To reach their conclusions, the EPA did not investigate, collect
evidence, or test in the field, but instead aggregated the reports and
research of others for analysis. Although this is a perfectly acceptable
practice, the shaky availability and reliability of information from
one group on which they depended means pivotal information was either
incomplete or lacking entirely.
At issue is the EPA’s fairly significant dependence on the
FracFocus Chemical Disclosure Registry
for an account of which chemicals are employed in the fracking
process. Well operators in some states are required by regulation to
disclose their chemical mixtures and some are not, but either way,
FracFocus disclosures are not only voluntary, but also subject to
proprietary conditions. If the compound is considered a trade secret,
it will remain
unknown and
unreported to the site.
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