Violations per Well Among PA Operators

Note

This post has been archived. It is provided here for informational purposes only.

People often want to know which operators perform the best (or worst) among their peers in terms of adhering to the laws set forth in a given state. In principle, the easiest metric for determining this is to look at the ratio of violations issued per well, or VpW.

However, in order to make that analysis, we would obviously need to have violations data. Unfortunately, out of the twenty states that we have shale viewers for on FracMapper, we only have violations data for Arkansas, Colorado, and Pennsylvania, with the latter being far and away more robust and complete when compared to the other two. We have been told that the data is also available for North Dakota as well, if we are willing to pay for it, so we might be able to perform a VpW analysis for the Peace Garden State in the near future.

Then, of course, there is the realization that, “What is a violation?” is actually somewhat of a philosophical question in Pennsylvania.  In the past, I’ve determined that the Pennsylvania Department of Environmental Protection (PADEP) uses the number of unique violation ID numbers issued to calculate their totals. However, historically, the department would often lump several issues that showed up on the Compliance Report together under the same violation ID.  Others have taken to looking at Notices of Violations (NOV’s), which are more limited in number.  Still others exclude any violations marked as being administrative in nature, an idea that makes sense superficially, but a closer look at the data shows that the label is extremely misleading.  For example, “Pits and tanks not constructed with sufficient capacity to contain pollutional substances” is an administrative violation, as is, “Improper casing to protect fresh groundwater”.

In addition to all of that, the cast of operators is constantly shifting as new operators come on board, old ones get bought out by rivals, joint ventures are formed between them, and the like.  Sometimes a parent company will shift the active operator status to one of its subsidiaries, so wells that were originally Consol will then be listed under CNX, for example.

In terms of violations per well, there is a further complication, in that all of the drilled wells data reflect the current custodians of the wells, whereas the violations data reflect those that received the violations.  The result is that there are records issued for Turm Oil (really!) for wells where Chesapeake is now listed as the operator.  In some respects, this makes sense:  why should Chesapeake carry the burden of the legacy mistakes of Turm in their compliance record?

But it does make analysis somewhat tricky.  My approach has been to combine operators that are obviously the same parent company, and to do the analysis in several different ways, and over different time frames.  Who’s ready for some numbers?

Violations per Well (VpW) for operators of unconventional wells in Pennsylvania with 50 or more wells. Those operators with scores higher than the average of their peers are highlighted in pink.

Violations per Well (VpW) for operators of unconventional wells in Pennsylvania with 50 or more wells. Those operators with scores higher than the average of their peers are highlighted in pink.

Here, violations per well are based on the number of violation ID’s issued, where as NOVpW is based on the number of Notices of Violations.  The date range for this table is from January 1, 2000 through October 21, 2013, and please note that the totals represent those that are included on the chart, not statewide totals.  A lot of violations are lost of the shuffle when we look at only the largest current operators, but it also helps eliminate some of the noise that can be generated with small sample sizes, as well as with the inconsistencies described above.  Here’s a look at data from this year:

Violations per Well (VpW) for operators with unconventional wells in Pennsylvania in 2013, through October 21. Those operators with scores higher than the average of their peers are highlighted in pink.

Violations per Well (VpW) for operators with unconventional wells in Pennsylvania in 2013, through October 21. Those operators with scores higher than on violation per well or NOV per well are highlighted in pink.

Notice that the highest violations per well and notices of violations per well scores are much higher than the data aggregated since 2000, whereas the statewide averages of the two scores are actually much lower.  The former is almost certainly attributable to having a smaller sample size, but there is something else at play with the latter:

Violations per well of Pennsylvania's unconventional wells. 2013 data through 10/21/2013.

Violations per well of Pennsylvania’s unconventional wells. 2013 data through 10/21/2013.

The number of violations per well drilled has been steadily decreasing since 2009, and it is now down to an average of less than one violation issued per every two wells.  There is nothing in the data that indicates why this is the case, however.

Note:  This post was edited on 12/18/2013.  The table showing operators violations per well and NOV’s per well in 2013 originally stated that that values higher than the average of their peers are highlighted in pink.  In fact, only those with values of 1.00 or higher are highlighted in that fashion.

Severed rights and leased lands in PA state forests

Leases and Severed Rights in PA’s State Forests

A few years ago, the Department of Conservation and Natural Resources (DCNR), the agency responsible for state park and state forest lands throughout Pennsylvania, published maps on their website showing which state forest lands had been leased for the purpose of unconventional oil and gas exploration and development.  Not only has that page been taken down, but the data are also not among the hundreds of Pennsylvania-specific datasets available on the Pennsylvania Spatial Data Access (PASDA), to which DCNR is a key contributor.

This data does still exist though, and it was provided to the FracTracker Alliance from DCNR upon request, along with data showing areas of the state forest where unconventional oil and gas rights are owned by the state, which is not always the case.  However, this fulfillment of our data request came with some strings attached:

  1. I understand that the accuracy of this data set and its boundaries cannot be guaranteed and should not be considered precise.
  2. I will not distribute raw data to other entities outside the scope of this request.
  3. I will annually provide the Bureau of Forestry with a status update of the project activities and findings.  If the project is abandoned, I will provide the Bureau of Forestry copies of the available information from the project.
  4. I will provide the Bureau of Forestry with copies of draft reports, articles, publications and so forth that result from this analysis.
  5. If requested, I agree to supply the Bureau of Forestry with copies of data analysis.
  6. I understand that the Bureau of Forestry or the Commonwealth of Pennsylvania is not relinquishing any rights or interests with this agreement.

Obviously, this ties our hands with regards to making the data available for download, either through the download section of our site, or through ArcGIS Online, but we feel as if the scope of our request was worded in such a way as to allow us  to produce a map of these layers, and make that available for public viewing.  Readers interested in obtaining similar data will have to contact DCNR directly, until the agency decides to release the data regarding Pennsylvania’s public lands without conditions.

We have combined this data with drilling data from the Pennsylvania Department of Environmental Protection, so that we can finally take a closer look at drilling on public lands in Pennsylvania, including an approximation of which wells are drilled on lands have been leased by the state, and which by third parties.  So with all appropriate disclaimers, here is that map:


Drilled unconventional wells in Pennsylvania and control of mineral rights on state forest land. To access full controls, such as legends, layer controls, and layer descriptions, please click the expanding arrows in the top-right corner of the map.

Determination Letters Added to PADEP Groundwater Complaints Map

A couple of months ago, Laura Legere of the Scranton Times-Tribune published an article showing her research into determination letters sent by the Pennsylvania Department of Environmental Protection (PADEP) in response to people who claimed that their groundwater had been impacted by oil and gas activity in the state.  Of the 973 complaints represented on this dataset, the PADEP has determined a causality between the oil and gas activity and the water complaint in 162 instances.  Note that not all of these complaints are necessarily as a result of the hydraulic fracturing (a.k.a. fracking) stage of operations.

The FracTracker Alliance assisted in the project by creating an interactive map of the instances throughout the state.  As the Scranton Times-Tribune has now made digital scans of each of the 973 records available on their servers, we have been able to link to them on the map.

In this screen capture, the popup box for the first of eleven complaints mapped at this location is shown.  In order to access the determination letter, the user must simply click on the PDF logo.

In this screen capture, the popup box for the first of eleven complaints mapped at this location is shown. In order to access the determination letter, the user must simply click on the PDF logo.

Names, addresses, and other personal information about the complainants have been removed from this dataset in order to protect their privacy.  And because the locations are drawn at the center-point of the municipality in which they live, we can get a general sense for the distribution of the events without being able to zoom in one the affected parties’ houses.

To get an idea of what the determination letters look like, here is one example in which the PADEP indicates that someone’s water supply has been impacted by gas drilling:

A portion of one of the determination letters sent by PADEP to a landowner in response to a complaint about groundwater.  Click the image to access the full PDF file.

A portion of one of the determination letters sent by PADEP to a landowner in response to a complaint about groundwater. Click the image to access the full PDF file.

Here is the dynamic version of the map of the complaints:


Please click on the Fullscreen icon to load our full suite of controls.

This updated data has also been added to the US Map of Suspected Well Water Impact project:

PA Unconventional Drilling Activity Trends

The Pennsylvania Department of Environmental Protection (PADEP) publishes data on unconventional oil and gas permits, drilled wells, and violations. The FracTracker Alliance has taken this data, and summarized it by month:

Permits issued, wells drilled, and violations issued for unconventional oil and gas wells in Pennsylvania from January 2005 through May 2013.

Permits issued, wells drilled, and violations issued for unconventional oil and gas wells in Pennsylvania from January 2005 through May 2013.

There are numerous ways to interpret the raw data, to the point where it is easy to get bogged down in the specifics. Still, a certain amount of discussion is merited to understand that answers to questions like, “How many unconventional oil and gas violations are there in Pennsylvania?” are fundamentally interpretive in nature, based on the available data. For example, there are often multiple actions for a single well API number that appear in the permits report, and likewise multiple actions for a single violation ID number that has been issued. In this analysis, we have counted only the first action for each of these.

Here are some more summary details about the data:

This table shows a summary of unconventional oil and gas data in PA by month.

This table shows a summary of unconventional oil and gas data in PA by month.

The top section shows summaries of monthly counts of permits, drilled wells, and violations, while the second section shows the frequency of the monthly totals reaching specified targets, and the third section shows the total numbers that were used for the analysis.  For example, we can see in the top section that the maximum number of violations issued in a month is 160, so there are zero instances where the monthly total of violations reached the target of being greater than 200.  And while there have been four months since January 2005 where there have been no unconventional permits issued in the state (the most recent being in September 2005, incidentally), this has happened 21 times on the violations report.


Pennsylvania Shale Viewer on FracMapper. Please click the “Fullscreen” icon to learn more about the map, and access additional tools.