light, dust, odors and vibrations will clearly be impacting the surrounding area. Before drilling begins, a steel pipe 24 inches in diameter will be pounded into the ground by a pile driver to a depth of 250 feet. The noise from that activity is expected to be extremely loud.
– It is expected that wildlife will be disturbed by these combined operations and will be displaced by them. In the case of panthers this can be extremely dangerous. Large amounts of panther roadkill – the leading cause of death for this highly endangered species – have already been documented in this area – especially along I-75 just south of the drill site. Intra-specific aggression – or panther on panther fights over territory which often end in the death of one of the participants – is the second leading cause of death for Florida panthers. In a high panther density area like this, there is a definite possibility that a displaced panther will end up in another’ panther’s home range – and will not have a happy ending. Lastly, only a relatively small number of the 100 to 160 panthers remaining in Florida (and most are in this narrow belt of land between I-75 and the Caloosahatchee River) have been collared. There is a possibility that an uncollared female panther
with kittens could abandon a den leading to the death of her offspring. Three panther dens (from collared females) have been historically documented in the vicinity of this well.
None of the above issues were considered by DEP in their approval of this exploratory oil well. They did request consultation from the Florida Fish and Wildlife Conservation Commission (FWC) and the U.S. Fish and Wildlife Service (FWS). Unfortunately – and as we reported in our previous email – no consultation from either agency was provided.
With regard to the Class II injection well – I would highly recommend a read of the following investigative article – “Injection Wells: The Poison Beneath Us” from the Pulitzer Prize winning journal Propublica. You can find it here:
In their own summary of Class II injection wells, the EPA describes the process as follows:
“When oil and gas are extracted, large amounts of brine are typically brought to the surface. Often saltier than seawater, this brine can also contain toxic metals and radioactive substances. It can be very damaging to the environment and public health if it is discharged to surface water or the land surface. By injecting the brine deep underground, Class II wells prevent surface contamination of soil and water.”
The Propublica article explains some of the problems. Casings used to transport these toxic fluids can and do leak – and the movement of the fluids once it gets down to its target depth is often unknown. Far from the nice layered geology we see in textbooks, real geology is not neat – nor is it ever fully understood. Injectate – the fluid dumped down these holes – can move vertically into upper aquifers used for drinking water – or horizontally into other water bodies. In the case of a well like this – which is simply a dumping ground for a still to be determined amount of waste water – the risks to our wildlife, habitat, and drinking water are simply too high.
If you’ve read this far – thanks a lot. Long as this email is, it is still only a tiny summary of the issues DEP and EPA will be attempting to squeeze into Tuesday’s meetings. Hope to see as many of you as possible come this Tuesday.
South Florida Wildlands Association
P.O. Box 30211
Ft. Lauderdale, FL 33303
P.S. South Florida Wildlands Association can only carry out this work through the generous donations of our supporters. Many of you have stepped forward in recent months – and your assistance has been greatly appreciated. But as we mentioned in our last email on the topic, the wells which are the subject of this Tuesday’s meeting – an exploratory drilling well and Class II injection well – are in reality only the tip of the iceberg. A major “oil play” is now taking place in southwest Florida and hundreds of thousands of acres of primary and secondary Florida panther habitat have recently been leased by Collier Resources for oil drilling or seismic operations. With crude oil now going for over $100 per barrel – there is a lot of money to be made here. One of those leases recently permitted – to Tocala LLC – is on approximately 100,000 acres of land just north of the Florida Panther National Wildlife Refuge and the Bear Island Unit of the Big Cypress National Preserve.
It is heavily used by panthers and contains a section of State Road 29 which probably sees more panther roadkill than any other route in Florida. South Florida Wildlands was the only organization which filed within the time limit to get in a petition for another administrative hearing. If you have the ability – please consider a donation to allow us to carry out this fight and others. Our organization is a fully recognized 501c3 non-profit and contributions are tax-deductible to the fullest extent of the law. Our donation page can be found here:
Our work in this area has been well-covered in the media. Some of the pieces featuring South Florida Wildlands Association and South Florida’s new oil boom can be found below. They will also provide background for those attending Tuesday’s meeting.
Special thanks to Richard Charter