New Neighborhood Drilling Permits Issued While California Fails to Act on Public Health Rules
California drilling permits continue while Frontline communities and grassroots groups call for an immediate moratorium and 2,500′ setback.
California Denies Well Stimulation Permits
California regulators recently denied 21 well stimulation permit applications—a welcomed move in the right direction—but not enough.
Mapping PFAS “Forever Chemicals” in Oil & Gas Operations
FracTracker Alliance released a new map identifying the locations of over 1,200 oil and gas wells using toxic “forever chemicals” in Arkansas, Louisiana, Oklahoma, New Mexico, Texas, and Wyoming.
EPA
Impacts of 2020 Colonial Pipeline Rupture Continue to Grow
In August 2020, the Colonial Pipeline ruptured, spilling an estimated 1.2 million gallons of gasoline—18 times more than originally reported.
2021 Pipeline Incidents Update: Safety Record Not Improving
The map below shows 6,950 total incidents since 2010, translating to 1.7 incidents per day. Pipelines are dangerous, in part because regulation around them is ineffective.
Shell’s Falcon Pipeline Under Investigation for Serious Public Safety Threats
Breaking News
The Falcon Ethane Pipeline System is at the center of major investigations into possible noncompliance with construction and public safety requirements and failing to report drilling mud spills, according to documents obtained from the Pennsylvania Department of Environmental Protection (PA DEP) by FracTracker Alliance. These investigations, which are yet to be released, also uncovered instances of alleged data falsification in construction reports and Shell Pipeline Company firing employees in retaliation for speaking up about these issues.
3/17/21 Press release: https://www.fractracker.org/falcon-investigation-press-release-fractraccker-alliance/
Key Takeaways
- Shell’s Falcon Pipeline, which is designed to carry ethane to the Shell ethane cracker in Beaver County, PA for plastic production, has been under investigation by federal and state agencies, since 2019. The construction of the pipeline is nearing completion.
- Allegations in these investigations include issues with the pipeline’s coating, falsified reports, and retaliation against workers who spoke about issues.
- Organizations are calling on public agencies to take action to protect public welfare and the environment along the entire pipeline route through Ohio, West Virginia, and Pennsylvania.
- These investigations reveal yet another example of the life-threatening risks brought on by the onslaught of pipeline construction in the Ohio River Valley in the wake in the fracking boom. They also reveal the failure of public agencies to protect us, as documents reveal the federal agency that oversees pipeline safety did not adequately respond to serious accusations brought to its attention by a whistleblower.
- These new concerns are coming to light as people across the country are demanding bold action on plastic pollution and the climate crisis through campaigns such as Build Back Fossil Free, Plastic Free President, and Future Beyond Shell. On a local level, residents in the Ohio River Valley continue to shoulder the health burdens of the fracking industry, despite a recent ban on fracking in the eastern part of Pennsylvania, which a growing body of scientific evidence verifies. The Falcon Pipeline, which would transport fracked gas for plastic production, is directly at odds with these demands.
Shell’s attempts to cut corners while constructing this 98-mile pipeline, likely motivated by the increasingly bleak economic prospects of this project, present serious public safety concerns for the thousands of residents along its route in Pennsylvania, West Virginia, and Ohio.
These allegations are serious enough to warrant immediate action. We’re calling on the Pipeline and Hazardous Materials Safety Administration (PHMSA) to thoroughly examine these allegations and suspend construction if not yet completed, or, in the case that construction is complete, operation of the Falcon Pipeline. Furthermore, we call on state environmental regulators to fully investigate construction incidents throughout the entire pipeline route, require Shell Pipeline to complete any necessary remediation, including funding independent drinking water testing, and take enforcement action to hold Shell accountable. Read our letters to these agencies here.
These investigations were featured in a March 17th article by Anya Litvak in the Pittsburgh Post-Gazette.
3/18/21 update:
Additional coverage of this story was published in a Times Online article by Daveen Ray Kurutz, a StateImpact Pennsylvania article by Reid Frazier, and an Observer-Reporter article by Rick Shrum.
Pipeline workers speak out
According to documents obtained through a public records request, a whistleblower contacted PHMSA in 2019 with serious concerns about the Falcon, including that the pipeline may have been constructed with defective corrosion coating. PHMSA is a federal agency that regulates pipeline operation. The whistleblower also shared environmental threats occurring within the DEP’s jurisdiction, prompting the PA DEP and Pennsylvania Attorney General’s Office to get involved.
Many of the issues with the Falcon relate to a construction method used to install pipelines beneath sensitive areas like roads and rivers called horizontal directional drilling (HDD). Shell Pipeline contracted Ellingson Trenchless LLC to complete over 20 HDDs along the Falcon, including crossings beneath drinking water sources such as the Ohio River and its tributaries. FracTracker and DeSmog Blog previously reported on major drilling mud spills Shell caused while constructing HDDs and how public agencies have failed to regulate these incidents.
Falcon Pipeline Horizontal Directional Drilling locations and fluid losses
This map shows the Falcon Pipeline’s HDD crossings and spills of drilling fluid spills that occurred through 3/5/2020. To see the data sources, click on the information icon found in the upper right corner of the map header as well as under the map address bar.
View Map Full Sized | Updated 6/16/20
PHMSA’s incomplete investigation
Correspondence between the PA DEP and PHMSA from February 26, 2020 reveal the gravity of the situation. While PHMSA conducted an inquiry into the whistleblower’s complaints in 2019 and concluded there were no deficiencies, PA DEP Secretary Patrick McDonnell wrote that his agency felt it was incomplete and urged PHMSA to conduct a more thorough investigation. Secretary McDonnell noted the PA DEP “has received what appears to be credible information that sections of Shell’s Falcon Pipeline project in western PA, developed for the transportation of ethane liquid, may have been constructed with defective corrosion coating protection,” and that “corroded pipes pose a possible threat of product release, landslide, or even explosions.”
FracTracker submitted a Freedom of Information Act request with PHMSA asking for documents pertaining to this inquiry, and was directed to the agency’s publicly available enforcement action webpage. The page shows that PHMSA opened a case into the Falcon on July 16, 2020, five months after Secretary McDonnell sent the letter. PHMSA sent Shell Pipeline Company a Notice of Amendment citing several inadequacies with the Falcon’s construction, including:
- inadequate written standards for visual inspection of pipelines;
- inadequate written standards that address pipeline location as it pertains to proximity to buildings and private dwellings;
- compliance with written standards addressing what actions should be taken if coating damage is observed during horizontal directional drill pullback; and
- inadequate welding procedures
Shell responded with its amended procedures on July 27, 2020, and PHMSA closed the case on August 13, 2020.
Of note, PHMSA states it is basing this Notice on an inspection conducted between April 9th and 11th, 2019, when construction on the Falcon had only recently started. PHMSA has confirmed its investigation on the Falcon is ongoing, however we question the accuracy of self reported data given to PHMSA inspectors should be questioned
The PA DEP also brought the matter to the attention of the US Environmental Protection Agency.
Timeline of events in the Falcon investigation
Public knowledge of these investigations is limited. Here’s what we know right now. Click on the icons or the event descriptions for links to source documents.
Ohio and West Virginia
The Falcon pipeline also crosses through Ohio and briefly, West Virginia. While we do not know how these states are involved in these investigations, our past analyses raise concerns about the Ohio Environmental Protection Agency’s (OEPA) ability to regulate the pipeline’s HDD crossings.
One of the focuses of the Pennsylvania DEP’s investigation is the failure to report drilling fluid spills that occur while constructing a HDD crossing. The PA DEP shut down all HDD operations in November, 2019 and forced Shell to use monitors to calculate spills, as was stated in permit applications.
A horizontal directional drilling (HDD) construction site for the Falcon Pipeline in Southview, Washington County, Pennsylvania. You can see where the drilling mud has returned to the surface in the top left of the photo. Photo by Cyberhawk obtained by FracTracker Alliance through a right-to-know request with the Pennsylvania Department of Environmental Protection.
The Falcon Pipeline’s HDD locations are often close to neighborhoods, like the HOU-02 crossing in Southview, Washington County, Pennsylvania. Photo by Cyberhawk obtained by FracTracker Alliance through a right-to-know request with the Pennsylvania Department of Environmental Protection.
To our knowledge, the OEPA did not enforce this procedure, instead relying on workers to manually calculate and report spills. Shell’s failure to accurately self-report raises concerns about the safety of the Falcon’s HDD crossings in Ohio, including the crossing beneath the Ohio River, just upstream of drinking water intakes for Toronto and Steubenville, Ohio.
Public water system wells, intakes, and Drinking Water Source Protection Areas nears the Falcon Pipeline Route. Note, the pipeline route may have slightly changed since this map was produced. Source: Ohio EPA
The Shell ethane cracker
The Falcon is connected to one of Shell’s most high-profile projects: a $6 billion to $10 billion plastic manufacturing plant, commonly referred to as the Shell ethane cracker, in Beaver County, Pennsylvania. These massive projects represent the oil and gas industry’s far-fetched dream of a new age of manufacturing in the region that would revolve around converting fracked gas into plastic, much of which would be exported overseas.
Many in the Ohio River Valley have raised serious concerns over the public health implications of a petrochemical buildout. The United States’ current petrochemical hub is in the Gulf Coast, including a stretch of Louisiana known colloquially as “Cancer Alley” because of the high risk of cancer from industrial pollution.
Construction of the ethane cracker and the Falcon pipeline have forged forward during the COVID-19 pandemic. In another example of the culture of fear at the worksite, several workers expressed concern that speaking publicly about unsafe working conditions that made social distancing impossible would cost them their jobs. Yet the state has allowed work to continue on at the plant, going so far as to grant Shell the approval to continue work without the waiver most businesses had to obtain. As of December 2020, over 274 Shell workers had contracted the coronavirus.
Weak outlook for Shell’s investment
While the oil and gas industry had initially planned several ethane crackers for the region, all companies except for Shell have pulled out or put their plans on hold, likely due to the industry’s weak financial outlook.
A June 2020 report by the Institute for Energy Economics and Financial Analysis (IEEFA), stated that:
Royal Dutch Shell owes a more complete explanation to shareholders and the people of Pennsylvania of how it is managing risk. Shell remains optimistic regarding the prospects for its Pennsylvania Petrochemical Complex in Beaver County, Penn. The complex, which is expected to open in 2021 or 2022, is part of a larger planned buildout of plastics capacity in the Ohio River Valley and the U.S. IEEFA concludes that the current risk profile indicates the complex will open to market conditions that are more challenging than when the project was planned. The complex is likely to be less profitable than expected and face an extended period of financial distress.
Many of Pennsylvania’s elected officials have gone to great lengths to support this project. The Corbett administration enticed Shell to build this plastic factory in Pennsylvania by offering Shell a tax break for each barrel of fracked gas it buys from companies in the state and converts to plastic (valued at $66 million each year). The state declared the construction site a Keystone Opportunity Zone, giving Shell a 15-year exemption from state and local taxes. In exchange, Shell had to provide at least 2,500 temporary construction jobs and invest $1 billion in the state, giving the company an incredible amount of power to decide where resources are allocated in Pennsylvania.
Would the state have asked Shell for more than 2,500 construction jobs if it knew these jobs could be taken away when workers spoke out against life-threatening conditions? Will the politicians who have hailed oil and gas as the only job creator in the region care when workers are forced to hide their identity when communicating with public agencies?
States fail to regulate the oil and gas industry
The PA DEP appears to have played a key role in calling for this investigation, yet the agency itself was recently at the center of a different investigation led by Pennsylvania Attorney General Josh Shapiro. The resulting Investigating Grand Jury Report revealed systematic failure by the PA DEP and the state’s Department of Health to regulate the unconventional oil and gas industry. One of the failures was that the Department seldom referred environmental crimes to the Attorney General’s Office, which must occur before the Office has the authority to prosecute.
The Office of Attorney General is involved in this investigation, which the PA DEP is referring to as noncriminal.
The Grand Jury Report also cited concerns about “the revolving door” that shuffled PA DEP employees into higher-paying jobs in the oil and gas industry. The report cited examples of PA DEP employees skirting regulations to perform special favors for companies they wished to be hired by. The watchdog research organization Little Sis listed 47 fracking regulators in Pennsylvania that have moved back and forth between the energy industry, including Shell’s Government Relations Advisor, John Hines.
National attention on pipelines and climate
The Falcon Pipeline sits empty as people across the nation are amping up pressure on President Biden to pursue bold action in pursuit of environmental justice and a just transition to clean energy. Following Biden’s cancellation of the Keystone XL pipeline, Indigenous leaders are calling for him to shut down other projects including Enbridge Line 3 and the Dakota Access Pipeline.
Over a hundred groups representing millions of people have signed on to the Build Back Fossil Free campaign, imploring Biden to create new jobs through climate mobilization. Americans are also pushing Biden to be a Plastic Free President and take immediate action to address plastic pollution by suspending and denying permits for new projects like the Shell ethane cracker that convert fracked gas into plastic.
If brought online, the Falcon pipeline and Shell ethane cracker will lock in decades of more fracking, greenhouse gasses, dangerous pollution, and single-use plastic production.
Just as concerning, Shell will need to tighten its parasitic grip on the state’s economic and legislative landscape to keep this plant running. Current economic and political conditions are not favorable for the Shell ethane cracker: financial analysts report that its profits will be significantly less than originally presented. If the plant is brought online, Shell’s lobbyists and public relations firms will be using every tactic to create conditions that support Shell’s bottom line, not the well-being of residents in the Ohio River Valley. Politicians will be encouraged to pass more preemptive laws to block bans on plastic bags and straws to keep up demand for the ethane cracker’s product. Lobbyists will continue pushing for legislation that imposes harsh fines and felony charges on people who protest oil and gas infrastructure, while oil and gas companies continue to fund police foundations. Shell will ensure that Pennsylvania keeps extracting fossil fuels to feed its ethane cracker.
The Falcon pipeline is at odds with global demands to address plastic and climate crises. As these new documents reveal, it also poses immediate threats to residents along its route. While we’re eager for more information from state and federal agencies to understand the details of this investigation, it’s clear that there is no safe way forward with the Falcon Pipeline.
Royal Dutch Shell has been exerting control over people through the extraction of their natural resources ever since it began drilling for oil in Dutch and British colonies in the 19th Century. What will it take to end its reign?
References & Where to Learn More
- FracTracker Petrochemicals & Plastics articles and imagery: https://www.fractracker.org/categories/by-content/petrochemicals/
- FracTracker Falcon EIA webpage: https://www.fractracker.org/projects/falcon-public-eia/
- FracTracker June 16, 2020 article Falcon Pipeline Construction Releases over 250,000 Gallons of Drilling Fluid in Pennsylvania and Ohio
- Future Beyond Shell Campaign: https://futurebeyondshell.org/ (see this campaign’s social media toolkit here)
Topics in this Article
Health & Safety | Legislation & Politics | Petrochemicals & Plastics | Pipelines
Kern County’s Drafted EIR Will Increase the Burden for Frontline Communities
Overview
This article focuses on the city of Arvin as an example to show how some Frontline Communities in California are completely surrounded by an unrelenting barrage of carcinogenic and toxic air pollutants from oil and gas wells. Kern County’s proposed environmental impact report (EIR) would streamline the approval of an additional 67,000 new oil and gas wells in the County and thus further degrade air quality. We provide several recommendations for how local and state decision-makers can better protect public health from these serious threats.
Upstream greenhouse-gas and volatile organic compound (VOC) emissions from oil and gas extraction have been drastically under-reported throughout the United States, and California’s emissions regulations for oil and gas production wells are not comprehensive enough to protect Frontline Communities. The contribution of VOCs from the oil and gas extraction sector is responsible for California’s central valley and Kern County communities being exposed to the worst air quality in the country. As carcinogens, air toxics, and precursors to ozone, VOC’s present a myriad of health threats.
The contribution of VOCs from the well-sites in Kern, in addition to the cumulative burden of the Central Valley’s degraded air quality, puts Kern residents at considerable risk. Obvious loopholes in the California Air Resources Board’s oil and gas rule must be addressed immediately, and revised to prevent the cumulative impact of multiple exposure sources from causing additional documented negative health impacts. Additionally Kern County’s proposed environmental impact report (EIR) would streamline the approval of an additional 67,000 new oil and gas wells in the County and thus further degrade air quality. It is crucial that the EIR is instead revised to eliminate extraction near sensitive populations. (For more details on this proposal, see our more in depth environmental justice analysis of Kern County and our article on the proposed EIR.)
In support of establishing new public health rules that protect Frontline Communities, Earthwork’s Community Empowerment Project, in collaboration with the Central California Environmental Justice Network and FracTracker Alliance, has focused on documenting the uncontrolled emissions from extraction sites within and surrounding the small city of Arvin, California. Using infrared cameras with state of the art optical gas imaging (OGI) technology, the team documented major leaks at multiple well-sites. Footage from Arvin spans the years from 2016-2020. A collection of this footage has been compiled into the interactive story map that follows.
Toxic Emissions Filmed at Oil and Gas Wells in Arvin, CA
This StoryMap explores how current California regulations fail to stop emissions from tanks on oil and gas well-sites by looking at examples of emissions from well-sites in Arvin, California. Place your cursor over the image and scroll down to advance the StoryMap and explore a series of maps charting the fracking-for-plastic system. Click on the icon in the bottom left to view the legend.
View Full Sized Map | Updated 3/4/21
Data sources:
- CalGEM AllWells data, used for identification of oil and gas well sites in Arvin, CA
- California School Campus Database (CSCD), used for school footprint data
- U.S. EPA’s AirData mapping portal
The cases of uncontrolled emissions in the story map provides just an example of the inventory of uncontrolled emissions sources in Kern County, and California at large. Finding and filming emissions sources while using OGI cameras in California is not at all uncommon, otherwise there would not be seven prime examples just in the City of Arvin. Prior to 2018, emissions from these well-sites went completely unregulated. While the California oil and gas rule (COGR) was developed to address greenhouse gas emissions from small sources, certain aspects of the rule are not being enforced by the local air districts. Rather than requiring tanks to have closed evaporation systems the air districts allow operators to set pressure/vacuum hatches to open and emit toxic and carcinogenic vapors when pressure builds inside tanks. While this is a safety mechanism on tanks, in practice it allows tanks to be consistent sources of exposure that put neighboring communities at risk. Specifically, California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate Change, Article 4, § 95669, Leak Detection and Repair, Paragraph I states that “Hatches shall remain closed at all times except during sampling, adding process material, or attended maintenance operations.”
Degraded Air Quality
New research from Harvard, Berkeley and Stanford has shown that living near oil and gas drilling and extraction exposes Frontline Communities to emissions of VOC’s and ozone that put them at risk for a variety of health impacts. Researchers at Stanford have linked proximity and density of oil and gas wells to preterm birth for pregnant mothers (Gonzalez et al. 2020), even at large distances. Similar research from UC Berkeley showed mothers living near oil and gas drilling and extraction are also at risk of birthing infants with low birth weight (Tran et al. 2020). The study found pregnant people who lived within 0.62 miles (1 kilometer) of the highest producing wells were 40% more likely to have low birth weight babies and 20% more likely to have babies who were small for their gestational age compared to people living farther away from wells or near inactive wells only. Most recently, new research from Harvard University shows that even very low ambient levels of ozone, particulate matter (PM2.5), and nitrogen dioxide increased hospitalizations for cardiac and respiratory conditions (Wang et al. 2021). These are the primary and secondary pollutants emitted from oil and gas extraction sites and also result from burning fossil fuels. The magnitude of the impact on public health is also much larger than previously considered. Another article recently published by researchers at Harvard shows that fossil fuel air pollution is responsible for 18% of total deaths, worldwide (Vohra, et al. 2021).
While the COGR rule is a step in the right direction to reduce emissions, oil and gas’s legacy of degradation to ambient air quality has placed the Central Valley in the worst categories for these pollutants in the country. This puts Kern residents at considerable risk. The local health department continues to report improved conditions and increased numbers of healthy air days, but the truth is the mean, median and maximum values of ozone concentrations at US EPA monitoring locations in Kern County have remained relatively constant at harmful levels from 2015-2019. Expanding the data to 2020 shows a two sharp decreases in ambient levels of pollutants that correspond to decreases in reported production volumes for the county. The first decrease in 2016 corresponds to a drop in production following the institution of State Bill requirements for fracking permits. The decrease in 2020 is a result of the slowed production and burning of fossil fuels related to the Covid-19 Pandemic, as shown below in Figure 1.
Figure 1. Plot of annual Maximum 1 hour Ozone concentrations at all monitoring locations in western Kern County. Ozone concentrations are presented in parts per million. Annual trends in ambient concentrations of ozone. Note the decrease in concentrations in 2016 and in 2020. Both events correlate to decreases in production.
Using the U.S. EPA’s AirData mapping portal, air quality data for Kern County was exported, compiled and plotted to show trends over time. Above in Figure 1, annual ambient concentrations of ozone are shown. The trends of ambient concentrations follow similar trends in the spatial and temporal distribution of CalGEM reported production volumes. FracTracker Alliance is conducting more thorough analyses of these correlations, so stay tuned for future reports.
The locations of these monitoring locations are shown below in the map in Figure 2. Note that there are not any monitors in northwestern Kern, near large oil fields including North Belridge and Lost Hills. The communities near these fields, such as the City of Lost Hills are predominantly Latinx with elevated levels of linguistic isolation and poverty.
Figure 2. Map of Air Quality Monitors in Kern County.
Conclusion
Permitting new oil and gas wells in Kern County is certain to degrade the already harmful local and regional ambient air quality of the Central Valley. Kern County’s proposed EIR, as it stands will streamline an additional 67,000 sources of VOCs to the inventory of emissions already impacting communities. The health impacts from concentrations of ozone are well established, and the release of VOCs are major risk driver for communities living closest to oil and gas extraction operations as well as for regional public health. Together, these primary and secondary pollutants create a major risk driver for Kern County communities. Globally, these emissions are responsible for upwards of 8 million premature deaths annually. The burden on Frontline Communities in Kern County is likely much higher, and will only grow if the currently drafted EIR is passed. Additional air quality monitoring stations in northwestern Kern County should be installed immediately to help track air quality impacts.
To reduce this harm to Frontline Communities, California Senator Scott Weiner has submitted a new senate bill. Senate Bill 467 would stop the issuance of hydraulic fracturing permits and create a public health setback distance of 2,500 feet from homes, schools and other health care facilities for all new drilling permits. The bill would also create a program to provide new training and job opportunities for workers who would be negatively impacted by the bill. Senate Bill 467 provides the first step for a green transition away from the health impacts resulting from fossil fuel industries.
The Take Away
Built on sound data and ample research, FracTracker recommends the following measures be taken to protect the health of California’s overburdened Frontline Communities: Kern County should revise its environmental impact report to address the onslaught of harmful oil and gas emissions (EIR), California Air Resources Board’s oil and gas rule should close its loophole allowing emissions from the pressure/vacuum hatch on the tank to be exempt from regulation, and legislators should educate themselves on the importance of 2,500 foot setbacks requirements for oil and gas wells.
References & Where to Learn More
FracTracker’s public comments regarding recommendations to modify the Kern County Draft Environmental Impact Report (EIR): https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/03/Kern.EIR_.comments_FracTrackerAlliance_3.8.21_compressed.pdf
FracTracker California articles, maps, and imagery: https://www.fractracker.org/map/us/california/
Earthwork’s Community Empowerment Project: https://www.youtube.com/playlist?list=PL9BS7nDf-8tqlaUT8pc0Yr0Tpfl0UFDMK
Newsom Well Watch, a collaboration between FracTracker and Consumer Watchdog: https://newsomwellwatch.com/
Topics in this Article
Infrastructure | Health & Safety | Legislation & Politics | Social
California Oil & Gas Setbacks Recommendations Memo
Kyle Ferrar, Western Program Coordinator for FracTracker Alliance, contributed to the December 2020 memo, “Recommendations to CalGEM for Assessing the Economic Value of Social Benefits from a 2,500’ Buffer Zone Between Oil & Gas Extraction Activities and Nearby Communities.”
Below is the introduction, and you can find the full memo here.
Introduction
The purpose of this memo is to recommend guidelines to CalGEM for evaluating the economic value of the social benefits and costs to people and the environment in requiring a 2,500 foot setback for oil and gas drilling (OGD) activities. The 2,500’ setback distance should be considered a minimum required setback. The extensive technical literature, which we reference below, analyzes health benefits to populations when they live much farther away than 2,500’, such as 1km to 5km, but 2,500’ is a minimal setback in much of the literature. Economic analyses of the benefits and costs of setbacks should follow the technical literature and consider setbacks beyond 2,500’ also.
The social benefits and costs derive primarily from reducing the negative impacts of OGD pollution of soil, water, and air on the well-being of nearby communities. The impacts include a long list of health conditions that are known to result from hazardous exposures in the vulnerable populations living nearby. The benefits and costs to the OGD industry of implementing a setback are more limited under the assumption that the proposed setback will not impact total production of oil and gas.
The comment letter submitted by Voices in Solidarity against Oil in Neighborhoods (VISIÓN) on November 30, 2020 lays out an inclusive approach to assessing the health and safety consequences to the communities living near oil and gas extraction activities. This memo addresses how CalGEM might analyze the economic value of the net social benefits from reducing the pollution suffered by nearby communities. In doing so, this memo provides detailed recommendations on one part of the broader holistic evaluation that CalGEM must use in deciding the setback rule.
This memo consists of two parts. The first part documents factors that CalGEM should take into account when evaluating the economic benefits and costs of the forthcoming proposed rule. These include factors like the adverse health impacts of pollution from OGD, the hazards causing them and their sources, and the way they manifest into social and economic costs. It also describes populations that are particularly vulnerable to pollution and its effects as well as geographic factors that impact outcomes.
The second part of this memo documents the direct and indirect economic benefits of the proposed rule. Here, the memo discusses the methods and data that should be leveraged to analyze economic benefits of reducing exposure to OGD pollution through setbacks. This includes the health benefits, impacts on worker productivity, opportunity costs of OGD activity within the proposed setback, and the fact that impacted communities are paying the external costs of OGD.
Please find the full memo here.
Industrial Impacts in Michigan: A Photo Essay & Story Map
Southwest Detroit and neighboring South Rockwood in Monroe County could not be more different demographically, but one thing they have in common is a consistent battle with the extractives industry.
With environmental advocates Theresa Landrum and Doug Wood, FracTracker created a Story Map to document what this infrastructural buildout in Southeastern Michigan looks like from the air, how it has displaced entire neighborhoods, and how it has forever changed their quality of life, in the name of short-term profiteering.
“Marathon is a prime example of corporate polluters continuing
to choose profit over safeguards for our public health.”
– Congresswoman Rashida Tlaib
Each year, FracTracker Alliance gives out its Community Sentinel Award for Environmental Stewardship. We had an amazing group of candidates this year, and the four winners are extremely brave, persistent, insightful, and collaborative activists representing diverse communities all over the country.
I have had the good fortune to interact with two of the winners – Theresa Landrum and Brenda Jo McManama – quite frequently over my time at FracTracker. This year’s Sentinel Award winners and all its previous recipients are passionate and persistent fighters for environmental justice in their own backyards and around the United States.
It is around this time of year that all the negativity involved in the fight against fossil fuel industries dissolves away for me as I find myself inspired and humbled by the Sentinel winners. Theresa and Brenda Jo constantly inspire me and FracTracker to strive to do more, do better, and remain cleareyed as to whom we serve. All the Community Sentinel nominees are exemplars of what it is to walk authentically and humbly through life.
However, I am going to spend the next couple paragraphs speaking specifically about Ms. Landrum, because it is she that I have come to know and work quite well with since COVID-19 was something we thought would be gone by June.
I had heard so many amazing things about Ms. Landrum from a common comrade, Mr. Doug Wood, whom FracTracker has written about with respect to the silica sand mining he is fighting and dubious pro-mining legislation being pushed in Michigan’s Statehouse, but I had never met her in person. That changed on a scorching hot day this past June, when Doug, Theresa, and I met (socially distanced) in the shadow of Marathon Petroleum’s refinery at Detroit’s Kemeny Recreation Center, just a couple stones throws across I-75 (see images below).
Incidentally, this is the same refinery that Congresswoman Rashida Tlaib (D, MI-13) has been railing against for years, including in a statement she issued on yet another incident at
the refinery:
“Marathon is a prime example of corporate polluters continuing to choose profit over safeguards for our public health. It is time to say enough is enough of Marathon’s constant disregard of the health and safety of residents who live, work, and visit the surrounding communities. Marathon has perpetrated numerous incidents detrimental to our communities and must be held accountable – they clearly cannot be trusted to protect our health. I look forward to discussing the need to hold Marathon and other entities who poison our community accountable and solutions to make our communities breathe and live free at the upcoming congressional field hearing I am hosting with other members of Congress, experts, and grassroots activists here in Detroit.”
Scroll horizontally to see additional images:
- Southeastern Michigan Environmental Activists Doug Wood and Theresa Landrum at Detroit’s 48217 Kimeny Park with Marathon’s Refinery in the Background, June, 2020
- Anti-Frac Sand mine signage created by Monroe County, Michigan activist Doug Wood, June, 2020
- No Dumping signage erected by Marathon Oil in Detroit’s Oakwood Neighborhood adjacent to the company’s oil refinery
- Concerned Citizen and Sylvania Minerals mine neighbor Doug Wood
It did not take more than 30 seconds for me to realize that Theresa was an authentic and persistent fighter for her community, and that she belongs on the Mt. Rushmore of EJ advocates – as does Doug Wood and all of the Community Sentinel nominees past, present, and future.
After meeting at the recreation center, I followed Theresa around with my drone, capturing footage and images of the worst actors in the 48217 zip code of Southwest Detroit, as well as of River Rouge and Ecorse. This turned out to be the first of three trips to meet with Theresa throughout the summer and fall of 2020.
During each trip and across dozens of phone conversations, Theresa explained to me what industry has done to Southwest Detroit, how she has gone about combatting it, and the way that Lansing treats Wayne County.
It struck me that much of her experience overlaps with the stories I have heard in disparate demographics, from soybean farmers in LaSalle County, Illinois, to dairy farmers in Western Wisconsin, all the way to coalminers in Central Appalachia.
Their stories illustrate the near universal tale of how industry needs and welfare demands take precedence over the rights of citizens. It is the story of globalization, shareholder returns, and political/economic elites ignoring, mocking, or being deaf and blind to the needs of their constituents and the crimes being committed in the name of progress and Gross Domestic Product (GDP).
One thing Theresa and I have spent quite a bit of time discussing is the overlap in environmental justice across demographics, and how superficial differences have been weaponized to divide us, leaving only corporations and their political handmaids to benefit. Industry beneficiaries and politicians have colluded to declare in the words of Thomas Frank’s latest book “The People, No!” Yet, it is people like Theresa, Doug, Brenda Jo, and all the other environmental activists we celebrate who are and will be instrumental in bridging those divides, and guiding the citizenry to pivot, to identify and defeat the real Leviathan – the Hydrocarbon Industrial Complex in all its manifestations and with all its tentacles spread out across this country.
The best way I know how to return the favor to folks like Theresa is to continue to do what FracTracker does best, and what I hope I am doing well, which is documenting the infrastructure and landscapes that are or have been in the crosshairs of industry, whether it be steel, coal, oil, or in the case of our name – fracked natural gas.
I have been working with Theresa and Doug on a Story Map that illustrates the scale and scope of industrial impacts in southeastern Michigan, from US Steel’s Zug Island to Sylvanian Mineral’s frac sand mine in South Rockwood. As I mentioned above, we have outlined the plight of Doug and Dawn Wood in their fight against their neighbor Sylvanian Minerals. However, with respect to Southwest Detroit, it is critical that we give a bit of background to the region’s cultural significance. For that, I am going to refer to Ms. Landrum’s own words, shared below:
A Historical Perspective of Wayne County Michigan’s Tri-Cities Region
By Theresa Landrum
During the first and second waves of the early 20th Century Great Migration, African Americans came from the South to Michigan’s communities of Ecorse (48229), River Rouge (48218), and Southwest Detroit (48217), AKA the “Triple Cities,” seeking factory jobs in the surrounding industries; U.S. Steel (formerly Great Lakes Steel), Ford Motor Company, Zug Island, Dana Corporation, and BASF Chemicals. During this time, many white men enlisted in the armed forces, and employers needed workers – so companies recruited southern African Americans to fill the jobs.
This region is one of the first African American settlements in Michigan after World War II, where Black people could actually buy homes, which helped establish metro Detroit’s Black middle class.
By the 1930s and 40s it was a self-sustaining area rich with opportunities, a mecca for Black-owned businesses, like gas stations, stores, jazz clubs, restaurants, hotels, laundromats, dry cleaners, and much more. It was also the home of Black professionals: doctors, pharmacists, policemen, florists, bakers, dentists, teachers, lawyers, and realtors thrived here, and was the site of one of Michigan’s first Black hospitals, Sidney A. Sumby Memorial Hospital, built by Black doctors.
The thread that ties these three communities/zip codes together is their formation of (what was then) Ecorse Township. Their division came after the City of Detroit expressed interest in annexing the River Rouge area. River Rouge incorporated into a village to ward this off, but Detroit was able to annex the Southwest 48217 area in 1922, thus segmenting Ecorse Township into three parts.
Fast forward to the 1950s, when Detroit’s landscape changed forever with the government’s declaration of “Eminent Domain” that claimed many African American homes for construction of the I-75 Expressway, which runs right through the center of Southwest Detroit’s (SWD) 48217 community. As I-75 was constructed, Ohio Oil (which officially became Marathon Oil in 1962) also increased its footprint in the area by acquiring nearly 100 acres and destroying a wetland habitat to expand its storage tank farm, which to date has over 100 storage tanks.
Marathon expanded again in 2007 with the announcement of the $2.2 billion Detroit Heavy Upgrade Project (DHOUP), where they would transition to refining dirty tar-sands from Alberta, Canada. This increased production to 120,000 barrels of crude per day, and thus increased the expulsion of harmful, pollutive emissions into the nearby neighborhoods. The project was completed in 2012, which also resulted in Marathon buying over 400 homes in the SWD 48217 (Oakwood Heights) area, further encroaching into residential communities.
Theresa was a recipient of the 2020 Community Sentinel Award for Environmental Stewardship, presented by FracTracker Alliance and Halt the Harm Network. Read more about her story here.
The Thoughts of Dawn & Doug Wood About Living Next to a Frac Sand Mine
I asked Dawn and Doug Wood to send me their thoughts on what it is like living next to Sylvanian Minerals and US Silica’s frac sand mine in South Rockwood, Michigan. I extracted (and clarified where necessary) the excerpts below that clearly illustrate their frustrations with their community, local, and federally elected officials, as well as the mine operators:
“[The] list of insurmountable mini-nightmares of living next to a frac sand mine [is endless at this point]. [Ten] years ago, they wanted to annex this quarry. [Our] village government has exercised no control over this corporation. [T]he village and the quarry refuse to do any air monitoring, [and] the residents who voted [in favor of] this quarry continue to be silent against any controls over this quarry. Residents seem to fear retaliation if they speak out against [the] village/quarry, [and to this day we] can’t quite explain the community’s lack of outrage … [We] have been shaking our head for years about this … It’s like the pandemic, it is invisible, yet it is killing people … [and] we are living in a polluted community, so our lungs are already taxed [which amplified the impacts of COVID]. [We] have been petitioning for air monitors and dust controls for four years, [and to add insult to injury] after ten years of this bull- – – -, the industry proposes Senate Bill 431 to totally strip communities of their controls, allowing mines to expand whenever they want, and new quarries to just be approved wherever they want [which has prompted the industry to correctly assume] they are entitled. PURE MICHIGAN is the state slogan. We think that’s PURE BULL- – – -!!”
A Southwestern Detroit and Neighboring Monroe County Industrial Impacts Story Map
Southwest Detroit and neighboring South Rockwood in Monroe County could not be more different demographically, but one thing they have in common is a consistent battle with the extractives industry.
We built this Story Map to identify the industrial bad actors and census-level indicators such as mean annual income, and most importantly, to present a growing library of georeferenced drone footage and imagery we have collected over the years.
There have been dozens of other industrial projects foisted on the Triple Cities area of Detroit during this period and to the present day. The goal of this Story Map was to document with drone photography what this infrastructural buildout looks like from the air, how it has displaced and been incorporated directly into neighborhoods – and in the case of Sylvanian Mineral’s South Rockwood facility operating adjacent to good people like the Woods – how it has forever changed their quality of life, in the name of short-term profiteering.
We will continue to “infill” and expand this Story Map in the coming months and years, especially throughout greater Wayne County and the surrounding counties, as southeastern Michigan continues to act as a chokepoint for all manner of industrial and fossil fuel operators and activities. Furthermore, this collaborative effort with Ms. Landrum demands her community’s involvement and acceptance. We also strive to make this project a valuable resource for Michigan-based environmental NGOs and the state’s excellent journalists, like Steve Neavling at Detroit MetroTimes, and Evan Kutz at Great Lakes Beacon.
We plan to update this Map with more culturally significant imagery from the Detroit Public Library and The Wayne State Walter Reuther Library to include media focusing on labor strife, police violence, and the rich tradition and history of the region’s artistic heritage. Additionally, we will expand the depth and breadth of our drone imagery library, as well as continue our nascent effort to collect the stories of regional elders who speak to Southwest Detroit as one of the fulcrums of African American culture, and who explore how industrial colonialism has decimated much the area’s sense of place and community pride.
However, I am confident and hopeful that with progressive voices like Congresswoman Tlaib, committed journalists like those previously mentioned, and activists like Ms. Landrum passing the torch to a younger generation of activists, Southwest Detroit’s condition will take a turn for the better.
Footnote on Michigan’s Senate Bill 431
We wrote about the impacts that SB 431 would have on Michigan’s community and ecosystems last summer, when we were outlining some of the industry’s efforts in Statehouses across the country to weaken environmental regulations – and in some cases, the democratic process itself. SB 431, in particular, would have made the process of operating a sand and gravel mine in Michigan much easier, by way of removing local participation. As the Metamora Land Preservation Alliance (MLPA) wrote in opposition to the bill, this legislation would have allowed for “uncontrolled gravel mining” throughout the state. However, in a bit of good news, a large coalition of Michigan environmental organizations was able to defeat this bill with the MLPA, writing the following on its Facebook page:
“KILLER GRAVEL BILLS DEFEATED!!!
SENATE BILLS 431/849 DEFEATED!
NO SENATE VOTE THIS YEAR – BILLS ARE DEAD!
After almost 18 months of battling in Lansing – Senate Bills 431 & 849 (sponsored by Senator Hollier (D) Detroit) – have been defeated. They will not be coming up for a vote this calendar year, and by Senate rules they will therefore expire. Thus ending, for this year, the dire threat of uncontrolled gravel mining, endangerment of our groundwater, and loss of control of how our communities grow and develop. Make no mistake – this was a serious threat to Michigan’s citizens and communities – and it was a no-holds-barred fight in Lansing.”
Wins for communities over corporations like this are rare, indeed, and should be celebrated. Congratulations to the Woods, MLPA, and all the Michigan communities and organizations that pushed back against this bill. You are true Community Sentinels!
Industrial Impacts in Michigan:
A Photo Essay & Story Map
By Ted Auch, PhD, Great Lakes Program Coordinator
and
Theresa Landrum, of Detroit, Michigan, 48217. The Original United Citizens of Southwest Detroit; 48217 Community and Environmental Health Organization; Michigan Advisory Council on Environmental Justice; Sierra Club Detroit Chapter, MEJC Clean Air Council; Michigan PFAS action response team
People and Production: Reducing Risk in California Extraction
Executive Summary
New research shows that low-income communities and communities of color that are most impacted by oil and gas extraction (Frontline Communities) in California are at an elevated risk for preterm birth, low birth weight, and other negative birth outcomes. This is in addition to the elevated risks of cancer; risks for respiratory, cardiovascular, and pulmonary disorders; and risks for eyes, ears, nose, throat, and skin irritation that Frontline Communities face, among others. Public health interventions including setback requirements for oil and gas drilling are necessary to address the environmental health endemics documented in Frontline Communities.
This report focuses on the two immediate stakeholders impacted by oil and gas well drilling setbacks: Frontline Communities and oil and gas operators. First, using U.S. Census data this report helps to define the Frontline Communities most impacted by oil and gas extraction. Then, using GIS techniques and California state data, this report estimates the potential impact of a setback on California’s oil production. Results and conclusions of these analyses are outlined below.
- Previous statewide and regional analyses on proximity of oil and gas extraction to various demographics, including analyses included in Kern County’s 2020 draft EIR, have inadequately investigated disparate impacts, and have published erroneous results.
- This analysis shows that approximately 2.17 million Californians live within 2,500’ of an operational oil and gas well, and about 7.37 million Californians live within 1 mile.
- California’s Frontline Communities living closest to oil and gas extraction sites with high densities of wells are predominantly low income households with non-white and Latinx demographics.
- The majority of oil and gas wells are located in environmental justice communities most impacted by contaminated groundwater and air quality degradation resulting from oil and gas extraction, with high risks of low-birth weight pregnancy outcomes.
- Adequate Setbacks for permitting new oil and gas wells will reduce health risks for Frontline Communities.
- Setbacks for permitting new oil and gas wells will not decrease existing California oil and gas production.
- Phasing out wells within setback distances will further decrease health risks for Frontline Communities.
- Phasing out wells by disallowing rework permits within a 2,500’ setback distance will have a minimal impact on overall statewide oil production, estimated at an annual maximum loss of 1% by volume.
- Setbacks greater than 2,500’ in combination with other public health interventions are necessary to reduce risk for Frontline Communities.
- Based on the peer reviewed literature, a setback of at least one mile is recommended.
Table of Contents
Demographics
CalEnviroScreen
Spatial Bias
Well Density
Shafter
Lost Hills, Arvin, and Taft
Bakersfield
Ventura
Los Angeles
Los Angeles
Kern County
Introduction
The energy focused on instituting policies to protect the health of Frontline Communities in California from the negative impacts of oil and gas extraction is at an all-time high. In August 2020, Assembly Bill 345 was heard in the State Senate’s Natural Resources Committee, but was blocked from reaching the Senate floor for a vote. The bill would have required the Geologic Energy Management Division in the Department of Conservation (CalGEM) to establish a minimum setback distance between oil and gas production and related activities and sensitive receptors like homes, schools, and hospitals. While this strong effort to establish health and safety setbacks through the state legislature may have failed, the movement has paved the way for local actions. Additionally, California is in the midst of a statewide public health rule-making process to address the health impacts of oil and gas extraction currently experienced by Frontline Communities.
In related advocacy, Frontline Community groups in California recommended a minimum 2500’ setback based on scientific studies, including a 2015 report by the California Council on Science and Technology which identified “significant” health risks at a distance of one-half mile from drill sites. A recent grand jury report from Pennsylvania recommended 5,000’ setbacks, with 2,500’ as a minimum requirement to address the most impacted communities. Additionally, the state of Colorado has recently adopted 2,000’ setbacks for homes and schools, while the existing 2,000’ setback has had minimal impacts on oil and gas production.
In September 2020, Governor Newsom declared the deadline for the first draft of the pre-regulatory rule-making report will be the first of January 2021. FracTracker Alliance has therefore completed an updated assessment of the Frontline Communities most impacted by oil and has projected the potential impact on oil and gas extraction operations. An interactive map of oil and gas activity and Frontline Communities is shown below in Figure 1. The map identifies the operational (active, idle, and new) oil and gas wells located within 2,500’ and 1 mile buffer zones from sensitive receptors, defined as homes, schools, licensed daycares and healthcare facilities.
The impacts of oil and gas drilling do not stop at 2,500’, as regional groundwater contamination and air quality degradation of ozone creation and PM2.5 concentrations are widespread hazards of oil and gas extraction. Phasing out wells within 2,500’ of homes will reduce the negative health effects for the Frontline Communities bearing the brunt of the risks associated with living near oil and gas wells, as well as reduce regional environmental hazards. These risks include over 24 categories of health impacts and symptoms associated with 14 bodily systems, including eyes, ears, nose, and throat; mental health; reproduction and pregnancy; endocrine; respiratory; cardiovascular and pulmonary; blood and immune system; kidneys and urinary system; general health; sexual health; and physical health among others. The most regularly documented health outcomes include mortality, asthma and respiratory outcomes, cancer risk including hematological (blood) cancer, preterm birth, low birth weight and other negative birth outcomes.
The interactive map below in Figure 1 shows the operational oil and gas wells located within 2,500’ of sensitive receptors, including homes, schools, healthcare facilities, prisons, and permitted daycares. Overall in the state of California, 16,724 operational (8,618 active, 7,786 idle, and 320 new) wells are located within the 2,500’ setback. Of the total ~105,000 operational (62,000 active, 37,400 idle, and 6,000 new), about 16% are within the setback. These wells accounted for 12.8% of the total oil/condensate produced in California in 2019. Table 1 below shows the counties where these wells are located, by well permit status. It bears noting that these figures on well location and production represent only a snapshot of current industry activity. As discussed below, current setback proposals would provide a phase out period for existing wells that would greatly reduce any immediate impact on production. Further, directional and even horizontal drilling is common in California, meaning operators can relocate their surface drilling equipment to safer distances and still access oil and gas reserves to maintain production.
Table 1. Status of wells within the 2,500’ setback zone, by county. The table shows the counts of wells located within the 2,500’ setback from homes and other sensitive receptors, broken out by the status of the wells.
| Well Count by Status | |||
| County | Active | New | Idle |
| Kern | 3,501 | 234 | 2,171 |
| Los Angeles | 2,580 | 29 | 3,006 |
| Orange | 914 | 13 | 816 |
| Ventura | 534 | 7 | 600 |
| Santa Barbara | 198 | 17 | 241 |
| Los Angeles Offshore | 168 | 2 | 51 |
| Glenn | 133 | 76 | |
| San Joaquin | 97 | 71 | |
| Monterey | 88 | 9 | 95 |
| Fresno | 86 | 6 | 137 |
| Sutter | 73 | 71 | |
| Tulare | 65 | 1 | 30 |
| Colusa | 47 | 80 | |
| Tehama | 38 | 34 | |
| Solano | 30 | 0 | 65 |
| Sacramento | 22 | 1 | 38 |
| San Bernardino | 14 | 29 | |
| Humboldt | 12 | 11 | |
| Alameda | 7 | 3 | |
| Contra Costa | 5 | 1 | 16 |
| San Benito | 3 | 4 | |
| San Luis Obispo | 2 | 14 | |
| Yolo | 1 | 13 | |
| Grand Total | 8,618 | 320 | 7,786 |
Figure 1. Map of California operational oil and gas wells with 2,500’ and one mile setback distances. One mile setbacks are included as a minimum recommendation of this report based on peer reviewed literature. This report recommends the state of California consider one mile as a minimum setback distance to protect Frontline Communities. As you zoom into the map additional, more detailed layers will appear.
Methods (Quick Overview)
In this article we conducted spatial analyses using both the demographics of Frontline Communities and the amount of oil produced from wells near Frontline Communities. This assessment used CalGEM data (updated 10/1/20) to map the locations of operational oil and gas wells and permits, as shown above in Figure 1. The analyses of oil production data utilized CalGEM’s annual production data reporting barrels of oil/condensate. GIS analyses were completed using ESRI ArcGIs Pro Ver. 2.6.1 with data projected in NAD83 California Teale Albers.
Wells within 2,500’ and 1 mile of sensitive receptors were determined using GIS techniques. This report defines sensitive receptors as residences, schools, licensed child daycare centers, healthcare facilities. Sensitive receptor datasets were downloaded from California Health and Human Services, and the California Department of Education.
We used block group level “census designated areas” from American Community Survey (2013-2018) demographics to estimate counts of Californians living near oil and gas extraction activity. Census block groups were clipped using the buffered datasets of operational oil and gas wells. A uniform population distribution within the census blocks was assumed in order to determine the population counts of block groups within 2,500’ of an operational oil and gas well, 2,500’ to 1 mile from an operational well, and beyond 1 mile from an operational well. Census demographics and total population counts were scaled using the proportion of the clipped block groups within the setback area (Areal percentage = Area of block group within [2,500’; 2,500’-1 mile; Beyond 1 mile] of an operational well / Total area of block group).
This conservative approach provided a general overview of the count and demographics of Californians living near extraction operations, but does little to shed light on most impacted Frontline Communities; specifically urban areas with dense populations near large oil fields. More granular analyses at the local level were necessary to address the spatial bias resulting from non-uniform census block group dimensions and population density distributions, as well as the distribution of operational oil and gas wells within the census block groups. Consequently, we conducted further analysis utilizing customized sample areas for each oil field, which were selected manually using remote sensing data. Full census blocks were used to summarize the actual areas and the urban populations constituting the majority of Frontline Communities.
In the localized, static maps that follow, the census blocks included in the population summaries are shown in pink, while the surrounding census blocks are shown in blue. As seen in Table 2, census data for this initial environmental justice assessment was limited to “Race” (Census Table XO2), “Hispanic or Latino Origin” (Census Table XO3) and several other indicators including “Annual Median Income of Households” (Census Table X19) and “Poverty” (Census Table X17).
Results and Discussion
California Statewide Analysis
Demographics
As a baseline, it is important to provide statewide estimations to track the total number of Californians living near oil and gas extraction operations. This analysis showed that about 2.17 million Californians live within 2,500’ of an operational oil and gas well, and about 7.37 million Californians live within 1 mile. The demographics of these communities at and between these distances is shown below in Table 2, alongside demographic estimates of the California population living beyond 1 mile from an oil and gas well. Census block groups closer to oil and gas wells have higher proportions of Non-white (calculated by subtracting “White Only” from “Total Population”) and Latinx (“Hispanic or Latino Origin”) populations, as well as higher proportions of low-income households, based on both median annual income and poverty thresholds. The analysis show that communities living closer to oil and gas wells have higher percentages of non-white and Latinx populations when compared to the population living beyond 1 mile from an operational oil and gas wells. Communities closer to oil and gas wells are also more likely to be closer to the poverty threshold with lower median annual household incomes.
Table 2. The table shows statewide demographics at multiple distances from operational oil and gas wells. Included are estimates of the non-white and Latinx proportions of the populations within set distances from operational oil and gas wells. The percentage of populations within several poverty thresholds were also summarized, along with median annual household income and age.
| Distance from an operational oil and gas well | |||
| Indicators of Disparity | Within 2,500′ | 2,500′ – 1 Mile | Beyond 1 Mile (Statewide) |
| Demographics: Non-white | 44.44% | 43.56% | 39.16% |
| Demographics: Latinx | 43.25% | 44.97% | 37.79% |
| Poverty: Under Poverty Threshold | 15.01% | 14.97% | 14.12% |
| Poverty: Under 1.5X Poverty Threshold | 24.31% | 24.85% | 23.25% |
| Poverty: Under 2X Poverty Threshold | 33.59% | 34.25% | 32.17% |
| Median Annual Household Income < $40k | 30.09% | 30.73% | 28.72% |
| Median Annual Household Income <$75k | 53.53% | 54.36% | 51.76% |
| Age: 0-5 years | 6.08% | 6.12% | 6.37% |
| Age: <18 years | 21.54% | 22.12% | 23.39% |
| Age: 65+ | 13.17% | 13.11% | 13.68% |
| Demographics: White only | 55.56% | 56.44% | 60.84% |
CalEnviroScreen
CalGEM operational wells data was also overlaid on CalEnviroScreen 3.0 (CES) indicators of environmental health. CES is provided by the Office of Environmental Health Hazard Assessment (OEHHA), on behalf of the California Environmental Protection Agency (CalEPA).
CalEnviroScreen data, like U.S. Census data, is also aggregated at the census block group level. While this data can also suffer from the same spatial bias as the statewide analysis above, CES is still very useful to visualize and map the regional pollution burden to assess disparate impacts. The results of the analysis are shown below in Table 3. Counts of operational oil and gas wells for ranges of CES percentile scores. Higher percentiles represent increased environmental degradation or negative health impacts as specified. Of note, the majority of operational oil and gas wells are located in census tracts with the worst scores for air quality degradation and high incidence of low birth weight.
The large number of wells located in the 60-80th percentile rather than the worst (80-100th percentile) is a result of spatial bias, and the many factors that are aggregated to generate the CES Total Scores. These factors include relative affluence and other indicators of socio-economic status. The majority of the worst (80th-100 percentile for Total CES Score) census block groups are located in low-income urban census block groups, many in Northern California cities that do not host urban drilling operations.
This spatial bias results from edge effects of census block groups, where communities living near oil and gas extraction operations may not live in the same census block groups as the oil and gas wells, and are therefore not counted. The authors would recommend future analyses be designed that use CES data to assess disparate impacts in the census block groups most impacted by oil and gas extraction. Neighboring census block groups that do not physically contain operational wells still suffer the consequences of proximity.
For the asthma rankings, the majority of wells are located in the best CES 3.0 percentile (0-20th percentile) for Asthma. While there is much urban drilling in Los Angeles, the spatial bias in this type of analysis gives more weight to the majority of oil and gas wells that are located in rural areas, which historically have much lower asthma rates. This is a result of the very high incidence of asthma in cities without urban drilling such as the Bay Area and Sacramento (80-100th percentile).
Table 3. Counts of operational oil and gas wells in select CalEnviroScreen 3.0 indicators census tracts.
| Operational Well Counts by CES3.0 Percentile | |||||
| 0-20%ile | 20-40%ile | 40-60%ile | 60-80%ile | 80-100%ile | |
| PM2.5 Air Quality Degradation | 5,708 | 4,237 | 16,614 | 7,089 | 69,987 |
| Ozone Air Quality Degradation | 2,238 | 5,435 | 6,107 | 9,898 | 79,957 |
| Contaminated Drinking Water | 1,019 | 1,675 | 53,452 | 6,214 | 41,206 |
| High Incidence of Low Birth Weight | 10,186 | 13,368 | 14,995 | 3,236 | 58,036 |
| High Incidence of Asthma | 40,247 | 19,827 | 18,902 | 4,867 | 19,792 |
| Total CES 3.0 | 1,583 | 5,756 | 15,671 | 65,356 | 12,985 |
Spatial Bias
Using census data to assess the demographics of those communities most affected by oil and gas drilling can produce misleading results both because of how census designated areas (census tracts and block groups) are designed and because of the uneven distribution of residents within tracts. For example, the majority of Californians who live closest to high concentrations of oil and gas extraction, such as the Kern River oil field, do so in residentially zoned cities and urban settings. In most Frontline Communities the urban census designated areas do not actually contain many wellsites. Instead urban census designated areas are located next to the “estate” and “industrial” (including petroleum extraction) zoned census designated areas that contain the well-sites.
Estate and industrially zoned census designated areas contain the majority of well-sites in Kern County. They are much larger than residentially zoned areas with very low population densities and higher indicators of socioeconomic status. Population centers within the estate zoned areas are often located on the opposite end and farther from well sites than the lower income communities and communities of color living in the neighboring, residentially-zoned census designated areas (e.g., Lost Hills and Shafter). In these cases the statewide demographic summaries above misrepresent the Frontline Communities who are truly closest to extraction operations. Localized environmental justice demographics assessments can also be manipulated in this way.
For instance, The 2020 Kern County draft EIR (chapter 7 PDF pp. 1292-1305) used well counts aggregated by census tracts to conclude that wells in Kern County were not located in disparately impacted communities. Among other requirements for scientific integrity, the draft Kern EIR fails to take into account how the shape, size, and orientation of census designated areas affect the results of an environmental justice assessment. In addition, the EIR uses low-resolution data summarized at the census tract level. Census tracts are much too large to be used to investigate localized health impacts or disparities. Using these blatantly inadequate methods, the draft EIR even claimed Kern County’s oil and gas wells are predominantly located in higher income, white communities, which is outright wrong. For more specific criticisms of the Draft EIR read the FracTracker analysis of the 2020 Kern County EIR.
Results from these types of analyses can be very misleading. Using generalized methods of attributing wells to specific census designated areas does little to identify the communities most impacted by the localized environmental degradation resulting from oil and gas extraction operations, particularly when large census areas such as census tracts are used.
This report therefore takes a different approach, focusing directly on California’s most heavily drilled communities. To understand who and which communities are most harmed by the large-scale industrial oil and gas extraction operations in California, spatial analyses must be refined to focus individually on the communities closest to the highest density extraction operations. For the analyses below, census block groups within 2,500’ of ten different Frontline Communities, all located near some of California’s largest oil and gas fields, were manually identified. The selected block groups’ major population centers were all located within the 2,500’ buffers. Unlike the statewide analysis above, the localized analyses below do not assume homogenous population distributions. Using these methods, FracTracker has identified and demographically described some of the most vulnerable California communities most at risk to the impacts of oil and gas extraction. In the maps below, the “case” census block groups used to generate descriptive demographic summaries of at risk communities bordering extraction operations are outlined in pink, while surrounding census block groups are outlined in light blue.
Well Density
The analyses above are important to understand some of the public health risks of living near oil and gas drilling in California. Yet the methods above used statewide aggregation of well counts and static buffers that do not not show the spectrum of risk resulting from well density. Numerous Frontline Communities in California are within 1 mile or even 2,500’ of literally thousands of oil and gas wells. Conversely, there are many census areas in California that have been included within the spatial analysis of the full state, as described above, located near a single low producing well. Therefore the above methods conservatively summarize demographics and dilute the signal of disparate impacts for low income communities of color. Those methods are not able to differentiate between such scenarios as living near one low-producing well in the Beverly Hills golf course versus living in the middle of the Wilmington Oil Field.
As with any toxin, the dosage determines the intensity of the poison. In environmental sciences, increasing exposure to toxins by increasing the number of sources of a toxin can increase the dosage and therefore the severity of the health impact. The impact of well density has been documented in numerous epidemiological studies as a significant indicator of negative health outcomes, including recently published reports from Stanford University and The University of California – Berkeley linking adverse birth outcomes with living near oil and gas wells in California (Tran et. al 2020, Gonzalez et. al 2020). Therefore the rest of this report focuses on the Frontline Communities living near large oil extraction operations–i.e., oil fields with high densities of operational oil and gas wells.
Kern County
Toggle between the sections below by clicking in the upper left corner of the title bar.
Shafter
The City of Shafter, California, is located near more than 100 operational wells in the North Shafter oil field, as shown below in the map in Figure 2. Technically, the wells are located within a donut-shaped census block group (outlined in blue) that surrounds the limits of the urban census block groups (outlined in pink). Shafter’s population of nearly 20,000 is over 86% Latinx, but the surrounding “donut” with just 2,000 people is about 70% Latinx, much wealthier, and with very low population density. The other neighboring rural census areas housing the rest of the Shafter oil field wells follow this same trend.
An uninformed analysis, such as the Kern County EIR, would conclude that the 2,000 individuals who live within the blue “donut” are at the highest risk, because they share the same census designated area as the wells. Notably, the only population center of this census block group (or census tracts, which follow this same trend) is at the opposite end of the block group, farthest from the Shafter oil field. Instead, the most at-risk community is the urban community of Shafter with high population density; the census block groups within the pink hole of the donut contain the communities and homes nearest the North Shafter field.
Figure 2. The City of Shafter, California is located just to the south of the North Shafter oil field. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Lost Hills, Arvin, & Taft
The cities of Lost Hills, Arvin, and Taft are all very similar to Shafter. The cities have densely populated urban centers located within or directly next to an oil field. In the maps below in Figures 3 readers can see the community of Lost Hills next to the Lost Hills oil field. Lost Hills, like the densely populated cities of Arvin and Taft, are located very close to large scale extraction operations. Census block groups that include the most impacted area of Lost Hills is outlined in pink, while surrounding low population density census block groups are shown in blue. The majority of the areas outlined in blue are zoned as “estate” and “agriculture” areas. The outlines of the city boundaries are also shown, along with 2,500’ and 1 mile setback distances from currently operational oil and gas wells.
Lost Hills is another situation where a donut-shaped census area distorts the results of low resolution demographics assessments, such as the one conducted by Kern County in their 2020 Draft EIR (PDF pp. 1292-1305). Almost all of the wells within the Lost Hills oil fields are just outside of a 2,500’ setback, but the incredibly high density of extraction operations results in the combined impact of the sum of these wells on degraded air quality. While stringent setback distances from oil and gas wells are a necessary component of environmental justice, a 2,500’ setback on its own is not enough to reduce exposures and risk for the Frontline Community of Lost Hills. For these Frontline Communities, a setback needs to be much larger to reduce exposures. In fact, limiting a public health intervention to a setback requirement alone is not sufficient to address the environmental health inequities in Lost Hills, Shafter, and other similar communities.
Lost Hill’s nearly 2,000 residents are over 99% Latinx, and over 70% of the households make less than $40,000 in annual income (which is substantially less than the annual median income of Kern County households [at $52,479]). The map in Figure 3 shows that the Lost Hills public elementary school is located within 2,500’ of the Lost Hills oil field and within two miles of more than 2,600 operational wells, in addition to the 6,000 operational wells in the rest of the field.
The City of Arvin has 8 operational oil and gas wells within the city limits, and another 71 operational wells within 2 miles. Arvin, with nearly 22,000 people, is over 90% Latinx, and over 60% of the households make less than $40,000 in annual income.
Additionally the City of Taft, located directly between the Buena Vista and Midway Sunset Fields, has a demographic profile with a Latinx population at least 10% higher than the rest of southern Kern County.
Lost Hills, Arvin, and Taft are among the most impacted densely populated areas of Kern County and represent the most Kern citizens at risk of exposure to air quality degradation from oil and gas extraction.
In all of these cases, if only census tract well counts are considered, like in the 2020 Kern County draft EIR, these Frontline Communities will be completely disregarded. Census tracts are intentionally drawn to separate urban/residential areas from industrial/estate/agricultural areas. The census areas that contain the oil fields are very large and sparsely populated, while neighboring census areas with dense population centers, such as these small cities, are most impacted by the oil and gas fields.
Figure 3. The Unincorporated City of Lost Hills in Kern County, California is located within 2,500’ of the Lost Hills Oil Field. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Bakersfield
The City of Bakersfield is a unique scenario. It is the largest city in Kern County and as a result suburban developments surround parts of the city. Urban flight has moved much of the wealth into these suburbs. The suburban sprawl has occurred in directions including North toward the Kern River oil field, predominantly on the field’s western flank in Oildale and Seguro. In the map below in Figure 4, these areas are located just to the north of the Kern River.
This is a poignant example of the development of cheap land for housing developments in an area where oil and gas operations already existed; an issue that needs to be considered in the development of setbacks and public health interventions and policies. This small population of predominantly white, middle class neighborhoods shares similar risks as the lower-income Communities of Color who account for the majority of Bakersfield’s urban center. Even though these suburban communities are less vulnerable to the oppressive forces of systemic racism, real estate markets will continue to prioritize cheap land for development, moving communities closer to extraction operations.
Regardless of the implications of urban sprawl and suburban development, it is important to no disregard the risks to the demographics of the at-risk areas of the city of Bakersfield are predominantly Non-white (31%) and Latinx (60%), particularly as compared to the city’s suburbs (15% Non-white and 26% Latinx). About 33,000 people live in the city’s northern suburbs, and another 470,000 live in Bakersfield’s urban city center just to the south of the 16,500 operational wells in the Kern River, Front, and Bluff oil fields. The urban population of Bakersfield is a large Frontline Community exposed to the local and regional negative air quality impacts of the Kern River and numerous other surrounding oil fields.
Figure 4. Map of the city of Bakersfield in Kern County, California located between several major oil fields including the Kern Front oil field. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Southern California
Ventura
The City of Ventura and the proximity of the Ventura oil field is a similar situation to cities in Kern. The urban center of Ventura is bisected by the Ventura oil field’s nearly 1,200 operational wells. While over 70% of the city’s population is Latinx, the very sparsely populated census areas also containing portions of the oil field are 34% Latinx.
In the map below in Figure 5, take note of the population distribution within the portion of the city closest to the oil field versus the census areas to the east. While a statewide or less granular analysis would assume an evenly distributed population density, in this localized analysis, it is clear that the most vulnerable Frontline Communities are the urban centers closest to the oil fields. Even though the census blocks to the east contain oil and gas wells, the populations are less at risk because the population centers are located farther from the oil field.
Figure 5. Ventura Oil Field in Ventura, California census areas within the 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Los Angeles
In Los Angeles County, Inglewood, Wilmington, Long Beach, and Los Angeles City are some of the largest oil and gas fields. There are many areas in Los Angeles where a single low-producing well is located in an upper middle class suburb, on a golf course, or next to the Beverly Hills High School.
While all well sites present sources of exposure to volatile organic compounds (VOCs) and other air toxics, these four oil fields have incredibly high densities of oil and gas wells in urban neighborhoods. The demographics of the Frontline Communities located within 2,500’ of these major fields are presented below in Table 4. These areas are additionally lower income communities; for example, over 50% of annual household incomes in the census areas surrounding the Los Angeles City oil field are below $40,000, while the Los Angeles County median annual income is over $62,000.
Table 4. Demographics for Frontline Communities living within 2,500’ of Los Angeles’s major oil and gas fields along with counts of operational wells in the fields are shown in the table. The demographic “Latinx” is the count of “Hispanic or Latino Origin” population, and “non-white” was calculated by subtracting “white only” from “total population.”
| Oil Field | Well Count | Non-white (%) | Latinx (%) |
| Inglewood | 914 | 62% | 11% |
| Wilmington | 2,995 | 56% | 63% |
| Long Beach | 687 | 50% | 30% |
| Los Angeles City | 872 | 69% | 59% |
| Ventura | 1,193 | 10% | 72% |
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Inglewood
Figure 6. Inglewood Oil Field Frontline Community, Inglewood, California census areas within a 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Wilmington
Figure 7. Wilmington Oil Field Frontline Community, Wilmington, California census areas within a 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Long Beach
Figure 8. Long Beach Oil Field Frontline Community, Long Beach, California census areas within a 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Los Angeles City
Figure 9. Los Angeles City Oil Field Frontline Community census areas within a 2,500’ setback area. The map shows the 2,500’ setback distance in tan, as well as the census block groups in both pink and blue. Pink block groups show the urban case populations used to generate the demographic summaries.
Production
The creation of public health policies such as 2,500’ setbacks to help protect Frontline Communities is controversial in California as many state legislators are still beholden to the oil and gas industry. The industry itself pushes back strongly against any proposal that could affect their bottom line, no matter how insignificant the financial impact may be. When AB345 was proposed, the industry’s lobbying organization Western States Petroleum Association claimed that institution of 2500’ setbacks would immediately shut down at least 30% of California’s total oil production. This number is an outright fabrication.
As shown in Table 1 above, a 2,500’ setback would impact the less than 9,000 active and new wells; 42% in Kern County and 29% in Los Angeles County. Ventura and Orange Counties are a distant 3rd and 4th, respectively. These counts are further broken down by field in Table 5 below. Statewide these wells accounted for just 12.8% of California’s current oil production by volume (as reported in barrels of oil/condensate by CalGEM), which is much smaller than the wholly unsubstantiated 30% decline claimed by industry.
Table 5. Counts of wells by well status for operational (active, idle, and new) oil and gas wells located within a 2,500’ setback. Fields include the count of wells within the 2,500’ setback and the amount of oil produced from those wells within the setback. The percentage of total oil from that field is also included.
| Oil Field | County | Well Count | Well Ct % of Total | 2019 Oil Prod (BBLS) | Oil Prod % of Total |
| Wilmington | Los Angeles | 2,514 | 83% | 2,292,669 | 22% |
| Kern River | Kern | 1,338 | 9% | 2,121,071 | 12% |
| Inglewood | Los Angeles | 891 | 97% | 1,806,354 | 96% |
| Midway-Sunset | Kern | 1,892 | 10% | 1,614,081 | 8% |
| Ventura | Ventura | 287 | 24% | 1,202,764 | 31% |
| Long Beach | Los Angeles | 687 | 100% | 1,036,506 | 100% |
| Brea-Olinda | Los Angeles | 695 | 97% | 967,223 | 95% |
| Huntington Beach | Orange | 528 | 83% | 753,494 | 42% |
| Placerita | Los Angeles | 448 | 100% | 508,182 | 100% |
| Santa Fe Springs | Los Angeles | 304 | 99% | 421,719 | 72% |
| Cat Canyon | Santa Barbara | 115 | 10% | 418,697 | 36% |
| Beverly Hills | Los Angeles | 156 | 100% | 351,877 | 100% |
| McKittrick | Kern | 334 | 18% | 346,738 | 10% |
| Montebello | Los Angeles | 227 | 98% | 318,657 | 97% |
| Fruitvale | Kern | 286 | 80% | 316,184 | 75% |
| San Ardo | Monterey | 180 | 13% | 313,339 | 4% |
| Torrance | Los Angeles | 219 | 100% | 307,413 | 100% |
| Seal Beach | Los Angeles | 175 | 88% | 282,790 | 74% |
| Shafter, North | Kern | 70 | 78% | 267,256 | 66% |
| Edison | Kern | 520 | 41% | 261,098 | 39% |
| Brentwood | Contra Costa | 4 | 100% | 230,868 | 100% |
| Oxnard | Ventura | 124 | 82% | 214,884 | 100% |
| Sansinena | Los Angeles | 162 | 100% | 207,474 | 100% |
| Poso Creek | Kern | 320 | 16% | 193,533 | 4% |
| Rosecrans | Los Angeles | 94 | 100% | 174,720 | 100% |
| Rio Bravo | Kern | 80 | 74% | 166,444 | 82% |
| Richfield | Orange | 231 | 100% | 165,426 | 100% |
| Coyote, East | Orange | 81 | 100% | 163,639 | 100% |
| San Vicente | Los Angeles | 48 | 100% | 162,940 | 100% |
In the case that setback regulations are crafted both to prohibit new drilling and to phase out existing operations within the setback distance, the industry would have the opportunity to respond with measures that preserve the majority of production volumes, particularly in the Central Valley. For example, in Kern County, the overwhelming majority of new wells drilled in 2020 are directional or horizontal; these drilling technologies would allow operators to access the same below ground resources from surface locations that are further away from and safer for communities. Further, for existing wells within the 2,500’ setback, current proposals would institute a phase out period. Existing wells could be allowed to continue to operate under the terms of their current permits but not allowed to expand or rework their operations to increase or extend production; alternatively (or in addition), well operators could continue for a prescribed timeframe formulated to allow them to recoup their investment (called “amortization”).
Los Angeles
It is clear that the oil fields of Los Angeles would be the most impacted if setbacks phased out the wells responsible for the highest risk to Frontline Communities. The majority of Los Angeles’s urban oil fields are located entirely within 2,500’ of homes, schools, healthcare facilities and daycares.
As shown above in Table 5, wells within the setback produce 96% of the oil in the Inglewood fields, 84% in the Long Beach field, and 100% of the oil in several other smaller fields. With the phase out of these wells, oil extraction would cease in these fields. Most of these fields produce very low volumes of oil and already have high counts of idle wells, 28% idle in Wilmington, 25% in Inglewood, and 56% in Long Beach for example. The sole outlier of this trend is the Wilmington field. The majority of production in the Wilmington field comes from wells located in the Long Beach harbor, enough of them located outside of the 2,500’ setback such that while 83% of the Wilmington field wells are within the 2,500’ setback, these wells account for only 22% of the field’s overall production.
Kern County
The situation in Kern County is quite the opposite of Los Angeles, where the majority of operational wells are located within 2,500’ of homes, residences, and other sensitive receptors like healthcare facilities. In Kern, the overwhelming majority of wells are located beyond 2,500’ and even 1 mile from sensitive receptors. While the Midway-Sunset and Kern River fields have the most wells within the 2,500’ setback area, those wells make up a small percentage of the total operational wells in the fields. As can be seen in the map in Figure 1, wells within the 2,500’ setback zone in the large Kern oil fields are entirely located on the borders of the fields. Overall, a 2,500’ setback in Kern County would only affect 7.1% of active/new wells, accounting for 5.97% of the county’s production.
The oil and gas industry and operators in states including Texas, Colorado, North Dakota, Pennsylvania, Ohio, West Virginia, New Mexico, and Oklahoma are very vocal of their ability to avoid surface disturbance and target oil and gas pools located under sensitive receptors (homes, schools, healthcare facilities, endangered species habitat etc.) using directional drilling. According to the industry, directional drilling has been used for nearly a century to extract resources from areas where surface disruption would impact sensitive communities and habitats.
The same is true for California, especially in Kern County and especially recently. An October 2020 draft environmental impact report by the Kern County Planning and Natural Resource Department disclosed that in a dataset of 9,803 wells drilled from 2000 to 2020 by the California Resources Corporation, the majority of wells were drilled directionally (46%) or horizontally (10%), as opposed to vertically. More recent wells in the County have utilized directional and horizontal drilling even more heavily: a 2020 dataset of wells drilled county-wide indicates that 76% were drilled directionally and an additional 7% were drilled horizontally; only 17% were drilled vertically. These statistics indicate that, even if all wells neighboring Frontline Communities in Kern County were to be phased out (itself a small percentage of the total number of wells in the county), there would only be a small impact on Kern County oil production owing to the prevalence of non-vertical techniques that allow operators the flexibility to access reserves from different surface locations. As noted previously, if all oil production from within the 2,500’ setback zone were to be immediately eliminated statewide, it would mean a maximum decrease of just 12.8% of California’s current annual oil production. But the availability of directional and horizontal drilling in Kern County, where the lion’s share of all drilling statewide occurs, means it is more likely that the decrease in production will be significantly less than 12.8% and likely much less than 10%.
Existing Well Phase Out
Any assertion that a 2,500’ setback would immediately affect oil production is baseless because current setback proposals would institute a phase out period for existing wells. For example, existing permitted wells could be allowed to continue to operate under the terms of their current permits but not allowed to expand or rework their operations to increase or extend production. Alternatively, under a policy approach known as amortization, well operators could continue for a prescribed timeframe formulated to allow them to recoup their investment.
If wells within the setback distance are phased out pursuant to a “no rework” policy, operators would be afforded some time to maximize production in order to ensure that operators receive a sufficient return on their investment under the terms of their existing permits before they shut down. Under such an approach, older wells with increasing risks of fugitive emissions through leaks at the surface and well casing failures could be sequentially phased out by placing a ban on rework permits not required for maintenance or safety. CalGEM permitted well reworks, including sidetracks and deeper drills, increase production and the lifespan of wells. The catalog of rework permits can be found on the CalGEM website.
Based on CalGEM’s production data from 2018 and 2019, a phase out effectuated by disallowing well reworks would result in an annual reduction of less than 1% of total oil production. Of the 52,997 wells reporting oil/condensate production volumes in 2018, 338 received a rework permit in the same year. In 2019, of the 48,860 wells reporting oil production volumes, 285 received rework permits. By volume, the wells that received rework permits accounted for 0.87% of oil production in 2018 and just 0.04% in 2019.
Conclusion
The oil and gas industry in California has consistently pushed back against Frontline Communities who demand public health protections against emissions from oil and gas operations. This occurs even when there will be little to no impact reducing production. It is an industry policy to refuse any concessions and oppose all measures, even to protect public health, by leveraging the industry’s wealth at every level of the political hierarchy.
Fatefully, 2020 has resulted in multiple wins for public health in California. While the failure of AB345 made it clear that the California state legislature is still beholden to the fossil fuel industry, the momentum has continued. Community grassroots groups in Ventura County successfully passed a 1,500’ setback ordinance for occupied dwellings and 2,500’ setbacks for sensitive receptor sites including healthcare facilities and schools. Just south of Ventura, the County of Los Angeles is also in the midst of a rule-making process that is considering multiple setbacks, including 1,000’ to 2,500’ distances. And a committee of the Los Angeles City Council just voted to develop a proposal that would phase out oil drilling across the city as a non-conforming use.
While Ventura and Los Angeles are making progress, Kern County is creating a new process to streamline oil and gas well permitting and has even proposed to decrease the existing zone-specific 300’ setbacks from homes to 210’.
Kern County Frontline Communities and the rest of California also deserve the same consideration as residents of Ventura and Los Angeles Counties. The research is clear that a setback of at least one mile in addition to more site specific public health interventions are necessary to reduce the negative health impacts resulting from these industrial operations within and neighboring Frontline Communities.
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
216 Franklin St, Suite 400, Johnstown, PA 15901
Phone: +1 (717) 303-0403 | info@fractracker.org
FracTracker Alliance is a 501(c)3 non-profit: Tax identification number: 80-0844297