Ever since the DEP responded to FracTracker’s request for oil and gas violation data in October 2010, I have been providing periodic updates of the data in a variety of meaningful ways, such as raw violations totals and violations per amount of gas produced. But for most purposes, the best analysis has always been in terms of violations per well.
Since that time, the data have improved considerably. Not only have significant issues been addressed with both datasets, but the violations and drilled wells are now both relatively easy to access online directly from the DEP. That does not mean, however, that the available datasets are perfect or straightforward. For example, the DEP seems to count violations by the number of violation ID numbers issued, but upon closer inspection, that’s not the full story, and as a result, I prefer to use the total number of entries on the compliance report instead. The situation for permits and wells used to be almost exactly the opposite, as those reports often list multiple actions for the same well.
I have not checked the permits report lately but as I began this analysis, I was surprised to discover that the drilled wells list has been cleaned up considerably, as each unique eight digit well API number appears on the list exactly once. Now I may be the only one excited about this, but it is a notable milestone in the evolution of the data in my humble opinion, because it removes an element of interpretation which can have a significant impact on the result of the analysis. And as an added bonus, it makes the analysis much easier, too.
So let’s take a look at violations per well (VpW) from January 1, 2005 through June 12, 2012:
Violations per well by year in Pennsylvania’s Marcellus Shale.
Keep in mind that if we were talking about raw totals of violations and wells, it would of course be significant that we are less than half way through the year. As a ratio, however, that’s not the case, and there is no reason to expect the VpW for 2012 to change substantially up or down based on seasonality. Looking at the the trend, however, there is plenty of reason to expect the final score to be lower, as the rate of violations per well has been declining sharply in recent years. In fact, the current 2012 rate of 0.51 violations per year is less than half of the 1.14 violations per Marcellus well that we saw in 2009. Certainly, that’s an encouraging trend, if it can be attributed to changes in practices in the field, and not just changes how violations are administered, coinciding with changes in the executive branch of the state government.
One of those changes made by the new administration was an effort to route the violations process through Harrisburg. It was a move that raised considerable suspicion among some people, as it had the appearance of moving the oversight process a good bit closer to elected and appointed officials. But on the other hand, it was clear that the three DEP offices which handled oil and gas violations were not on the same page:
2010 Violations per Well by DEP issuing region.
Violations issued from the North Central Regional Office (NCRO) were roughly three times that coming from either the North West Regional Office (NWRO) or the South West Regional Office (SWRO). As the role of the regional office is supposedly diminished in determining what is and is not a violation, we will take a look at the 2012 data on a county by county basis:
Marcellus Shale violations per well (VpW) by county from 1-1-12 through 6-12-12. Counties outlined in yellow contained at least one drilled well during the period.
Compared to the map above, it seems like the strong association with VpW score and regional office affiliation is starting to break down. For those who are are curious, you can see all of the data for each county dating back to 2005 by clicking on the blue “i” tool, then any map outline.
But because the VpW scores can be so exaggerated for counties with just a handful of Marcellus Shale wells, let’s take a look at the five counties with the most wells, all of which were in the North Central Regional Office jurisdiction except for Washington, which was in the South West Regional Office:
Violations per Well for the 5 counties in PA with the most Marcellus Shale wells, as of 6-12-2012.
Last year was the first time since 2007 that Washington County did not have the lowest VpW score out of the five counties with the most wells. In this subset, trends are down across the board since 2009, and now the counties that are major players in the Marcellus are all much closer together.
When it was learned that the plan at the DEP was to have Secretary Krancer approve each Marcellus violation, the prediction that the number of violations relative to the activity of the industry would decrease was widespread. Even though the specific plan was scuttled, the expected result came to pass anyway. And yet, the validated hypothesis does not amount to proof of political meddling; the possibility that the data reflect improved practices in the field would also net the same result.