Introduction -- Fracturing fluids: some are hazardous -- Some hydraulic fracturing fluids are hazardous to human health -- Voluntary agreement to stop using diesel does not eliminate health threat -- Much more information is needed to understand the toxicity and health hazards posed by hydraulic fracturing fluids -- Fracturing fluid recovery: incomplete -- EPA study lacks data on the recovery of injected fracturing fluids -- EPA uses a theoretical, best-case scenario, without any supporting data to conclude that stranded fracturing fluids will not harm USDWs -- EPA fails to examine long-term impact of fluids stranded in CBM formations -- EPA does not discuss the toxicity of produced water that contains residual fracturing fluids -- Fracture behavior: unpredictable -- Fractures and fracturing fluid can move out of target formations -- Fracture behavior is poorly understood -- Critique of EPA's study and analyses -- Data gaps plague EPA study -- EPA selectively includes and excludes information that does not have scientific studies of data to back it up -- Lack of confirmed contamination cases does not prove that harm has not occurred or will not occur -- EPA is not being consistent in its level of protection of groundwater or human and ecosystem health -- Discussion: non-toxic alternatives exist -- Non-toxic hydraulic fracturing fluids are being developed, and some already exist -- Several studies show that water is an effective fracturing fluid, and that it is more economic and less destructive than gel-based fluid -- Conclusions -- Recommendations.