Assessment of Rework Permits on Oil Production from Operational Wells Within the 3,200-Foot Public Health Protection Zone
Rework operations on oil and gas production wells are significant sources of local and regional air quality degradation and put frontline communities and sensitive individuals at elevated risk of health impacts. They are also sometimes necessary to resume normal production following a mechanical failure within a well bore. Rework activities typically require operators to open the well bore to the surface environment, resulting in an uncontrolled release of hazardous air pollutant emissions, including toxic and carcinogenic volatile hydrocarbons. To accommodate this pollution, operators are granted 90-day exemptions from the Clean Air Act and all California Air Resources Board emissions regulations.
Due to the exposure risks resulting from rework operations, both SB 1137 and CalGEM’s emergency implementaion of the rule include a ban on rework and workover operations, in addition to new drilling, within the 3,200’ public health protection zone. While this rule will protect the health of millions of Californians, there is a concern that the public health emergency rule will decrease domestic oil production volumes from California. This report therefore assessed how this new rule will impact future production in California, and based on the data made the following determinations.
• An average 1.9% of producing wells within the protection zone receive rework permits each year.
• Denying rework permits would result in an estimated 1.75% loss in annual production, statewide.
• Rates of production decline were faster for reworked wells than non-reworked wells.
• Production increases following rework operations decreased rapidly; 63.5% of reworked wells remained stripper wells, with that percentage climbing to 84.4% within three years.
• The majority of rework permits (66%) have been issued to wells in Kern County.
• The majority of wells operating within the public health protection zone are stripper wells (83%).
• Non-stripper wells were 30% more likely to be reworked than stripper wells.
The results of this analysis show that the policy proposed in SB 1137 of denying rework permits within the health protection zones is a common sense public health intervention. This policy will have the benefit of accelerating the process of well retirement and site remediation for high risk wells, reducing the counts of marginal wells that evade idle status. Maintaining marginal wells with extended production decline curve time frames has allowed operators to dump bad assets on shell companies. Reports show that such wells can be neglected, resulting in leaks and air quality degradation, or orphaned to the state. Plugging and abandoning these wells instead of granting emissions exemptions for hazardous rework operations will improve the local and regional air quality for frontline communities. Additionally, denying rework permits will have a minimal effect on production within the protection zone, which is a fraction (just 1.75% in 2021) of overall statewide production.
This short summary report assesses how rework operations impact oil and gas well production volumes. The analyses summarize impacts at the state level, and then focus on rework permit activity that had occurred within the boundaries of a 3,200’ protection zone from sensitive receptors, as defined by SB 1137. The data analysis overlaid annual oil well production data with rework permit notices to answer several questions that provide insight into how many oil wells will potentially discontinue production as a result of the implementation of SB 1137. The law prohibits operators from obtaining a Notice of Intention (NOI), which is necessary to rework, sidetrack, or deepen existing wells. If the majority of oil wells are generally only productive for a few years without reworking them, it is important to understand the possible repercussions on production from eliminating the ability for operators to receive rework permits. The map below shows the locations where CAlGEM has issued permits, and highlights permits that have been issued within the health protection zones.
This analysis assessed how the trends of oil production are impacted by rework operations. Typical reworks are conducted when some sort of technical issue either reduces or prevents production from the borehole of a well. It is not clear to what extent production increases in a well following a rework operation; neither is the typical lifespan of production following the rework. Analyzing reported production volumes for wells prior to rework operations can provide insight into the health wells prior to a rework, as well as the impetus for operators to apply for rework permits. Comparing production volumes prior to a rework with production volumes post-rework provides insight into the impact of reworks on production. Analyzing production data for a sample cohort population of oil-producing wells located within the 3,200’ public health protection zone that also received a rework permit provided an estimation of the potential impact on production of denying rework permits within the protection zone. If reworks permits are denied within the protection zone, the resulting loss in future production will be similar to the historical increase in production following well reworks, if rates of reworks remain consistent.
The analysis also focused on how eliminating the ability to receive rework permits could affect production and to develop an understanding of the effect of well rework operations on production in general. Therefore parts of this analysis included statewide data in order to assess the general impact of rework operations on production, and other sections of this analysis restricted the geography to those areas of California within 3,200’ of a sensitive receptor, as outlined in SB 1137. The latter analyses were conducted using the dataset of wells identified as within the 3,200’ protection zone, identified in previous reports by FracTracker Alliance. This dataset of wells was cross-referenced with both the CalGEM weekly summary reports of issued permits and the CalGEM well production and injection summary reports.
All analyses in this report were limited by the availability of CalGEM permitting data, which was compiled and transcribed from CalGEM weekly permitting updates. Accurate permitting data was not available prior to 2010. Therefore much of this analysis focused on the last 10 years of permitting data and those same years of production data (2012-2021). This analysis compared production figures for wells before and after rework permits were issued. Permitting and production data for these years were compiled and summarized from the annual CalGEM monthly production datasets and CalGEM weekly permit update files using Python Ver 3.10.7.
California Oil and Gas Permits
This interactive map looks at the locations of oil and gas permits issued by GalGEM to California operators for new drilling, reworking, sidetracking and deepening well, and highlights the permits located within 3,200’ of sensitive receptors, including homes, schools, healthcare facilities, and other public locations.
View the map “Details” tab below in the top right corner to learn more and access the data, or click on the map to explore the dynamic version of this data. Data sources are also listed at the end of this article.
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View Full Size Map | Updated 1/13/2023| Map Tutorial
Rework operations are used to fix functional issues with oil and gas wells that occur downhole in the wellbore. “Rework” as a legal term means actual work in the hole of an oil or gas well previously completed as a producer that is related to the cause of cessation of production and is made in an attempt to recomplete or repair a well to return it to production, or as defined by the California regulatory code as “any operation subsequent to drilling that involves deepening, redrilling, plugging, or permanently altering in any manner the casing of a well or its function.” Reworks may also be related to workovers, which are more extensive repair or maintenance procedures that require “shutting-in” the well, or stopping production, before work is performed. A workover can also include changing the producing zone in a well or re-completing the well to produce from a different payzone. Without these rework operations, production wells are not likely to be able to function safely.
Reworks, workovers, sidetracks and redrills are included in the prohibitions of SB 1137 due to the elevated risk at which they place communities (for the sake of brevity, this report will use the term rework as an umbrella term that includes all of these prohibited activities that require operators to obtain a ‘notice of intent’). For the considerations of exposure assessment and risk management, these operations can be considered synonymous with drilling new wells. These types of permits reintroduce exposure risks by allowing operators to restart production at a wellsite that had already run its productive course. While an operator may be able to restart production, the majority of reworked wells are not able to maintain production for long, as the data shows. Additionally the payoff is not worth the long-term risk of extending the life of an operational well near communities, or the short term exposures that can occur during the actual rework operations.
Operators are granted 90 day exemptions from Air District rules [§ 956689(a)(2)(G)] while rework operations are occurring. Operators would otherwise unquestionably violate California Air Resources Board emissions regulations, as well as the additional public health protections of local districts. When operators perform rework operations they necessarily open the wellbore to the atmosphere, freely venting what are often large volumes of hydrocarbon emissions. An example of this is shown in the optical gas imaging footage below, of a production facility actively conducting rework operations on a well pad in Santa Barbara, CA. The plumes of emissions are visible, continuously moving over the fencelines of the facility.
Time Frame Analysis of Rework Operations on Production
Multiple CalGEM datasets were aggregated to complete this analysis, including the current “AllWells” dataset, annual production and injection volume data, and weekly permit updates. The analysis was specifically focused on oil/condensate production so datasets were limited to the wells that reported any volume of production during the time periods of the analysis. This was necessary since well status codes are often unreliable.
The AllWells dataset of unique API ID’s used for the analysis was limited to wells that had received just one (1) rework permit in the last 10 (2012-2021) years in order to eliminate the influence on production of multiple rework operations in consecutive years. An additional 5-year subset 2014-2018 (N=6,668) was pulled from the ten year dataset. Monthly production figures for each well was then summed annually. Annual production volumes were calculated for:
- the year prior to the year the permit was issued,
- the year the permit was issued, and
- the three years following the rework permit.
These years were selected in order to compare annual production volumes prior to rework operations, to production volumes following rework operations. California does not publish a dataset of notifications for actual rework operations. Therefore for the production year prior to rework, this study used the lesser value (volume) of either the year of the issued rework operation or the prior year’s production total. For post-rework production volumes, this study used the maximum annual production value taken from the subset of three years of annual oil/condensate production following the year of the rework permit. This was done in order to account for the standard two-year lifespan of a CalGEM rework permit under the assumption that reworking a well is conducted with the intention of resuming production and possibly increasing production, at least temporarily.
Production Increases Following Reworks
The data shows that production following rework operations during this 5 year timespan is estimated to have increased from reworked wells 809.2% from one year to the next. Production from wells prior to rework totaled 3,411,174 bbls/year (n=3,818). Following the rework, the sample set of the same wells produced an estimated 27,604,364 bbls/year. This increase is specifically representative of the year directly following rework operations. The production data shows this bump in production to be a short lived phenomenon, as production decreased rapidly in consecutive years, dropping an estimated 42.8% by the third year following rework.
Additionally, production from many reworked wells did not have a positive response, or did not resume production at all. Of the 3,818 wells that received rework permits, an estimated 648 (17.0%) failed to improve or increase production volumes. Of the other 3,169 wells that showed some sort of improvement, 51.0% were not able to produce more than 10 bbls/day. While some did regain production, the majority (63.5%) remained stripper wells, producing less than 15 bbls/day.
Data from 1 year post rework showed that of the total reworked (n=3,818), just 30.3% of the wells produced enough oil to not be classified as a stripper well for at least one year following the rework. While some wells resumed production a large proportion (38.3%) of productive wells stopped producing or went idle altogether within the three years following the rework; 77.1% produced less than 10 bbls/day; and 84.4% produced stripper well volumes (<15 bbls/day).
While these percentages of stripper wells are rather high considering the resources spent on the wells to conduct rework operations, the figures are pretty similar to the distribution of production throughout the state. In 2021; 44,791 wells reported oil/condensate production, with just 15.4% of wells reporting production volumes greater than 15 bbls/day, versus 15.6% for wells that had received a rework permit within the three previous years.
Analysis of Past Reworks on Current Production (2021)
In total there are 27,352 operational oil and gas wells (status = active/idle/new) that have been identified with a wellhead location within the 3,200’ public health protection zone. Of those 27,352; 5,262 (19.2%) have received rework permits during the last 10 years (between January 1, 2012-December 31, 2021), compared to 2,528 (9.2%) over the course of the last five years (January 1, 2017-December 31, 2021).
Over the past 10 years, producers have been granted a total of 3,921 permits to drill new wells within the protection zone; 1,044 in the last 5 years. Trends for reworks were a bit different, and actually increased during this same time period. Over the course of the last 10 years (January 1, 2012- December 31, 2021) there were about 27,500 total rework permits issued by CalGEM; 7,354 (26.7%) were issued to wells within the protection zone limits.
Analysis by Production Volume
According to CalGEM production reports, in 2021 California produced 137,157,387.6 barrels of oil/condensate. FracTracker’s protection zone analysis shows that 33,287,112 barrels of oil/condensate (24.3%) were produced from oil wells within the 3,200’ protection zone. The vast majority of California’s oil wells produce stripper well volumes. It is therefore important to explore if there are differences in well reworking counts for higher versus lower producing wells. This will provide insight into what types of wells (high producing vs stripper) are more likely to receive rework permits and are therefore more impacted by SB1137.
To focus on higher producing wells the dataset was limited to wells producing more than at least 15 barrels per day (bpd), based on the reported annual estimate for 2021. This works out to a total of 5,475 bbls per year. Oil wells producing less than that are considered“stripper” wells. Many of the wells producing less than this amount may not be economically viable to continue operations considering the engineering requirements of SB1137. Differences in rework rates between stripper wells and higher producing wells are therefore important to consider. The population of higher producing wells within the protection zone that have received rework permits over the course of the last 5 and 10 years were therefore aggregated and compared to the sample population of stripper wells.
The permitting and production data show that non-stripper wells received more rework permits proportionally than did stripper wells within the protection zone. Of the 10,784 oil wells that have reported production from within the protection zone for 2021; 1,834 (17.0%) wells produced more than 15 bpd. As such, 83% of wells located within the protection zone and reporting production in 2021 were stripper wells. Of those 1,834 non-stripper wells, 431 (23.5%) received at least one rework permit within the previous 10 years (2012-2021), and 233 (12.7%) received at least one rework permit within the previous 5 years (2017-2021). Of the 8,950 stripper wells in the protection zone, 1,612 (18.0%) received at least one rework permit within the previous 10 years (2012-2021), and 906 (10.1%) received at least one rework permit within the previous 5 years (2017-2021). These figures show that higher producing wells (>15 bpd) received higher percentages of rework well permits than stripper wells. Over the 10 year period, non-stripper wells were 30% more likely to receive a rework permit than a stripper well, and 26% more likely over the 5 year period.
Breaking the data down into basins shows the regional rates of production decline. Comparisons are shown below in Table 1. The analysis did not take into account the spud dates of the wells or the age of the wells. The table shows that while the Los Angeles (LA) basin has the highest count of non-stripper wells within the protection zone, the LA basin received the fewest rework permits per well. Unique to the LA basin, permit counts have decreased in the last five years, whereas in the Central Valley (CV) and the Central Coast (CC) they have increased. The CC had the highest percentage of rework permits issued per non-stripper well in the protection zone, followed by the CV. These regional differences may have an impact on regional reductions of operational wells and production volumes via the implementation of SB1137.
Table 1. Counts of producing wells within the 3,200’ protection zone in each basin (2021) and the counts of rework permits issued to these wells over the course of the last 5 and 10 year periods.
|Full State||Central Valley||Los Angeles||Central Coast|
|Wells Producing > 15bbls/day (2021)||1,834||643||886||305|
|5 Year Permit Count||233||106||50||78|
|5 Year Permit Count %||12.7%||16.5%||5.6%||25.6%|
|10 Year Permit Count||431||162||157||112|
|10 Year Permit Count %||23.5%||25.2%||17.7%||36.7%|
For the full state including areas outside the protection zone, oil wells in Kern County, which produced 69.1% of of oil in California (2021), were issued 16,130 rework permits over the course of the last 10 years (66% of total rework permits issued), while wells in Los Angeles County with 2,752 rework permits (just 8% of total) had the second most by county. This substantial difference shows that much more rework activity occurs in the CV versus other regions of the state and reflects the increased production from Kern County specifically. Also, the production data shows that for the cohort of wells producing above stripper levels in 2012, production declined the most for wells in the CV Basin. This held true both for wells that received rework permits and those that did not. In both the CV and the LA Basins, wells that received reworks were more likely to not be producing above stripper levels 10 years later than wells that had not been reworked. For wells of the CC basin, production from both reworked and non-reworked wells declined below the level of stripper production at essentially the same rates.
Comparing Current Production for Wells with vs without Reworks
Production Greater than 15 Bbls per Day
To evaluate the potential for wells to continue production above 15 bbls per day without well reworks, this analysis tracked production over the course of these 5 and 10 year periods. Production volumes for wells producing above the stripper threshold in 2012 were tracked and the incidences of rework permits were noted. Of the 1,903 wells producing more than 15 bpd in 2012; 1,576 (82.8%) did not receive a rework permit during the following 10 year period (2012-2021). Without a rework permit during this 10 year period; 482 wells (30.6%) remained productive above a stripper level. Of the 327 producing wells that received rework permits during this period, 69 (21%) continued to produce oil at greater than stripper volumes in 2021. Wells that received reworks were 31% more likely to become stripper wells.
Regionally these figures followed similar trends, although substantial differences in rates of reworks and rates of decline did provide insight into the future for each basin. For the Los Angeles (LA) Basin (production from Los Angeles and Orange Counties), of the just 788 wells in LA producing more than 15 bpd in 2012; 679 (86.3%) did not receive a rework permit during the following 10 year period (2012-2021). Without a rework permit during this 10 year period; 276 wells (40.6%) remained productive above a stripper level. Of the 109 producing wells that received rework permits during this period, 24 (22.0%) continued to produce oil at greater than stripper volumes in 2021. Of note, the percent of wells in the LA Basin that remained productive above stripper levels without a rework permit was 10 percentage points higher than the state total.
For the CV Basin (production from Kern and Fresno), of the just 806 wells in the CV producing more than 15 bpd in 2012; 674 (83.5) did not receive a rework permit during the following 10 year period (2012-2021). Without a rework permit during this 10 year period; 110 wells (16.3%) remained productive above a stripper level. Of the 132 producing wells that received rework permits during this period, 18 (13.6%) continued to produce oil at greater than stripper volumes in 2021. Of note, the percent of wells in the CV that remained producing above stripper levels both with and without a rework permit was lower than the state total.
For the Central Coast (CC) Basin (production from Ventura, Santa Barbara, San Luis Obispo, and Monterey), of the 308 wells in the CC producing more than 15 bpd in 2012; 223 (72.2%) did not receive a rework permit during the following 10 year period (2012-2021). Without a rework permit during this 10 year period; 96 wells (31.1%) remained productive above a stripper level. Of the 85 producing wells that received rework permits during this period, 27 (31.8%) continued to produce oil at greater than stripper volumes in 2021. Of note, the percent of wells in the CC Basin that remained producing above stripper levels both with and without a rework permit was substantially higher than the state total.
Minimally Producing Stripper Wells
The financial burden of required engineering controls will vary from one operator to the next. Some operators will choose to invest in low or marginally producing wells depending on their long-term production strategies, as well as their investment in and utilization of enhanced oil recovery production methods. This assessment therefore provides the same analysis as above, but with the sample set of wells producing between 10 and 1 bbls/day. This sample set represents oil production wells that produced substantially less than the stripper well production threshold.
Production volumes for wells producing volumes less than 3,650 bbls in 2012 (10 bpd) were tracked and the incidences of rework permits were noted over the course of the following 10 years (2012-2021). A lower threshold of 365 bbls/year (1 bpd) was used for this cohort to avoid the inclusion of idle wells. Of the 5,407 wells producing less than 3,650 bbls/year in 2012; 4,531 (83.8%) did not receive a rework permit during the following 10 year period (2012-2021). Without a rework permit during this 10 year period; 2,353 wells (51.9%) remained at least minimally productive (producing over 365 bbls per year). Of the 876 producing wells that received rework permits during this period, 458 (52.3%) continued to produce oil in at least minimal volumes in 2021.
Limiting the data to the 5 year period 2017-2021 shows slightly different results. Over the five year period a significantly smaller percentage or reworked wells stayed (at least minimally) productive, compared to those that had received rework permits. There were 5,935 wells that produced less than 3,650 bbls/year in 2017, making up 64.8% of all the wells reporting production above 1 bbl/day that year. Of the 5,935 wells producing between 365 and 3,650 bbls/year in 2017; 5,317 (89.6%) did not receive a rework permit during the following five year period (2017-2021). Without a rework during this 5 year period, 3,595 (67.6%) producing wells remained minimally productive (above 365 bbls/year). Of the 692 producing wells that did receive a rework permit during this 5 year period, 408 (59.0%) continued to produce oil at volumes between 365 and 3,650 bbls/year in 2021.
Even at these very low production figures, well reworks were not able to increase the lifespan of production for wells. While unreworked marginal wells fared slightly better than reworked wells, the typical decline curve of marginal oil wells eventually caught up. As shown in the 10-year comparison of marginal wells, both reworked and non-reworked wells were eventually equivalent, at the very end of their lifespan.
Monitoring data clearly shows that rework operations present uniquely heightened risks for frontline communities. Necessarily opening a well bore to allow for the rework operations creates a point source release of hazardous air pollutants including toxic and carcinogenic polycyclic aromatic hydrocarbons including BTEX (benzene, toluene, ethylbenzene, and xylenes) compounds that degrade local and regional air quality resulting in a multitude of health impacts. There are also additional volatile acids and other chemicals often used during reworks that present additional exposure risks. This complacent acceptance of this elevated risk scenario has even been codified in California state air quality regulations with a blanket exemption for uncontrolled releases from all extraction activities and production equipment and infrastructure. The exemptions apply to all state rules and protections meant to reduce these risks for communities. Additionally, they last for a full 90 day period. Eliminating rework operations within the public health protection zone will prevent an annual average of 500 unregulated point sources of acute and chronic exposures to air toxics and carcinogens each year in California communities.
When it comes to “asset retirement” and well plugging, it is not completely clear to what extent the SB 1137 policy forbidding rework operations within the 3,200’ protection zone will necessarily accelerate the phase out of operational oil and gas wells within the protection zone, but this analysis shows that the counts of wells transitioning from active to idle or plugged and abandoned well status will be increased. At the face level, about 2% of the wells within the protection zone receive rework permits each year, based on a ten year average. This translates to the elimination of rework operations for 500 wells per year. Additionally it is likely that this count will decrease proportionally with the counts of active wells within the protection zone. Of importance, the implementation of SB1137 may at some point have the side effect of increasing the count of idle wells in the state. Without proper regulation to guide operators to plug these inoperable wells, many of these wells in need of a rework may instead end up in idle well management plans and eventually on California’s orphan wells list. Wellsites are more likely to leak and become sources of hazardous air toxics and environmental contamination with neglect. Policies need to be in place to require operators to plug any wells that become idle within the protection zone.
The production focused portion of this analysis shows that the protection zone for rework permits will likely reduce extraction volumes within the protection zone at a marginal level. The amount of potential or future production that may be eliminated from wells that do not receive reworks within the protection zone was deduced. Measures of production increases following rework operations can be considered equivalent to the theoretical loss of increased production resulting from denying rework permits in the protection zone. Under the assumption that while reworks are necessary for the safe resumption of maximum production for a well, operators are likely to continue producing from a well even if it needs a rework. Preventing rework operations would therefore eliminate the subsequent increase in the volume of production from wells following rework operations.
As reworks permits are denied and if reworks continue at historical rates, the potential loss of future production is likely to be equal to the historical increase in production from wells that have received reworks in the past. Based on this assumption, California could experience an estimated reduction in oil production of about 2,400 MBbls per year from current production levels (2021). This represents an annual 7.1% reduction in production from within the protection zone, which represents 1.75% of oil production statewide. This percentage is likely to decrease steeply over time as operators prioritize reworks for higher producing wells. As higher producing wells are idled and removed from the sample population, they will comprise a smaller proportion of the total.
This report also finds that while there was an immediate increase in production following rework operations, the rework operations did little or nothing to sustain the increased production. Increases in production were short lived and the majority of production volumes declined back to normal (equivalent to their prior production averages) within a three year period. Additionally, wells that received reworks reported production declines at faster rates than those that did not receive rework permits. These comparisons are interesting, because they show that rates of production decline for wells that receive reworks are accelerated. The rework operation permits do not increase the percentage of wells remaining active. Rather rework operations are more regularly issued to wells that are more likely to end production sooner. The small 1.7% increase in production is not worth the additional expenditures of fossil fuels and energy resources necessary for the reworks, or the increased risk of additional community exposures to air toxics. Preventing operators from conducting rework operations within the health protection zones is a common sense public health intervention due to its low cost to the oil and gas industry. It would provide substantial public health protections and has a minimal impact on production.
The results of this analysis show that the policy proposed in SB1137 of denying rework permits will put high risk wells on a track for early retirement. These wells are more likely to have an accelerated production decline, and therefore a shortened production lifespan as it is. Removing the ability for wells to receive reworks will have the added benefit of accelerating well retirement for troublesome wells. This will reduce the typical drawn out production decline curve time frames that have allowed wells to change ownership and has resulted in tens of thousands of stripper wells evading inclusion in idle well management plans. Plugging these wells earlier instead of granting emissions exemptions will reduce the counts of marginally producing wells at risk of becoming orphaned in the near future and will improve the local and regional air quality for frontline communities. This is a sensible tradeoff as the data shows that denying rework permits will have a small impact on production within the protection zone, which is a minimal amount of overall statewide production.
References & Where to Learn More
- Implications of a 3,200-Foot Setback in California by Kyle Ferrar, FracTracker Alliance (April 2022)
- Information and documents related to current rulemaking efforts by the California Department of Conservation
- “Public Health and Safety Risks of Oil and Gas Facilities in Los Angeles County” by Los Angeles County Department of Public Health (February 2018)
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