In August 2016, Shell announced plans for the “Falcon Ethane Pipeline System,” a 97-mile pipeline network intended to feed Shell’s ethane cracker facility in Beaver County, Pennsylvania. In response to available data, FracTracker launched the Falcon Public EIA Project in January of 2018 to unearth the environmental and public health impacts of the proposed pipeline. As part of that project, today we explore Shell’s Chapter 105 application and the deficiencies the Pennsylvania Department of Environmental Protection (DEP) cited after reviewing Shell’s application.
Just a heads up… there are a lot.
Shell originally submitted a Chapter 105 application to the DEP to receive a permit for water obstruction and encroachment. The DEP began reviewing the application in January of 2018. On June 1st, they sent Shell technical deficiency letters listing several issues with the application. Shell responded to these deficiencies on August 1st.
Now, it’s up to the DEP to decide if Shell’s response is adequate, and if the department should go ahead and approve the application or require more work from Shell. Explore the technical deficiencies below for more information.
Below is a map that highlights several of the deficiencies the DEP found with Shell’s application and a brief explanation of each one. Expand the map full-screen to explore more layers – Some layers only become visible when you zoom in due to the level of detail they display.
Next, we’ll walk you through the technical deficiencies, which we have broken down into the following categories:
- Wetlands, rivers, streams
- Stormwater control
- Public health and safety (drinking water & trails)
- Conservation areas
- Alternative routes
- Geological concerns (including mining issues)
- Documentation issues
1. Wetlands, Rivers, & Streams
Water withdrawal from rivers and discharge
- B2 A2 W2 The project will discharge waste water from an industrial activity to a dry swale, surface water, ground water, or an existing sanitary sewer system or separate storm water system. The DEP requested that Shell identify and describe this discharge, as the DEP’s Clean Water Program must authorize discharges. Shell stated that water will be discharged from hydrostatic testing, (which ensures a pipeline can withstand high pressure by pumping water through it to test for leaks), and a PAG-10 permit (needed for hydrostatic test water discharge) was submitted to the DEP July 27, 2018 with the locations of discharge. Drawings of the discharges are in Attachment O. (The locations of the discharges were not included in Shell’s public response to this deficiency.)
- B33 A31 W31 Shell will be withdrawing water for hydrostatic testing. The DEP asked Shell to explain the intake and discharge methods so the DEP can decide if these should be included as impacts. The DEP also asked Shell to provide the location of intake and discharge. The DEP’s Clean Water Program must authorize discharges. In response, Shell stated that water will be withdrawn from Raccoon Creek and the Ohio River in West Virginia. The specific locations are listed in the PAG-10 permit, submitted to the DEP in July. Drawings of the discharges are included in Attachment O.
Wetlands and Streams
- B5 A3 W4 The DEP asked Shell to identify the presence of wetlands within the project area that are identified by the US Fish & Wildlife Service’s National Wetlands Inventory (NWI) data system, and provide data on how they may be impacted by the proposed pipeline. Shell identified one NWI wetland in Beaver County, but did not delineate or provide information on it, due to safety concerns (it’s on a steep cliff). This wetland will be crossed via HDD (horizontal directional drill). In Allegheny County, there is an NWI wetland that Shell also did not provide data on. This wetland was not initially evident, and when staff returned to survey it, the property owner did not let them access the site because they did not want a pipeline on their property. According to Shell, this NWI wetland is not within the “Project’s Limit of Disturbance.” In Washington County, Shell stated that “all of the NWI-mapped wetlands that were determined not to be wetlands have been accounted for in Washington County. These NWI wetlands were all located in an area that had been previously strip-mined and due to mining activities, those wetlands are no longer there. Data were taken for these areas and included… separately as Attachment D.” Also in Washington County is an NWI wetland located above the Panhandle Trail, which Shell determined to be outside of the study area and therefore did not collect data on it. This wetland is not on the map, but Shell did provide this image of it.
- B6 A4 W5 The DEP requested that Shell match off-line wetland data with sampling point locations from study area maps. In response, Shell placed offline data sheets in the order that they are in Table 3 in the Wetlands Delineation Report and in Table 4 in the Watercourse Delineation Report.
- B7 A5 W6 Shell needed to discuss the types and conditions of riverine resources that the project impacts. Specifically, how the conditions of these resources relate to their hydrological functions, biogeochemical functions, and habitat attributes. These are discussed under question 7 for Beaver County, question 5 for Allegheny County, and question 6 for Washington County.
- B8 A6 W7 Shell needed to discuss the types and conditions of wetlands that the project impacts. Specifically, how the conditions of these wetlands contribute to their hydrological functions, biogeochemical functions, and habitat attributes. Shell also needed to discuss impacts to wetlands that will be temporarily impacted, as it previously only discussed wetlands facing permanent impacts. These are discussed under question 8 for Beaver County, question 6 for Allegheny County, and question 7 for Washington County.
- B9 A7 W8 The DEP asked Shell to evaluate the impact of open cut installation on wetlands with perched water tables and/or confining layers. Perched water tables have an impermeable confining layer (such as clay) between them and the main water table below. If open cut methods are used, the confining layer is destroyed and this water table will be lost. In Beaver County, Shell identified one wetland (W-PA-170222-MRK-002) will be open cut. If it is perched, Shell states it will replace the confining layer “along the same horizon during pipeline backfilling, and then [compact the layer] so that hydrology may be maintained.” Shell will also put trench plugs “on either side of the wetland on the ROW to prevent water from migrating out on the sides.” In Allegheny County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160401-MRK-006, W-PA-161220-MRK-001, and W-PA-161220-MRK-002.In Washington County, there are three wetlands potentially on perched water tables that will be open cut: W-PA-160407-JLK-002, W-PA-151203-MRK-005, and W-PA-151203-MRK-006.
- A11 The DEP asked Shell to evaluate if any wetlands can be classified as “exceptional value” due to their proximity to nesting areas of the northern harrier (a threatened species in Pennsylvania). Wetlands are exceptional value if they serve as habitat for threatened or endangered species, or if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain habitat for the species in the wetland. Shell determined that there are six wetlands that could be nesting areas for northern harriers, and therefore are exceptional value (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003, W-PA-170207-MRK-001, W-PA-170113-MRK-008, W-PA-170113-MRK-001). Three of these wetlands are within the project’s LOD (W-PA-170207-MRK-002, W-PA-161205-WRA-001, W-PA-170207-MRK-003).
- B13 A10 W11 The DEP asked Shell to evaluate whether the proposed Falcon Pipeline will impact wetlands that are of “exceptional value” based on their proximity to public water systems. Wetlands can be considered “exceptional value” if they are located along public or private drinking water supplies (surface or ground water), and help maintain the quality or quantity of the supply. Shell stated that the (potentially man made) ponds near public water supply A could be considered exceptional value, however, they are located outside of the project’s study area and were not delineated, therefore Shell does not have information on them or their impact to this well. There were no other wetlands Shell considered to be exceptional value based on their proximity to public water systems.
- B21 There were two protected plant species- harbinger of spring (PA threatened) and purple rocket (PA endangered)- located within the Raccoon Creek floodplain. The DEP asked Shell to evaluate whether there are wetlands in the project area that should be considered “exceptional value” due to their proximity to these species. Wetlands are considered “exceptional value” if they serve as habitat for a threatened or endangered plant or animal species. They are also exceptional value if they are hydrologically connected to or located within 0.5 miles of wetlands that maintain the habitat of the species. There are six wetlands near populations of these plant populations: W-PA-151014-MRK-001, W-PA-151013-MRK-002, -003, and -004, W-PA-170407-JLK-001, W-PA151013-MRK-001. However, Shell stated that the harbinger of spring is not dependent on wetland habitat for survival and the species is considered an upland plant species (because it is not listed on Eastern Mountains and Piedmont List or on the National Wetland Plant List). Purple rocket is listed as a “Facultative Wetland Plant” (FACW) on both lists. However, Shell stated that, “although it is a FACW, this plant is not one that occurs in wetlands,” and the population of purple rocket was found in an upland, disturbed area. Therefore, Shell determined that none of these wetlands are considered exceptional value.
- B23 A21 W21 Shell needs to assess cumulative impacts to wetlands from the proposed pipeline and other existing projects and potential future projects. These are discussed in the Cumulative Impact Assessment document, Sections 4.1 and 4.2, and Tables B1 and B2.
- B24 A22 W22 Shell needed to provide an explanation of how it will restore wetlands and streams disturbed during construction. The explanation needed to include information on seed mixes, shrubs, and trees that will restore stream banks and riparian areas.
- B26 A24 W24 Shell needed to provide a table that lists, describes, and quantifies permanent impacts to wetlands and watercourses. Shell stated that there are no permanent fills associated with the project, but there will be permanent conversion impacts to the following wetlands. They total 10,862 ft2 or 0.25 acres in Beaver County, 5,166 ft2 (0.12 acres) in Allegheny County, and 4971 ft2 (0.11 acres) in Washington County. (W-PA-151013-JLK-005, W-PA-161202-MRK-001, W-PA-160404-MRK-001, W-PA-160412-CBA-004, W-PA-160412-CBA-001, W-PA-161205-WRA-003, W-PA-160401-MRK-005, W-PA-170213-JLK-003, W-PA-160406-MRK-001, W-PA-170413-RCL-005, W-PA-170214-CBA-005.)
- B27 A25 W25 Shell needed to provide more information on the Neshannock Creek Restoration site, including a master restoration plan for the entire site. This mitigation is required to offset conversion impacts to wetlands along the pipeline route. The plan for the site is documented here.
- B28 A26 W26 Shell needed to provide the location and resource crossing number for the HDDs in PA. They are listed in these tables:
2. Stormwater control
- B3 A1 W1 Shell indicated that the project was in a floodplain project by the Commonwealth, a political subdivision of the commonwealth or a public utility. The DEP asked for an identification of this floodplain project, to which Shell responded that it misunderstood the question and the pipeline will not go through a floodplain project by one of these entities, but rather a floodway. The pipeline will pass many floodways, which are listed in Table 1 in separate documents for Beaver County, Allegheny County, and Washington County.
- W3 The DEP requested that Shell provide an analysis of impact to Act 167 plans. Act 167 requires counties to create stormwater management plans and municipalities to adopt ordinances to regulate development in accordance with these plans. The pipeline route occurs in areas with Act 167 plans in Chartiers Township, Mount Pleasant Township, and Robinson Township.
3. Public health and safety
- B1 The proposed pipeline does not meet the provisions of a zoning ordinance or have zoning approval in a particular area. Specifically, in Independence Township, the pipeline is within setback distances of places of congregation and/or of residences. One example is the Beaver County Conservation District, considered a place of congregation. Shell responded to this deficiency, saying it is working with Independence Township to obtain necessary approvals, and the township will “officially remove the pipeline ordinance from their records and no variances or permits will be required.”
- B10 A8 W9 The DEP requested that Shell evaluate and discuss how the pipeline may impact public water systems that are within 1 mile of the pipeline route. Shell located 12 sites within a mile, most of which are ground water wells. One site is the Ambridge Water Authority, which provides drinking water for an estimated 30,000 people. Shell stated that impacts “might include an Inadvertent Return (IR) causing a bentonite slurry mix to enter the supply, which might contaminate the supply for any wells that are located near an HDD site or construction equipment.” Shell stated that all wells are a minimum of 1000 feet outside construction zones and built in thick bedrock which will minimize threat on contamination. The sites within 1 mile include:
- Youthtowne Barn
- Beaver County Conservation District
- Independence Elementary School
- Independence Volunteer Fire Department
- McConnell’s Farm and Market, Inc
- Ambridge Water Authority- Independence Township
- Ambridge Water Authority- Raccoon Township
- Hookstown Free Methodist Church
- Hookstown Fair
- Hookstown Grange
- South Side Memorial Post 952
- Jack’s Diner
- NOVA Chemical, Inc
- B11 A9 W10 The DEP asked Shell to discuss efforts to avoid/minimize impacts to the above public water systems, and suggested that efforts “might include, but are not limited to, considering alternative locations, routings or design for the proposed pipeline; providing provisions for shut-off in the event of break or rupture; etc.” Shell stated that the route avoids direct impacts to groundwater wells and surface water intake. Shell will provide water buffalos if wells are contaminated, and drill new wells if necessary. There are mainline valves approximately 7 to 7.5 miles apart that can automatically shut off the flow of ethane. There will also be staff living within the project area that can quickly respond to issues.
- B12 The pipeline crosses headwaters of the Ambridge Reservoir and the Reservoir’s raw water service pipeline, which supplies water to 30,000 residents. The DEP noted significant public concern regarding this crossing, and asked Shell to evaluate and discuss the pipeline’s potential to affect the Reservoir and public water supply service. The DEP also asked Shell to elaborate on efforts to avoid/minimize impacts, and what measures will be implemented to mitigate any unavoidable impacts. In response, Shell stated the pipeline will cross the raw water line via an HDD 31 feet below the line. Shell explained that the water service line is made of pre-stressed concrete, which cannot be retrofitted in the field if a break occurs. It can take six weeks for pipe joints to be made and delivered from Ohio if there is a rupture. Shell stated it will supply extra pipe joints so the Ambridge Water Authority can have pieces on deck in case of a break. Shell also outlined the protective coatings and design of the HDD portion of the pipeline that will cross the water line, and said valves that can shut off the pipeline are located 2.4 miles from one side of the water line and 3.5 on the other.
- A17 W17 The DEP asked Shell to consider the proposed pipeline’s effect on the Montour Trail, a multi-use, recreational trail, and to consider re-routes that would avoid impacts to the Trail. Shell determined that routing around the trail is not feasible. Shell will use conventional bore or HDD methods. If the trail needs to be temporarily closed during construction, operation, or maintenance, Shell will notify the trail owner and provide alternate temporary access for trail users. Shell will also cross the Panhandle Trail by HDD. The entrance and exit sights of the bore will not be on the trail’s property. Shell has “unlimited ingress and egress over Owners property” for inspections, repair and maintenance of the pipeline, and in case of emergency situations.
- B29 A27 W27 Shell needed to revise the “Shell Pipeline HDD Procedure” to include HDD site feasibility analysis, inadvertent return risk assessment, water supply protection, agency contact information, etc. Shell’s response is included in the document, Inadvertent Returns from HDD: Assessment, Preparedness, Prevention and Response Plan.
- B30 A28 W28 Shell needed to include a preboring geologic evaluation to determine if drinking water supplies will be impacted around boring locations. Shell also needed to discuss how it will verify that drinking water sources and aquifers are protected and what measures will be taken in the event that they are impacted. Shell’s response is included as Appendix C to this document.
- B19 A18 W18 19A 19W – There are many areas important for the region’s biodiversity and natural heritage that the proposed pipeline passes near or through. The DEP asked Shell to evaluate impacts to these areas. Information on them is available from the Pennsylvania Natural Heritage Program. They include:
- Ambridge Reservoir Valleys Natural Heritage Area
- Lower Raccoon Creek Natural Heritage Area
- Raccoon Creek Valley and Wildflower Reserve Natural Heritage Area
- Raccoon Creek Floodplain Biologically Diverse Area
- Raccoon Creek Landscape Conservation Area
- Clinton Wetlands Biologically Diverse Area
- Raccoon Creek Landscape Conservation Area
- Raccoon Creek Valley & State Park Important Bird Area – Regarding the Important Bird Area, Shell stated that 23 miles of the pipeline is located within this area. Shell has not been able to get in contact with the National Audobon SW PA office. Shell added that the only waterbody large enough in the project area to support the documented waterfowl is the open water at Beaver County Conservation District. Shell stated that “an outlet has been installed at the far end of the lake to restore it to more of a wetland and less of a lake, as it was originally designed.” Raccoon Creek Valley is also a passageway for migratory birds, which are protected under the Migratory Bird Treaty Act. Shell stated that less than 2% of this Important Bird Area will be permanently impacted by pipeline construction and installation.
5. Alternative locations
- B17 A15 W15 The DEP asked Shell to revise its current alternatives and provide a more detailed “analysis of the alternative locations and routes that were considered to avoid or minimize adverse environmental impacts.” The alternatives are discussed in Section 9 of Shell’s Comprehensive Environmental Assessment.
- B18 16A 16W According to the DEP, “18.5 of the 45 miles (41%) of the proposed pipeline are parallel to or adjacent to existing right-of-ways (ROWs).” The DEP asked Shell to see if there are additional opportunities to build the pipeline within existing ROWs, with the hope of reducing environmental impacts. In response, Shell discussed the additional ROWs that were considered (along Mariner West) but ultimately rejected. Shell discusses these routes more in Section 9.1 of the Comprehensive Environmental Assessment.
- B32 A30 W30 The DEP asked Shell to discuss the feasibility of several changes to the proposed pipeline’s route, including avoiding impacts to wetlands, relocating resource crossings, moving valve sites outside of wetlands, moving HDD locations, and evaluating the impact to a coal refuse pile (the pipeline crosses underneath at least one pile via HDD). These reroutes are discussed under question 32 for Beaver County, question 30 for Allegheny County, and question 30 for Washington County.
6. Geological concerns
- B14 12A 12W The pipeline is located in previously coal mined areas. The DEP asked Shell to provide a map of the pipeline that showed these mining areas, and GIS shape files with this information. Shell’s response is included in the HDD Subsurface Investigation Reports, which includes the following table of the extent of mined areas along the pipeline route:
- B15 A13 W13 The pipeline is located in coal mined areas, which could be susceptible to subsidence and/or mine water discharge. The DEP requested that Shell revise drawings to show the limits of previously mined areas, depth of cover over the mine workings in areas the proposed pipeline crosses through, and the distance between mine workings and the proposed pipeline. Furthermore, the DEP asked Shell to “evaluate and discuss the potential for a subsidence event compromising the utility line, and the potential to create a mine water discharge.” Shell discusses this in Appendix B of this this document and in the Mining Summary Report. Shell also identifies the following areas as being at risk for coal mine discharge: HOU MM 1.2, HOU MM 8.9 (proposed HDD), HOU MM 12.1, HOU MM 12.95, HOU MM 13.1, HOU MM 13.6, HOU MM 17.4, and HOU MM 17.65 (proposed HDD).
- B16 A14 14W The DEP requested that Shell include areas where the pipeline will cross active mining permit boundaries. There is one active mining permit boundary that intersects the proposed pipeline, the Rosebud Mine in Beaver County.
- B31 A29 W29 Shell needed to evaluate the potential for the project to encounter areas underlain by carbonate bedrock and landslide prone areas. Carbonate bedrock is indicative of a karst landscape, meaning an area likely to have underground sinkholes and caves. The DEP also asked Shell to discuss precautionary methods taken during construction in these areas. Shell’s response is included in the Carbonate Rock Analysis and Slope Stability and Investigation Report. The Carbonate Rock Analysis report shows that carbonate bedrock was encountered in 20 out of 40 of the borings taken during the analysis.
- B4 The PA DEP asked Shell to describe the structures and activities that occur within junction sites. Shell responded that there will be a Junction Custody Transfer Meter Station at the site, and provided maps of the site.
- B22 20A 20w The DEP requested that Shell revise their Comprehensive Environmental Assessment to include alternatives, impacts, and mitigation items that were previously included in other sections of their environmental assessment.
- B25 A23 W23 The DEP asked Shell to provide a copy of the Mitigation Bank Credit Availability Letter from First Pennsylvania Resource, LLC. In response, Shell stated the Letter is no longer needed because “the permanent stream and wetland fills have been removed from this project.”
- B34 A32 W32 The DEP asked Shell to include a copy of the Preparedness, Prevention, and Contingency Plan.
- B35 A33 W33 Shell needs to include all of the above modifications to the application in the Chapter 103 permit application.
As evidenced by the list above, the proposed Falcon Pipeline poses a variety of threats to Pennsylvania’s natural resources, wildlife, and public health – but this deficiencies list is likely not complete. The pipeline also passes through West Virginia and Ohio, and if completed, will likely attract more pipelines to the area. As it feeds Shell’s ethane cracker plant in Beaver County, it is a major step towards the region becoming a hub for plastic manufacturing. Therefore, the public response to the above deficiencies and the decision the DEP makes regarding them will have major implications for the Ohio River Valley’s future.
By Erica Jackson, Community Outreach and Communications Specialist
With tens of thousands of wells scattered across the countryside, Southwestern Pennsylvania is no stranger to oil and gas development. New, industrial scale extraction methods are already well entrenched, with over 3,600 of these unconventional wells drilled so far in that part of the state, mostly from the well known Marcellus Shale formation.
Southwestern Pennsylvania is also home to the Pittsburgh Metropolitan Area, a seven county region with over 2.3 million people. Just over half of this population is in Allegheny County, where unconventional drilling has become more common in recent years, along with all of its associated impacts. In the following interactive story map, the FracTracker Alliance takes a look at current impacts in more urban and suburban environments, plus projects what future impacts could look like, based on leasing activity.
By Matt Kelso, Manager of Data & Technology
By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance
In an apparent move to step around compliance with comprehensive regulations outlined in the Endangered Species Act (ESA), a coalition of nine oil and gas corporations has filed a draft plan entitled the Oil & Gas Coalition Multi-State Habitat Conservation Plan (O&G HCP). The proposed plan, which would relax regulations on five species of bats, is unprecedented in scope in the eastern United States, both temporally and spatially. If approved, it would be in effect for 50 years, and cover oil and gas operations throughout the states of Ohio, Pennsylvania, and West Virginia—covering over 110,000 square miles. The oil and gas companies see the plan as a means of “streamlining” the permit processes associated with oil and gas exploration, production, and maintenance activities. Others outside of industry may wonder whether the requested permit is a broad over-reach of an existing loophole in the ESA.
Habitat fragmentation, air, and noise pollution that comes with oil and gas extraction and fossil fuel delivery activities have the potential to incidentally injure or kill bat species in the three-State plan area that are currently protected by the Endangered Species Act (ESA) of 1973. In essence, the requested “incidental take permit”, or ITP, would acknowledge that these companies would not be held to the same comprehensive regulations that are designed to safeguard the environment, particularly the flora and fauna at most risk to extirpation. Rather, they would simply be asked to insure that their impacts are “minimized and mitigated to the maximum extent practicable.”
Section 10(a)(2)(B) of the ESA contains provisions for issuing an ITP to a non-Federal entity for the take of endangered and threatened species, provided the following criteria are met:
- The taking will be incidental
- The applicant will, to the maximum extent practicable, minimize and mitigate the impact of such taking
- The applicant will develop an HCP and ensure that adequate funding for the plan will be provided
- The taking will not appreciably reduce the likelihood of survival and recovery of the species in the wild
- The applicant will carry out any other measures that the Secretary may require as being necessary or appropriate for the purposes of the HCP
What activities would be involved?
The proposed plan, which would seek to exempt both upstream development activities (oil & gas wells) and midstream development activities (pipelines). Upstream activities include the creation of access roads, staging areas, seismic operations, land clearing, explosives; the development and construction of well fields, including drilling, well pad construction, disposal wells, water impoundments, communication towers; and other operations, including gas flaring and soil disturbance; and decommissioning and reclamation activities, including more land moving and excavation.
Midstream activities include the construction of gathering, transmission, and distribution pipeline, including land grading and stream construction, construction of compressor stations, meter stations, electric substations, storage facilities, and processing plants, and installation of roads, culverts, and ditches, to name just a few.
Companies involved in the proposed “Conservation Plan” represent the major players in fossil fuel extraction, refinement, and delivery in the region, and include:
- Antero Resources Corporation
- Ascent Resources, LLC
- Chesapeake Energy Corporation
- EnLink Midstream L.P.
- EQT Corporation
- MarkWest Energy Partners, L.P., MPLX L.P., and Marathon Petroleum Corporation (all part of same corporate enterprise)
- Rice Energy, Inc.
- Southwestern Energy Company
- The Williams Companies, Inc.
Focal species of the request
The five species listed in the ITP include the Indiana Bat (a federally-listed endangered species) and Northern Long-eared Bat (a federally-listed threatened species), the Eastern Small-footed Bat (a threatened species protected under Pennsylvania’s Game and Wildlife Code), as well as the Little Brown Bat and Tri-colored Bat. Populations of all five species are already under dire threats due to white-nose syndrome, a devastating disease that, since 2008, has killed an estimated 5.7 million bats in North America. In some cases, entire local populations have succumbed to this deadly disease. Because bats already have a naturally low birthrate, bat populations that do survive this epidemic will be slow to rebound. Only recently, wildlife biologists have begun to see hope for a treatment in a beneficial bacterium that may save affected bats. However, production and deployment details of this treatment are still under development. Best summarized in a recent article in the Pittsburgh Post-Gazette:
This [ITP] would be a huge deal because we are dealing with species in a precipitous decline,” said Jared Margolis, an attorney with the Center for Biological Diversity, a national nonprofit conservation organization headquartered in Tucson, Ariz. “I don’t see how it could be biologically defensible. Even without the drilling and energy development we don’t know if these species will survive.
In 2012, Bat Conservation International produced a report for Delaware Riverkeeper, entitled Impacts of Shale Gas Development on Bat Populations in the Northeastern United States. The report focuses on landscape scale impacts that range from water quality threats, to disruption of winter hibernacula, the locations where bats hibernate during the winter, en masse. In addition, because bats have strong site fidelity to roosting trees or groups of trees, forest clearing for pipelines, well pads or other facilities may disproportionately impact local populations.
The below map, developed by FracTracker Alliance, shows the population ranges of all five bat species, as well as the current areas impacted by existing development by the oil and gas industry through well sites, pipelines, and other facilities.
View map fullscreen | How FracTracker maps work
To learn more details about the extensive oil and gas development in each of the impacted states, follow these links:
- Oil and gas threat map for Pennsylvania. Currently, there are ~104,000 oil and gas wells, compressors, and other related facilities here.
- Oil and gas threat map for Ohio. Currently, there are ~90,000 oil and gas wells, compressors, and other related facilities here.
- Oil and gas threat map for West Virginia. Currently, there are ~16,000 oil and gas wells, compressors, and other related facilities here.
Public input options
The U.S. Fish and Wildlife Service (USFWS) announced in the Federal Register in late November 2016 its intent to prepare an environmental impact statement (EIS) and hold five public scoping sessions about the permit, as well as an informational webinar. In keeping with the parameters of an environmental impact statement, USFWS is particularly interested in input and information about:
- Aspects of the human environment that warrant examination such as baseline information that could inform the analyses.
- Information concerning the range, distribution, population size, and population trends concerning the covered species in the plan area.
- Additional biological information concerning the covered species or other federally listed species that occur in the plan area.
- Direct, indirect, and/or cumulative impacts that implementation of the proposed action (i.e., covered activities) will have on the covered species or other federally listed species.
- Information about measures that can be implemented to avoid, minimize, and mitigate impacts to the covered species.
- Other possible alternatives to the proposed action that the Service should consider.
- Whether there are connected, similar, or reasonably foreseeable cumulative actions (i.e., current or planned activities) and their potential impacts on covered species or other federally listed species in the plan area.
- The presence of archaeological sites, buildings and structures, historic events, sacred and traditional areas, and other historic preservation concerns within the plan area that are required to be considered in project planning by the National Historic Preservation Act.
- Any other environmental issues that should be considered with regard to the proposed HCP and potential permit issuance.
The public comment period ends on December 27, 2016. Links to more information about locations of the public hearings, as well as instructions about how to sign up for the December 20, 2016 informational webinar can be found at this website. In addition, you can electronically submit comments about the “conservation plan” by following this link.
By Kyle Ferrar, Western Program Coordinator
Over 38,000 oil and gas wells have likely been hydraulically fractured in California. The last permitted hydraulic fracturing operation in CA was approved in June 2015. Additionally, new aquifer exemption proposals will make it easier for operators to obtain hydraulic fracturing permits. One of the most interesting and troubling issues we found when analyzing the data on violations is that operators with the highest number of new well permits are also responsible for the majority of violations. In this article, we provide a look at these and other the trends of unconventional drilling in CA.
Updated CA Shale Viewer
First of all, the CA Shale Viewer has been updated! New data has been uploaded into the map about unconventional drilling in California, and new data resources have been used to identify shale gas activity (Fig. 1). Recent reports in CA have exposed what many researchers expected – hydraulic fracturing has been occurring in the state without any oversight or documentation for a long time.
In this presentation of the Updated CA Shale Viewer we showcase an analysis of these new data sources that better describe unconventional drilling in CA. We then look to new well permitting data to see what current spatial trends may mean for future oil and gas development. We also look at a sample of operator violations issued by the state regulatory agency to tell us a bit about who the bad actors may be.
Figure 1. CA Shale Viewer – Location of well stimulation & other unconventional oil & gas activity
Current Fracking Activity
Fracking in California has been put on hold at the moment as a result of low oil prices combined with the new permitting requirements for groundwater monitoring. In 2015, the CA Council on Science and Technology (CCST) released a report on hydraulic fracturing, as required by State Bill 4, proposed by Senator Pavley. The legislation required the Division of Oil, Gas and Geothermal Resources to create regulations for hydraulic fracturing and other stimulation activities such as acidizing. The report highlighted the necessity of protecting California’s groundwater resources. As another requirement of SB4, the state water resources control board adopted Model Criteria for Groundwater Monitoring in areas of Oil and Gas Well Stimulation, which includes three main components:
- Area-specific required groundwater monitoring near stimulation wells by operators
- Requirements for designated contractor sampling and testing
- Regional scale groundwater monitoring to be implemented by the State Water Board
With these requirements in place to protect groundwater, using hydraulic fracturing and other “extreme” high energy input techniques to extract oil is not currently economical in California. Operators have not submitted a permit application for hydraulic fracturing in CA since June 2015.
This status may change in the near future, though, as DOGGR has proposed groundwater monitoring exemptions for 3 large aquifer systems in Kern and Arroyo Grande counties. Such a proposal would mean that operators would not have to monitor for groundwater contamination in these areas when using hydraulic fracturing or other stimulation technologies like acidizing.
Previous Fracking Activity
One outcome of the aforementioned CCST report on hydraulic fracturing was a review of stimulation activity that has occurred in CA but went undocumented. Researchers at Lawrence Berkeley National Laboratory (LBNL) screened thousands of oil and gas well logs and records to calculate the extent to which hydraulic fracturing was actually being used in California’s oil fields. LBNL derived “Well Stimulation Treatment” probabilities based on the number of well records that reported utilizing hydraulic fracturing.
Probabilities were then derived for each pool, which is a geographically isolated formation within an oil field. Using these probabilities, FracTracker calculated a conservative estimate for the number of stimulated wells in the state at over 38,000. There are 228,010 unique Well ID’s listed in the DOGGR database. This puts the proportion of hydraulically fractured wells in California at 16.7% of the total 228,090 wells known.
Whereas many other states break down their oil and gas data to show in what phase of development a well may be, CA identifies all wells between the permitted and producing/injecting phase as “new.” In Figure 2 below you can see the wells identified in 2016 as “new.” The DOGGR dataset shows there are currently 6,561 new wells in California as of July 2016. Counts of new well permits were calculated for individual operators and are listed below in Table 1.
Table 1. Top 10 operators according to new well permit counts in California, along with the number of new well permits currently active, the percent those permits represent of total new well permits in the state, and the percentage of violations the operator is responsible in the DOGGR dataset provided to FracTracker Alliance.
|Order||Operator||Permit Count||Permit %||Violations %|
|1||Aera Energy LLC||2012||30.67%||22.34%|
|2||Chevron U.S.A. Inc.||968||14.75%||20.35%|
|3||California Resources Production Corporation||768||11.70%||5.89%|
|4||Linn Operating, Inc.||574||8.75%||12.04%|
|5||E & B Natural Resources Management Corporation||572||8.71%||1%|
|6||California Resources Elk Hills, LLC||374||5.70%||5.52%|
|7||Seneca Resources Corporation||185||2.82%||2.83%|
|8||Freeport-McMoRan Oil & Gas LLC||164||2.50%||15.22%|
|9||Vaquero Energy, Inc.||154||2.35%||0.22%|
|10||Macpherson Oil Company||116||1.77%||2.09%|
There are 68 fields in CA that have added new wells in the new DOGGR dataset published in July 2016. The top 10 fields are listed in Table 2 below.
Table 2. Top 10 Oil Fields by Permit (New Well) Count
|Order||Oil Field||Well Count|
In Figure 2 below, the counts of new wells in fields are shown in shades of yellow/red. The fields with the highest number of new wells are located in the Central Valley. The top 10 operators’ wells are also identified. The majority of new well permits are located in the South Belridge oil field, and the majority of those wells are operated by Aera Energy. As can be seen in the map, most new wells are located in fields in Kern county, but Santa Barbara and Fresno, and even Salinas counties have fields with 40 or more new well permits.
Figure 2. New Well Permitting Map of Unconventional Drilling in California
Who collects violations data?
In most states with heavy oil and gas drilling, data on violations is collected by the state regulatory agency, aggregated in datasets and spreadsheets, and made available to the public. FracTracker has done analyses with such data in the past.
In Pennsylvania for instance, a 2011 look at the data showed us that as the number of inspectors on the ground in the Marcellus Shale fields increases, the number of violations/well actually decrease. This was important information that challenged the cynical hypothesis: that more inspectors mean additional eyes on the ground to identify more violations during inspections. In reality, more inspectors actually mean that operators are held to higher standards, and further best management practices (BMPs) are employed. This trend at least seemed to be the case in Pennsylvania. As a regulatory agency, such knowledge is incredibly important, and even validates increased spending and budgets for more personnel.
In California, the issue of publishing violations data is again met with a similar response from the Division of Oil Gas and Geothermal Resources (DOGGR), specifically the “Oh, is that my job?” question.
How is it shared?
At FracTracker, we spent time working with regulatory officials at DOGGR to get some data on violations. We were informed that at some point in the future, the data may be aggregated and available digitally. Until then, however, a request for the data would have to be made to each of the six district offices individually and would take approximately a year to pull together scanned copies of violations notices in PDF format. Unfortunately, we at FracTracker do not have the capacity to process such files. Instead we asked for anything DOGGR had digitally available, and we were provided with a sample subset of 2,825 violations dating mostly from 2013 and 2014 and only in District 2, the Los Angeles Basin.
What does CA violations data look like?
Looking at the sample of data in Table 2, we see that the majority of violations are caused by the operators that also have the most new well permits. Aera Energy, in particular, is responsible for over 1/5 of all violations in our sample set. Limiting factors and sampling bias of the sample set of violations may impact this analysis, though, as all violations are limited to Los Angeles County. Operators that mostly operate in the Central Valley will be under represented in the violations count. When more violations data becomes available we will be sure to expand this analysis.
Bans and Regulations on Unconventional Drilling in California
Although every state regulatory agency lambasts that they have the most comprehensive and conservative set of oil and gas extraction regulations, California regulators may actually be right. That is, save for New York which has banned hydraulic fracturing outright.
Regardless of the policy decisions made at the state-level, multiple local municipalities in CA have attempted to or succeeded in passing local bans. Six counties have passed outright bans on unconventional drilling in California, as can be seen in the FracTracker Local Actions map below (Fig. 3). Most recently the county of Alameda, home to the cities of Berkeley and Oakland, has passed a ban. The county of Monterey is also considering a ban on all oil and gas extraction, which has been approved as a local ballot initiative for November 2016.
Figure 3. Local Actions, Bans and Regulations Map
As the price of oil rebounds closer to $100/barrel, there will be more interest by operators to increase unconventional drilling in California. The addition of new aquifer exemptions will make it all the more appealing. These local movements are therefore incredibly important to ensure that “extreme” extraction methods like fracking don’t expand in the future.
Feature Photo: South Belridge field by Sarah Leen, National Geographic
By Matt Kelso, Manager of Data & Technology
Each state has its own definition of what it means for an oil or gas well to be “fracked.” In Pennsylvania, these wells are known as “unconventional,” a definition mostly based on the depth of the target formation:
An unconventional gas well is a well that is drilled into an unconventional formation, which is defined as a geologic shale formation below the base of the Elk Sandstone or its geologic equivalent where natural gas generally cannot be produced except by horizontal or vertical well bores stimulated by hydraulic fracturing.
The count of these unconventional wells in PA stands at 9,760 as of June 14, 2016. Their distribution is widespread across the state, but is particularly focused in the northeast and southwest corners of Pennsylvania.
The industry is not drilling at the same torrid pace as it was between 2010 and 2012, however. The busiest month for drill rigs in the Keystone State was August 2011, with 210 unconventional wells drilled. Last month, there were just 32 such wells.
As Figure 1 captures, the number of permits issued per quarter is always greater than the number of wells drilled during the same time period. Even when drilling activity seems to be entering a bust phase, oil and gas operators continue to plan for future development. Altogether, there are 17,492 permitted locations, meaning there are about 7,700 permitted locations where drilling has not yet commenced.
The number of violations issued by DEP is generally follows the same trends as permits and wells. It is usually the smallest of the three numbers. In the first quarter of 2016, however, is one of a few instances on the chart above where the number of violations issued outpaced wells drilled. There could be any number of reasons for this anomaly; it could have been due to to unusual compliance issued in the field or aggressive regulatory blitzes. It could also be due to some other factor that can’t be determined by the available published data source.
Interestingly, this phenomenon has not occurred since the first quarter of 2010, when the industry was in full swing.
One of the best ways to understand the impact of the industry is to look at violations per well (VpW). Unfortunately, there are a number of important caveats to that discussion. First of all, not all items that appear on the compliance report receive their own Violation ID number. It is clear from the DEP workload report that violations are tallied internally by the number of Violation ID numbers. This is as opposed to the number of items on the compliance report. As of June 14, 2016, there were 6,706 rows of data and 5,755 distinct Violation ID numbers that were issued to 2,080 different oil and gas wells. This discrepancy means that about 21% of unconventional wells are issued violations in Pennsylvania. Those that are cited receive an average of 2.8 to 3.2 violations per well, depending on how you count them.
Determining the violations per well by operator comes with additional caveats. The drilled wells data comes from the spud report, which lists the current operator of each of the wells. The compliance report, however, lists the operator that was in charge of the well at the time of the infraction. This poses a problem for analysis, however. The ownership of the wells is quite fluid when taken in aggregate, as companies fold, are bought out, or change their names to something else.
We calculated VpW figures for the 20 operators with the largest inventory of drilled wells wells in Pennsylvania, found in Table 1. In some instances, we were able to reunite operators with violations that were issued under a different name but are in fact the same company. Specifically, we combined Rex Energy’s violations with RE Gas Dev, CONSOL violations with CNX, and Southwestern with SWN Productions, as the company is now known.
SWN’s violation-per-well score appears to be quite low. Their statistic, however, does not take into account wells that it purchased from Chesapeake in 2014, for example. In this transaction, 435 wells changed hands, with an unknown number of those in Pennsylvania. Any violations on these wells that Chesapeake had would stay with that company even as their well count was reduced. Such a change would thereby artificially inflate Chesapeake’s VpW score. On the other hand, SWN is now in possession of a number of wells which might have been problematic during the early stages of operation. Those violations, alternatively, are not associated with SWN, making their inventory of wells appear to be less problematic.
Data Caveats and Takeaways
Alas, we do not live in a world of perfect data. As such, these results must be taken with a grain of salt. Still, we can see that there are some trends that persist among operators that have been active in Pennsylvania for many years. Chief, Cabon, and EXCO, for example, all average more than one violation per well drilled. Chevron, CNX, and RE Gas Development, on the other hand, have much better rates of compliance, on the order of one violation per every five wells drilled.
Kirk Jalbert, Manager of Community Based Research & Engagement
Kyle Ferrar, Western Program Coordinator
Weld County, Colorado, is one of the top producing shale oil and gas regions in the United States, boasting more than 12,000 active horizontal or directional wells, which account for 50% of all horizontal or directional wells in the state. To put this into perspective, the entire state of Pennsylvania has ten times the land area with “only” 9,663 horizontal or directional wells. At the center of Weld County is the city of Greeley, population 92,889. Greeley has experienced dramatic changes in the past decade as extraction companies compete to acquire oil and gas mineral rights. Extensive housing developments on the outskirts of the city are being built to accommodate future well pads on neighboring lots. Meanwhile, a number of massive well pads are proposed within or on the border of city limits.
FracTracker visited Colorado back in November 2015 and met with regional advocacy organizations including Coloradans Against Fracking, Protect our Loveland, Weld Air and Water, and Our Longmont to determine how we could assist with data analysis, mapping, and digital storytelling. FracTracker returned in June 2016 to explore conditions unique to Weld County’s oil and gas fields. During our visit we interviewed residents of Greeley and found that one of their greatest concerns was the dangers of siting oil and gas wells near schools. While there is much more we will be publishing in coming weeks about our visit, this article focuses on one troubling project that would bring gas drilling to within 1,300ft of a public school. The proposal goes before the Weld County Commissioners on Wednesday, June 29th for final approval. As such, we will be brief in pointing out what is at stake in siting industrial oil and gas facilities near schools in Colorado and why residents of Greeley have cause for concern.
Drilling Bella Romero
On June 7th, the Weld County Planning Commission unanimously approved a proposal from Denver-based Extraction Oil & Gas to develop “Vetting 15H”—a 24-head directional well pad in close proximity to Bella Romero Academy, a middle school just outside Greeley city limits. In addition to the 24-head well pad would be a battery of wastewater tanks, separators, and vapor recovery units on an adjacent lot. The permit submitted to the Colorado Oil & Gas Conservation Commission (COGCC) also states that six more wells may be drilled on the site in the future.
As was detailed in a recent FracTracker article, Colorado regulations require a minimum setback distance of 500ft from buildings and an additional 350ft from outdoor recreational areas. In more populated areas, or where a well pad would be within 1,000ft of high occupancy buildings, schools, and hospitals, drilling companies must apply for special variances to minimize community impacts. Setbacks are measured from the well head to the nearest wall of the building. For well pads with multiple heads, each well must comply with the respective setback requirements.
Vetting 15H would prove to be one of the larger well pads in the county. And while its well heads remain just beyond the 1,000ft setback requirement from Bella Romero buildings, a significant portion of the school’s ballfields are within 1,000ft of the proposed site. When setbacks for the well pad and the processing facility are taken together—something not explicitly demonstrated in the permit—almost the entirety of school grounds are within 1,000ft and the school itself lies only 1,300ft from the pad. The below figures show the images supplied by Extraction Oil & Gas in their permit as well as a more detailed graphic generated by FracTracker.
Youth: A High Risk Population
The difference between 1,000ft and 1,300ft may be negligible when considering the risks of locating industrial scale oil and gas facilities near populated areas. The COGCC has issued 1,262 regulatory violations to drilling companies since 2010 (Extraction Oil & Gas ranks 51st of 305 operators in the state for number of violations). Some of these violations are for minor infractions such as failing to file proper paperwork. Others are for major incidents; these issues most often occur during the construction phases of drilling, where a number have resulted in explosions and emergency evacuations. Toxic releases of air and water pollution are not uncommon at these sites. In fact, the permit shows drainage and potential spills from the site would flow directly towards Bella Romero school grounds as is shown in the figure below.
A host of recent research suggests that people in close proximity to oil and gas wells experience disproportionate health impacts. Emissions from diesel engine exhaust contribute to excessive levels of particular matter, and fumes from separators generate high levels of volatile organic compounds. These pollutants decrease lung capacity and increase the likelihood of asthma attacks, cardiovascular disease, and cancer (read more on that issue here). Exposure to oil and gas facilities is also linked to skin rashes and nose bleeds.
As we’ve mentioned in our analysis of oil and gas drilling near schools in California, children are more vulnerable to these pollutants. The same amount of contaminants entering a child’s body, as opposed to an adult body, can be far more toxic due to differences in body size and respiratory rates. A child’s developing endocrine system and neural pathways are also more susceptible to chemical interactions. These risks are increased by children’s lifestyles, as they tend to spend more hours playing outdoors than adults and, when at school, the rest of their day is spent at a central location.
At the June 7th public hearing Extraction Oil & Gas noted that they intend to use pipelines instead of trucks to transport water and gas to and from Vetting 15H to reduce possible exposures. But, as residents of Greeley noted of other projects where similar promises were made and later rescinded, this is dependent on additional approvals for pipelines. Extraction Oil & Gas also said they would use electric drilling techniques rather than diesel engines, but this would not eliminate the need for an estimated 22,000 trucking runs over 520 days of construction.
Below is a table from the Vetting 15H permit that shows daily anticipated truck traffic associated with each phase of drilling. The estimated duration and operational hours of each activity are based on only 12 wells since construction is planned in two phases of 12 wells at a time. These numbers do not account for the trucking of water for completions activities, however. The figures could be much higher if pipelines are not approved, as well as if long-term trucking activities needed to maintain the site are included in the estimates.
At the Top of the Most Vulnerable List
Bella Romero Academy has the unfortunate distinction of being one of the few schools in Colorado in close proximity to a horizontal or directional well amongst 1,750 public and 90 private schools in the state. Based on our analysis, there are six public schools within 1,000ft of a horizontal or directional well. At 2,500ft we found 39 public schools and five private schools. Bella Romero is presently at the top of the list of all schools when ranked by number of well heads located within a 1,000ft buffer. An 8-head well pad is only 800ft across the street from its front door. If the Vetting 15H 24-head well pad was to be constructed, Bella Romero would be far and above the most vulnerable school within 1,000ft of a well. It would also rank 3rd in the state for well heads located within 2,500ft of a school. The tables below summarize our findings of this proximity analysis.
The following interactive map shows which schools in Colorado are within a range of 2,500ft from a directional and horizontal well. Additional buffer rings show 1,000ft and 500ft buffers for comparison. 1,000ft was selected as this is the minimum distance required by Colorado regulations from densely populated areas and schools without requiring special variances. Environmental advocacy groups are presently working to change this number to 2,500ft. The map is zoomed in to show the area around Bella Romero. Zoom out see additional schools and click on features to see more details. [NOTE: The Colorado school dataset lists Bella Romero Academy as an elementary/middle school. Bella Romero was recently split, with the elementary school moving a few blocks west.]
Map of schools and setbacks in Colorado
Drilling near Bella Romero is also arguably an environmental justice issue, as its student population has some of the highest minority rates in the county and are amongst the poorest. According to coloradoschoolgrades.com, Bella Romero is 89% Hispanic or Latino and 3% African American whereas, according to the U.S. Census Bureau, Greeley as a whole is 59% White and 36% Hispanic or Latino. 92% of Bella Romero’s students are also from low income families. Furthermore, according to the EPA’s Environmental Justice Screening Tool, which is used by the agency to assess high risk populations and environments, the community surrounding Bella Romero is within the 90-95% percentile range nationally for linguistically isolated communities.
These statistics are significant for a number of reasons. Firstly, oil and gas permitting in Colorado only requires operators to notify residents immediately surrounding proposed well pads. This rule does not include residents who may live further from the site but send their students to schools like Bella Romero. Parents who might comment on the project would need to hear about it from local papers or neighbors, but language barriers can prevent this from occurring. Another factor we witnessed in our June visit to Latino communities in Weld County is that many students have undocumented family members who are hesitant to speak out in public, leaving them with no voice to question risks to their children.
Nevertheless, at the June 7th Planning Commission hearing, Weld County administrators insisted that their decisions would not take race and poverty into consideration, which is a blatant disregard for EPA guidelines in siting industrial development in poor minority communities. Weld County’s Planning Commission claimed that their ruling on the site would be the same regardless of the school’s demographics. By comparison, another proposed Extraction Oil & Gas site that would have brought a 22-head well pad to within 1,000ft of homes in a more well off part of town was denied on a 0-6 vote by the City of Greeley’s Planning Commission earlier this year after nearby residents voiced concerns about the potential impacts. Extraction Oil & Gas appealed the ruling and Greeley City Council passed the proposal in a 5-2 vote pending additional urban mitigation area permit approval. While the Greeley Planning Commission and the Weld County Planning Commission are distinct entities, the contrast of these two decisions should emphasize concerns about fair treatment.
There are very real health concerns associated with siting oil and gas wells near schools. When evaluating this project, county administrators should assess not only the immediate impacts of constructing the well pad but also the long-term effects of allowing an industrial facility to operate so close to a sensitive youth population. There are obvious environmental justice issues at stake, as well. Public institutions have a responsibility to protect marginalized communities such as those who send their children to Bella Romero. Finally, approving the Vetting 15H project would place Bella Romero far at the top of the list for schools in Colorado within 1,000ft of oil and gas wells. School board administrators should be concerned about this activity, as it will undoubtedly put their students’ health and academic performance at risk. We hope that, when the County Commissions review the proposal, these concerns will be taken into account.
By Ted Auch, Matt Kelso, and Sam Rubright
PA DCNR recently released a draft State Forest Resource Management Plan. The draft plan, last revised in 2007, is an important tool that the Bureau of Forestry (BOF) uses to help manage Pennsylvania’s approximately 2.2 million acre state forest system. Approximately 1.5 million acres of state forest lands lie within the shale gas fairway and gas extraction – along with related issues like water resources – is among the numerous subjects addressed in the document.
In total, approximately 673,000 acres are available for oil and gas development in PA state forests, either because private interests own the mineral rights below the land or because DCNR has opened up state-lands for drilling where it controls the mineral rights.
Approximately 386,000 acres have been leased by DCNR to allow drilling. DCNR’s shale gas monitoring report in 2014 said that only 16% of available state forest lands have been developed, which means that 84% (or 328,700 acres) could still be accessed for oil and gas through DCNR leases. Another 287,000 acres of state forest land sits atop private mineral rights. Mineral rights supersede – or overrule – those of the surface rights.
By some estimates, the projected “drillout” of state forest lands may include an additional 2,000 to 3,000 unconventional natural gas wells. There are concerns that the draft plan also does not adequately address the full scale and scope of such drilling and the serious impacts associated with it.
Derived from available data, FracTracker has prepared the following portrait of the projected impact to Pennsylvania’s state forest estate with emphasis on the resource-intensive nature of hydraulic fracturing and its extensive footprint on this sensitive landscape.
If you are concerned about these risks and potential development, DCNR is holding twelve meetings to gather public input on this draft plan until Nov 12th. Written comments can also be submitted through November 30 at StateForestPlan2015@pa.gov.
More background information about PA’s Draft 2015 State Forest Resource Management Plan
Extra Resources: Projected Build out Statistics
Table 1. Projected land use needed to add 2,000 to 3,000 more wells on PA state forestlands
|Facility Type||Unit||Projected Drilled Wells|
|Limit Of Disturbance (LOD)*||Acres||7,130||10,695|
|Addtl. Mid/Down-stream Facilities||Acres||2,847||4,271|
*Limit of Disturbance includes infrastructure, mounded earth, etc. needed to access and service the well pads.
**1 compressor station is needed for every 25-30 miles of gathering lines, at 15-30 acres per station.
In Ohio, well pads average 4-5 acres, 3.4 laterals per well pad, and 8.5 acres of gathering line per acre of well pad. However, each pad has what we are calling a “Limit of Disturbance,” which includes infrastructure, mounded earth, etc. LOD likely represents a conservative estimate of miscellaneous land disturbance as it does not include the access roads; it was not possible with our current datasets to discern which roads were specifically added to access the well pads. LODs are averaging 10-14 acres.
Using the 2,000-3,000 wells proposed, the total acreage that could be disturbed by new well pads, well pad LODs, gathering lines, compressor stations, and related mid/downstream facilities in PA’s state forests would be between and 36,621 and 54,931 acres depending on the number and size of compressor stations (i.e., averaging 24 acres) (Table 1).
Table 2. Projected resource use and waste produced per well based on OH, WV, and PA historical figures.
|Variable||Unit||Avg||Increase / Quarter|
|Water Needed||Gallons||3.5 MGs||–|
|Gallons||6.2-7.0 MGs||405-410 K|
|Gallons||7.9 MGs||450 K|
|OH Stats||Tons||700+ (estimate)||4.7-5.2|
|Landfill Waste (Drilling Muds)||Tons / Facility||28,098||15,319|
|Injection Waste||Gallons / Quarter||117 MGs||5.4 MGs|
* 7-9% of injected fluids returns to the surface as fracking waste
** significantly dependent upon lateral length
By Matt Kelso, Manager of Data & Technology
Wells Spudded (Drilled)
Unconventional oil and gas drilling is well established in Pennsylvania, with over 9,200 drilled wells, an additional 7,200 permitted locations that have not yet been drilled, and 5,300 violations all happening since the turn of the millennium. It took a while for the industry to gather steam, with just one unconventional well drilled in 2002, and only eight in 2005. But by 2010, that figure had ballooned to 1,599 wells, which was greater than the previous eight years combined. There were 1,956 wells drilled in 2011, representing the peak for unconventional drilling activity in Pennsylvania (Figure 1).
None of the three full years since then, however, have seen more than 70% of the 2011 total. Halfway through 2015, the industry is on pace to drill only 842 unconventional wells statewide, which would be the lowest total since 2009, and only 43% of the 2011 total.
Pennsylvania Shale Viewer. Click here to access the full screen view with a legend, layer details, and other tools.
Taken cumulatively, the footprint on the state is immense, as is shown in the map above, and impacts remain for some time. Of Pennsylvania’s 9,234 unconventional wells 8,187 (89%) are still active. Only 474 wells have been permanently plugged so far, with 570 given an inactive status, and one well listed as “proposed but never materialized,” despite being included on the spud report.
Permits & Violations
Figure 2 shows the monthly totals of permits, wells, and violations over the last 60 months. Linear trendlines were added to the chart to give a visual representation of changes over time if we ignore the noise of the peaks and troughs of activity, which is an inherent attribute of the industry. Each of the three trendlines has a negative slope1, showing downward trends in each category.
In fact, permits for new wells are declining more rapidly than the drilled wells, and violations issued are declining at a still faster rate. Over the course of five years, these declines are substantial. In July 2010, the smoothed totals that are “predicted” by the trendline show 304 permits issued, 159 wells drilled, and 128 violations issued per month. 60 months later, one would expect 213 permits, 81 wells drilled, and just 12 violations issued2.
Location of Drilling Activity
The oil and gas industry has been more selective about where unconventional wells are being drilled in recent years, as well. Altogether, there are unconventional wells in 39 different counties, with 32 counties seeing action in both 2010 and 2011. That number is down to 22 for both 2014 and the first half of 2015. There has been drilling in 443 different municipalities since 2002, with a maximum of 241 municipal regions in 2011, which shrank to 161 last year, and just 88 in the first half of 2015.
Summary of unconventional wells drilled in each Pennsylvania county by year, through June 30, 2015. Click here to access the full screen view with a legend, layer details, and other tools
Clicking on any of the counties above will show the number of unconventional wells drilled in that county by year since the first unconventional well was spudded in Pennsylvania back in 2002. The color scheme shows the year that the maximum number of unconventional wells were drilled in each county, with blues, greens, and yellows showing counties where the activity has already peaked, oranges showing a peak in 2014, and red showing a peak in 2015, despite only six months of activity. 30 of the 39 counties with unconventional wells in the state saw a peak in activity in 2013 or before.
- The equations for the three trendlines are as follows:
- Permits: y = -1.5128x + 303.81
- Wells: y = -1.2939x + 158.95
- Violations: y = -1.9334x + 127.53
- The lowest actual value for each category are as follows:
- Permits: 117, in July 2012
- Wells: 43, in February 2015
- Violations: 16, in August 2014.
New Report from FracTracker and the Natural Resources Defense Council
By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance
The FracTracker Alliance recently contributed to a report released by the Natural Resources Defense Council (NRDC), titled Drilling in California: Who’s at Risk?. In the report, we find that many communities disproportionally burdened by environmental and public health degradation also live in the areas most impacted by oil and gas (O&G) development, including hydraulic fracturing and acidizing. Additionally, the communities most impacted by such oil and gas activity are disproportionately non-white. Key points of the report are listed below, as outlined by the NRDC:
Key Points of “Drilling in California” Report
- Expanding oil production in California, in areas already heavily drilled or in new areas, can threaten the health of communities.
- New analysis shows that, already, approximately 5.4 million Californians live within a mile of one, or more, of the more than 84,000 existing oil and gas wells.
- More than a third of the communities living with oil and gas wells are also burdened with the worst environmental pollution, as measured by CalEPA’s CalEnviroScreen 2.0. These communities, with heightened risks, are 92 percent people of color.
- To prevent further environmental damage and public health threats, major improvements are required before hydraulic fracturing, acidizing, and other stimulation techniques are allowed to continue in California.
The analysis used the California Environmental Protection Agency (CalEPA) Office of Health Hazard and Assessment’s (OEHHA) impact screening tool CalEnviroScreen 2.0, which ranks all the census tracts in CA based on various indicators of environmental and public health degradation due to pollution sources. Stimulated and non-stimulated O&G well-site data came from multiple sources including the Division of Oil, Gas and Geothermal Resources; the South Coast Air Quality Management District; and FracFocus.
Visualizing the Data
The interactive web map below (Figure 1) provides a visual understanding of how these areas may be additionally burdened by California’s industrial oil and gas extraction activities. The CalEnviroscreen 2.0 dataset of census tract scores was mapped spatially to show the areas in CA disproportionately burdened by existing environmental stressors and health impacts. The locations of CA’s O&G production wells were overlaid on these maps since the CalEnviroscreen ranks did not specifically take into account the role of O&G extraction activity in communities. The top 20th percentile of total scores are shown in the map’s default view, and more CalEnviroscreen scores are displayable under the “Layers” tab (top right).
Figure 1. The top 20th percentile of highest CalEnviroscreen 2.0 total scores are shown in the map above along with well counts by census tract. Increasing well counts are portrayed with orange circles that increase in size with the number of wells. Click here to explore.
Figures 2-7 below are provide printable examples of several of CalEnviroscreen’s 2.0’s most important rankings when considering O&G extraction activity.