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An Open Letter to FracFocus

FracFocus.org is the preferred chemical disclosure registry for the oil and gas (O&G) industry, and use of your website by the industry is mandated by some states and regulatory agencies. As such, we hope you’ll be responsive to this call by FracTracker, other organizations, and concerned citizens across the country to live up to the standards of accessibility and transparency required by similar data registries.

A Focus on Data Transparency

Recent technological advances in high volume hydraulic fracturing operations have changed the landscape of O&G drilling in the United States.  As residents adjust to the presence of large-scale industrial sites appearing in their communities, the public’s thirst for knowledge about what is going on is both understandable and reasonable. The creation of FracFocus was a critical first step down the pathway to government and industry transparency, allowing for some residents to learn about the chemicals being used in their immediate vicinities.  The journey, however, is not yet complete.

Design Limitations on FracFocus

Query by Date

Even with the recently added search features there is no way to query reports by date. Currently a visitor would be unable to search by the date hydraulic fracturing / stimulation was performed, or when the report itself was submitted. Reports can only be viewed one PDF at a time, which would take someone quite a while to view all 68,000+ well sites in your system.

Aggregate Data Downloads

In October 2013, you informed us that “each registered state regulatory agency has access to the xml files for their state but they are not distributable from FracFocus to the public.” We must ask the reasonable question of “why not?” We understand that setting up a downloadable data system is a time-intensive process, as we manage one ourselves, but the benefits of providing such a service more than compensate for the effort expended. It is no longer possible to aggregate data, either automatically or manually, because of bandwidth limitations that keep users from downloading more than an arbitrarily limited number of reports in a single session. Considering public concern over the composition of frac fluid, as well as the volume and geographic extent of complaints of drinking water complaints to be related to O&G extraction, prudence would suggest making the data as accessible as possible. For example, making the aggregated data available to the public as a machine-readable download would greatly reduce the load on your servers, because users would no longer be forced to download the individual PDF reports. Changes in the way the reports are curated would also improve efficiency and reduce your server load; we would be more than happy to discuss these changes with you.

An Issue of Money?

The basic infrastructure to provide this service via FracFocus.org is already in place. An organization like the Groundwater Protection Council with a website serving some of the world’s wealthiest corporations loses credibility when making claims that “we have no way to meet your needs for the data.”  Withholding data from the public only serves to compound the distrust that many people have with regards to the oil and gas extraction industry.  Additionally, agencies that use FracFocus as a means of satisfying open government requirements are currently being short changed by the lack of access to your aggregated datasets; restricting access to data that is in the public interest is fundamentally at odds with data transparency initiatives, including the President’s 2013 Executive Order on Open Data.

One Small Step for a Company…

Within this discussion is a simple realization:  The Ground Water Protection Council, Interstate Oil and Gas Compact Commission, participating companies and states, and the federal government should recognize that data transparency is not merely a lofty ideal, but an actual obligation to our open society.  Once that realization has been made, the path of least resistance becomes clear:  you, FracFocus, should make all of your aggregate data available to the public, beginning with the easiest step: the statewide datasets that are already being provided to government agencies.

FracTracker operates in the public interest. We – and the thousands of individuals and organizations who use our services and yours – request no less from you. Thank you for addressing these critical matters.

Sincerely,
-The FracTracker Alliance-

FF Word Cloud

NM Shale Map Shows Contamination Events

Recently, the FracTracker Alliance has gotten several requests from residents of New Mexico for maps showing the large scale drilling operations in that state.  As we began to look around for data sources, we encountered an interesting document from 2008:

This 2008 document from the New Mexico Oil Conservation Division shows instances of ground water contamination by oil and gas pits in the state.

This 2008 document from the New Mexico Oil Conservation Division shows instances of ground water contamination by oil and gas pits in the state.

There isn’t much description on the document or the New Mexcio Oil Conservation Division (NMOCD) page that links to it, however, the subject matter is straightforward enough.  Altogether, there are 369 instances of ground water contamination documented by a New Mexico governmental agency from dozens of drilling operators throughout the Land of Enchantment.

Ground Water Contamination Controversy

Since the title of document indicates that the agents causing contamination are “pit substances”, this does not technically indicate that hydraulic fracturing is to blame.  This is largely a matter of definition, but it is an important one to understand, because the word “fracking” means something different to industry insiders than it does to the general public, and the issue of ground water contamination is a point of considerable debate.

Technically speaking,  hydraulic fracturing only refers to one stage of the well completion process, in which water, sand, and chemicals are injected into the oil or gas well, and pressurized to break up the carbon-rich rock formation to allow the desired product to flow better.Most people (and many media outlets) consider “fracking” to be the entire production process for wells that require such treatment, from the development of the several acre well pad, through the drilling, the completion, flaring, waste disposal, and integration of the product to pipelines.  (It is due to these competing definitions that the FracTracker Alliance goes out of our way to avoid the term “fracking”.)

All of this has lead to some carefully worded statements that seem to exhonerate hydraulic fracturing, despite suspected contamination events reported in Pennsylvania, Wyoming, and elsewhere.  Of course, from the perspective of residents relying on a contaminated aquifer, it hardly matters whether the water was contaminated by hydraulic fracturing, leeching from the associated pits, problems with well casing or cement, or re-pressurized abandoned wells.  A fouled aquifer is a fouled aquifer.

This document does not specify what was contained in the pits, only that they are contamination events.  Therefore, we do not know what stage of the process the contaminant came from, only that it was believed by the state of New Mexico to have originated from a pit, and not the well bore itself.

Notes About Location Information

It is important to note that the location information is not exact, but are generally within 0.72 miles of the specified location.  The reason for this is that the location information was provided using the Public Land Survey System (PLSS).  The brainchild of Thomas Jefferson, the PLSS was the method used to grid out the western frontier, and it is still used as a legal land description in many western states.  Essentially, the land was divided into townships that were six miles by six miles, which was then broken into 36 sections, each of which is one square mile.  FracTracker has calculated the centroid of each section, which could be up to 0.71 miles from the corner of the same section if the shape is perfectly square.

The PLSS system was used to grid out most of New Mexico, but some portions of the state had already been well defined by Spanish and Mexcian land grants.  Aside from being a fascinating historical anecdote, it does have an effect on the mapping of these pits.  In the image of the table above, note that the “Florance Z 40” well does not have any values in the location column.  As a result, we were not able to map this pit.  Altogether, 11 of the 369 pits identified as causing groundwater contamination could not be mapped.


New Mexico Shale Viewer. You can zoom and click on map icons in this window for more information. For full access to map controls, including layer descriptions, please click the expanding arrows icon in the top right portion of the map.

SkyTruth Aggregates FracFocus Data

Among the many provisions under Act 13, Pennsylvania oil and gas operators now must join several other states by disclosing some generalized information about chemical additives to wells that undergo hydraulic fracturing to a national registry called FracFocus.org. On their main page, FracFocus describes their role in the following manner:

In a single year, FracFocus has made a national impact from the Beltway to the Bakken. During this time, more than 200 energy-producing companies have registered over 15,000 well sites through FracFocus.

This success is the result of nationally recognized organizations working with the oil and natural gas industry to provide public transparency. Learn more and see highlights from the first year of FracFocus.

However, there are strong differences of opinion on what transparency really means.  Does it entail specific data about a well, general information about all the wells, or both?  The chemical registry is focused on specifics about individual wells, and although the data is easily accessible for them, they don’t offer data downloads for users interested in a wider scope.  Whether this amounts to data transparency has everything to do with the lens that one looks through.

Let’s say, for example, that you already know a bit about a given well.  As a random example, let’s use API# 37-131-20104, a well operated by Chesapeake in Wyoming County, PA.  When we conduct a search, we are given the opportunity to download a PDF where we can learn a great deal about the well that is not available from the Pennsylvania Department of Environmental Protection (PADEP) data download section. We learn, for example, that the well was fractured on May 8, 2012 using over 1.3 million gallons of water, as well as the maximum amounts used of chemical additives the hydraulic fracturing fluid, and why they were added to the mix.

Objectively, that is a large step forward in transparency, as this information was not available before.   But what if your questions about the industry are broader?  You may want to know, for example, if some operators are putting diesel fuel into the hydraulic fracturing fluid, or whether some anti-bacterial agents are more prominent in certain geographies than others.  You might want to do a comparison on which companies claim data to be proprietary, relative to the industry as a whole, or whether there is any correlation between particularly noxious chemical additives and well production.  To answer questions like these, you just need a summary of the data that FracFocus already offers.  But unfortunately, FracFocus will not provide this aggregated data.

To help address questions such as these, SkyTruth.org has extracted the data from the PDF documents using a combination of automated and manual techniques, and have made the results available to FracTracker and the general public.  The result is a major step forward in data transparency; even before the chemical data have been picked through and combed over, there are still several new types of data that the general public didn’t have access to before.

FracFocus Data Available for Mapping
SkyTruth’s efforts have allowed us to map FracFocus data. Click on the map above to explore.

The data include over 26,000 records from FracFocus since January 1, 2011 from twenty different states around the country. Now it is possible for people other than industry insiders to learn about variables not provided by the various states, including depth of target formation, fracturing dates, amounts of water used. There is also a separate dataset including all listed chemicals at each well, which comes in at well over 800,000 records for the 21 months of the report.

Of course, users must remain mindful that this is not, in fact, a completely comprehensive dataset.  While several states have recently required disclosure of the chemical additives, in remains a voluntary disclosure in other locations.  Some of the chemicals are listed in the abstract, but marked as proprietary, which naturally limits our understanding of what was put into the well.  And as with other large datasets of this sort, it is likely that there are a significant number of omissions and errors.

At FracTracker, we’d like to extend our gratitude to both FracFocus for collecting the data and making it public, and to SkyTruth, for aggregating it and making it more usable.  In our view, both of these steps are critical for true data transparency.  This transparency, in turn, is indispensable for making an enhanced understanding of the oil and gas industry possible.