Injection wells dispose of problematic liquid wastes by pumping them into porous rock formations thousands of feet beneath the surface of the earth. There are hundreds of injection wells in the state of Ohio, and the communities whose water and way of life they put at risk have no say where they are drilled and operated.

The following open letter from Coshocton County leaders asks Ohio legislators to pass laws that empower communities, offer better protection from injection wells, and require more transparency from government and industry. It was delivered to the legislators it addresses on January 24, 2024. The original authors and signatories of this letter invite fellow Ohioans to show their support for the policy changes outlined in the letter by signing this petition. 

Dear Gov. DeWine, Sen. Brenner, Rep. Kick, House Energy and Natural Resources Committee, Senate Agriculture and Natural Resources Committee, and legislative colleagues:

We write as a coalition of concerned business owners and local leaders from Coshocton County to (1) express our grave concerns about how the state of Ohio is regulating its Underground Injection Control (UIC) programs and (2) request legislative action. 

As you are undoubtedly aware, in September, a Coshocton injection well facility operated by the Texas-based company Buckeye Brine began accepting huge quantities of treated wastewater from the site of the East Palestine train derailment. In response, the offices of Coshocton Mayor Mark Mills and the Coshocton County Commissioners published a joint press release condemning Buckeye Brine’s decision to dispose of this waste in our community. Additionally, hundreds of concerned citizens have attended community meetings and protests to express their opposition to our county being used as a dumping ground. But the outcry of local officials and residents, along with their pleas for help from their legislators, have gone unheeded. As of the publication of this letter, Buckeye Brine has disposed of more than 3.5 million gallons of wastewater from the East Palestine cleanup efforts beneath the water sources and land on which our county’s residents, businesses, and visitors depend. It adds to more than a billion gallons of fracking and industrial wastewater injected by Buckeye Brine since 2012.

This situation is just the latest in a series of events that underscore how little power we have to determine what wastes get disposed of via deep injection wells in our county. We are especially concerned by this state of affairs given the numerous accidents, violations, and failures that have occurred at or en route to injection wells in the state of Ohio. Toxic brine from oil and gas wells has been spilled during transport to injection well facilities in Belmont County​, Morrow County, and Coolville, contaminating vital water sources. Wastewater disposed of via injection wells has migrated underground and erupted from regular oil wells up to five miles away in Nobel, Washington, and Athens Counties. A 2022 technical analysis conducted by Physicians, Scientists, and Engineers for Healthy Energy found the Class II injection well program regulated by ODNR does not adequately protect Ohioans from health and environmental risks and is in desperate need of reform.

The citizens of our county have no recourse in the face of violations, like the one that occurred at Buckeye Brine’s Coshocton facility on October 12, 2023. On that day, a UIC inspector noticed that flowback was occurring at one of the Class I wells. More than 4,500 gallons of fluid had to be siphoned from the injection tubing via vacuum truck. While the flowback was ultimately contained, we believe it is only a matter of time before an incident that contaminates our land or water occurs. We don’t want to be the next Athens County, where Ohio’s Underground Injection Control program failed to protect residents from having their groundwater and surface water contaminated by injection wells.

Requiring communities to take on these risks without their consent and without adequate compensation is unethical. We are writing to ask that you, our elected representatives, take legislative action. Please propose and advance changes to the Ohio Revised Code that will (a) support community involvement and consent in the siting and permitting of injection wells in the state of Ohio, (b) protect your constituents, and (c) require greater transparency about injected wastes. In particular, we support the following amendments and changes to the Ohio Revised Code for Class I and Class II UIC programs:

1. Enact policies and procedures that prioritize consent-based siting for all underground injection activities. As defined by the U.S. Department of Energy (USDE), consent-based siting is “driven by community well-being and community needs,” and it “enables broad community participation” in site selection. The USDE provides a viable model in the consent-based siting process it developed for nuclear waste disposal. This process should be replicated or adapted for Ohio’s UIC programs.

2. Impose regulations that better protect communities where injection wells are located. Specifically:

• Set lifetime caps on the amount of fluid that may be injected into a well.
• Set caps on the number of wells that may be drilled and operated within a 10-mile radius.
• Set a minimum distance that injection wells may be drilled from existing oil and gas infrastructure.
• Set a minimum distance that injection wells may be drilled from schools, medical facilities, businesses, residences, and places of worship.
• Require operators to develop detailed emergency response plans in case of leaks, spills, or other incidents in collaboration with local emergency services. Plans should be available to the public.
• Implement a regime of regular, independent health and environmental monitoring in the vicinity of injection wells with results made available to the public.
• Establish stronger penalties for companies that fail to comply with regulations, including substantial fines and the possibility of permit revocation, as a deterrent against cutting corners or neglecting safety and environmental standards.

3. Integrate more research in the site-selection and permitting process to ensure that communities are adequately protected. Specifically, please fund development and require the use of technologies that:

• Accurately map underground features (without drilling additional holes) so that experts can predict the movement and flow of waste fluid within the injection zone.
• Locate natural fractures in the confining zone that could compromise the integrity of the rock layers that are supposed to confine injected wastes.

Additionally, at the outset of the permitting process, ODNR and the Ohio EPA should also be required to commission studies that:

• Investigate the extent to which local industries and lifeways depend on natural resources, including groundwater, surface water, and undeveloped land.

Legislation should stipulate how this information should be used in site-selection and permitting of injection wells.

4. Use taxes and fees to ensure that municipalities with deep injection wells are financially compensated for the risks they assume and adequately prepared for cleanup costs if and when contamination occurs. Currently, the state of Ohio imposes surcharges on the disposal and transfer of municipal solid waste (ORC Section 3734.57). We request legislation that exacts similar fees on the transfer of liquid wastes and their disposal via injection well, to be deposited in funds dedicated to:

• Waste management and cleanup
• Environmental protection
• Local risk compensation (dispersed to municipalities where deep injection wells are located)
• Research and monitoring efforts by the Ohio EPA and ODNR

5. Enact policies that enhance communication and transparency regarding injection well activities. In particular, we request that you create laws that:

• Require full disclosure of financial interests and potential conflicts of interest for all parties involved in the approval and operation of injection wells.
• Grant municipal governments the authority to sample and test wastes that are being disposed of at sites in their jurisdiction.
• Require the Ohio Department of Natural Resources and the Ohio Environmental Protection Agency to notify local governments and the public any time a violation occurs at an injection well facility in that municipality.

Please, take action to protect our community and other Ohio communities with the urgency this matter deserves. We eagerly await your response to this letter. 

Endorsed by:

• Coshocton City Council
• Coshocton County Board of Commissioners
• Coshocton Park District Board of Commissioners
• Coshocton Visitors Bureau Board

Original Signatories:

1. Tisha Babcock, Facility Administrator, Genesis Coshocton Medical Center
2. Matthew Babson, Owner, Whitetail Dreams Outfitters LLC
3. Thomas Barcroft, Councilman at Large, Coshocton City Council
4. Douglas Beckley, Owner, Beckley Trucking LLC
5. Amy Borton, Owner, Our Nest on Main
6. Mindy Brems, Executive Director, Coshocton Visitors Bureau
7. Lainie Brillhart, Manager, Eagle Ridge Disc Golf
8. Casey Brown, Director of Operations, Roscoe Village Foundation, Inc.
9. Matt Colvin, Superintendent, Coshocton County Career Center
10. Rick Conkle, Coshocton County Commissioner
11. Stephanie Conn, CEO, Coshocton Regional Medical Center
12. Mike DePalma, President, Coshocton County Outfitters
13. Kayci Dickerson, Owner, Village Massotherapy
14. Russell Dreher, Chief, Coshocton Fire Department
15. Jeff Drennen, Owner and President, Jeff Drennen Dealerships
16. Stacey Drennen, Owner, Huck’s Tavern
17. Danielle Ellis, Erwin Family Eye Care, Doctor of Optometry
18. Kurt Ellis, General Manager, Pearl Valley Cheese
19. Kevin Ely, Owner and President, Wooly Pig Farm Brewery Co.
20. David Erwin, Erwin Family Eye Care, Owner and Doctor of Optometry; President, Coshocton Park Board of Commissioners
21. Corey Fischer, Councilman, Village of Warsaw; Director, Fischer Funeral Home
22. Gary Fischer, Coshocton County Commissioner
23. Jesse Fischer, Council President, Warsaw Village Council; Director, Fischer Funeral Home
24. Brad Fuller, Owner, Good Boy Bakery / Roscoe General Store
25. Cathy Fuller, Owner, Good Boy Bakery / Roscoe General Store
26. Michelle Turner Ganz, CEO, Dean’s Jewelry; Councilman at Large, Coshocton City Council
27. Janelle Given, Owner, Jillian’s Salon
28. Erin Gotwals, Co-owner, Strawberry Hill Farm
29. Terri Grove, Owner, Palmbay Studio
30. Rachel Jane Hall, Owner / Artist, Hillbippie Clay Co. LTD
31. Kirby Hasseman, CEO, Hasseman Marketing
32. Tom Hilgenberg, President, Coshocton City Council
33. Brittany Howell, Councilwoman, West Lafayette Village Council; Vice-President, Fidelity Title and Closing Services, Inc.
34. Chad Johnson, 2nd Ward Councilman, Coshocton City Council
35. David A. Kadri, Utility Director, City of Coshocton
36. Tim Kettler, Owner, Action Septic Service Inc.
37. Mark Kowalski, Superintendent, Coshocton City Schools
38. James Kreis, Councilman at Large, Coshocton City Council
39. Steve Lonsinger, M.A., REHS, Health Commissioner, Coshocton Public Health District
40. Jael Malenke, Owner and CEO, Wooly Pig Farm Brewery Co.
41. Lucy Bryan Malenke, Owner, Personal Statement Lady
42. Nathan Malenke, Owner, NTM Knives
43. Mike Masloski, Superintendent, Ridgewood Local School District
44. Robert McKenna, Owner, Unusual Junction, Inc.
45. Camille McPeek, Co-owner and Operator, Coshocton KOA Holiday
46. Ryan McPeek, Co-owner and Operator, Coshocton KOA Holiday
47. Chris Meyer, Owner, Sylvan Craft LLC
48. Matthew T. Miller, Owner, Miller Funeral Home
49. Kathy Milligan, Member, Coshocton Park Board of Commissioners
50. Mark Mills, Mayor of the City of Coshocton
51. Roger Moore, 3rd Ward Councilman, Coshocton City Council; Board Member, Coshocton Park Board of Commissioners
52. Jan Myers, Director of Operations, Universe Bridal & Prom and McKenna’s Market
53. Lynn E. Powelson Jr., Fire Chief, Three Rivers Fire District
54. Allison Reed, Owner and Dentist, Reed Family Dental
55. Chuck Rinkes, Superintendent, River View Local Schools
56. Tammi Rogers, Director, Coshocton Park District
57. Angie Sabatucci, Executive Director, Kids America, Inc.
58. Rev. Joseph D. Sanders, Pastor, First Baptist Church of Coshocton
59. Dave Saylor, Council Member, Conesville Village Council
60. Jill Sheridan, Owner, Rust Decor
61. Dane Shryock, Coshocton County Commissioner
62. Amy C. Shutt, Council Clerk, City of Coshocton
63. Janae Stevens, Owner, LeRetilley Event Center
64. Laurence Szeliga, Owner, MYOB Publishing, LLC
65. Audrey Tubbs, Owner and Operator, Fred’s Got Worms
66. Jessica Tubbs, Mayor, Village of West Lafayette
67. Timothy Tubbs II, Owner and Operator, Yippee Kayak
68. Ronald Wahl, President, J & R Door, LLC
69. Elizabeth Ward, Owner, Dile’s Faithful Cleaning
70. Linda Weber, retired magistrate, Coshocton County Board of Health
71. Renee Whinnery, Owner and Operator, Golden Sky Farm
72. Peter Wolfgang, Pastor, Conesville and New Moscow United Methodist Church