Dunes, Great Lakes Barrens at Risk

World Class Dunes and Great Lakes Barrens at Risk at Ludington

By Dave Dister, Consulting Ecologist, Ludington, MI

One of the prime reasons I moved to the Ludington, Michigan area in 2008 was the aesthetic and biological diversity evident at Ludington State Park (LSP). As a field biologist nearing the end of his formal career, I was eager to conduct a study of the vascular plants within the 5,300-acre park. That study consumed six years of exploring all habitats and ecosystems, and documenting (by vouchers) the flora I encountered. Although the unfortunate presence of the Sargent Sand Company operation was obvious as it cut through the south end of the park, it was not until the fracking boom a few years ago that I took special notice as a residential neighbor.

US Frac Sands and Silica Geology Map


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Above is a dynamic map of silica sands and frac sand mines, drying facilities, and other related facilities. Zoom and click on the map to explore various aspects of frac sand mining infrastructure. Click here to view the map full screen along with its legend.

Expanding Sand Mining

That “sleepy” sand mining operation suddenly turned into a 24-hour, seven-days-a-week operation, with associated noise that irritated a very light-sleeping biologist. Hamlin Township officials were only partially effective in addressing residential impacts “after hours,” and had no interest in developing reasonable ordinances upon a commercial operation. Although increased noise and truck traffic were a tangible nuisance, only when a renewal of the company’s sand mining permit was announced did it become clear that biological resources within the 372-acre private in-holding were afforded virtually no protection at all. And the more research I did into the regulatory permitting process, the more incredulous the situation appeared.


Above – Photos of Sargent Sands frac sand mining operations taken by Ted Auch, FracTracker Alliance

1979 Environmental Impact Report

My expertise as a wetlands biologist and botanist were well suited to scrutinizing the 1979 Environmental Impact Report (EIR), which was a hastily-compiled poorly-researched 24-page document.

From my perspective, there was a poor level of protection afforded to the Federal and State Threatened Pitcher’s Thistle (Cirsium pitcheri). As far as is known, Sargent Sand has no records of relocating this plant in proposed or active mining cells in its 100-year history of mining, although the Michigan Department of Natural Resources (MDNR) has known about plants on the property for more than 20 years. The MDNR and US Fish and Wildlife Service (USFWS) have been complicit in not adequately protecting this species, which has had minimal research into the success (or not) of transplanting individual plants. Young plants appear to transplant well, but long-term studies are not available. Older plants are much less likely to survive transplanting, as they depend on numerous minute root hairs to absorb moisture in a xeric habitat, and removal from a dune would strip-off most such root hairs. It requires about seven years for these plants to mature, so reproductive rates are slow.

Yep, it’s a fact of life – plants simply are not nearly as charismatic as animals, and consequently are treated as “second-class organisms” in the world of environmental protection. Sadly, the Michigan Department of Environmental Quality (MDEQ) just renewed the sand mining permit that allows Sargent Sand to “self-monitor” for this threatened species, and to “move plants” encountered in areas proposed for development. Does anyone really think a mining company will give two hoots about a thistle plant?!

Great Lakes Barrens Ecosystem

The rarity and value of Great Lakes Barrens (GLB) was not addressed when the 1979 EIR was written, though such ecosystems are clearly visible on aerial photographs of Sargent Sand Company property and surrounding LSP. These natural communities are known to be imperiled ecosystems at both the state and global levels. The Michigan Natural Features Inventory classifies “Great Lakes Barrens” – that include jack pine stands with associated xeric-loving shrubs and forbs – as S2 natural communities:

Imperiled in the state because of rarity due to very restricted range, very few occurrences, steep declines, or other factors making it very vulnerable to extirpation from the state. – Michigan Natural Features Inventory

Globally, Great Lakes Barrens have a similar designation. Consequently, mitigation measures must be strengthened and avoidance of impacts considered. Any Restoration Plan of such habitats must include high quality GLB plants such as buffaloberry (Shepherdia canadensis), bearberry (Arctostaphylos uva-ursi), ground juniper (Juniperus communis), sand cherry (Prunus pumila), sand-dune willow (Salix cordata), blueleaf willow (Salix myricoides), beach-heath (Hudsonia tomentosa), harebell (Campanula rotundifolia), white camas (Anticlea elegans), and wild wormwood (Artemisia campestris), among others.

Again, unfortunately the MDNR has not enforced strong protections against the destruction of Great Lakes Barrens. The “reclamation” of destroyed dunes and jack pine barrens for a mere “one-year period at 80 percent vegetative cover” comes nowhere close to a viable mitigation plan, as trees and shrubs impacted in such areas take decades to recover.

Furthermore, other state-listed plants, such as ram’s head lady-slipper orchid (Cypripedium arietinum) are known to be adjacent to Sargent Sand property but are not legally protected as they are only “Special Concern” species. Lastly, the Lake Huron locust (Trimerotropsis huroniana) is a state Threatened insect known to occur within Ludington State Park, and suitable “sparsely vegetated dune” habitat is common within Sargent Sand’s property. If you thought rare plants get little respect, try to protect a threatened grasshopper!

Great Lakes Barrens often include seasonal wetlands that are protected under Section 404 of the Clean Water Act of 1972, but which often lack surface waters much of the year. Not surprisingly, the 1979 EIR does not mention “wetlands” at all. At best, there is a comment that “There are three or four very small swamp areas on the property…”  However, a review of recent aerial photography indicates many Interdunal Wetlands remain within the northern half of Sargent Sand property. The largest of these appears to be at least 0.5 acre in size, and it is likely that several acres of such wetlands exist on the property.

Consequently, a formal Wetland Delineation is needed to determine the exact location and amount of Jurisdictional Wetlands on Sargent Sand property. Any impact to such wetlands requires mitigation measures that include avoidance, minimization, and/or wetland creation elsewhere within the watershed. Additionally, Interdunal Wetlands are ranked S2 Natural Communities by the State of Michigan, and have a rank of G2 globally. Both of these designations indicate these areas are “Imperiled,” so mitigation ratios should be high (e.g., 10:1 or 20:1).

Current Political Climate in Ludington

The current political leadership in Michigan, as well as the nation, has presented a formidable challenge for environmentalists and scientists. Additionally, the system certainly appears rigged when the agency – the MDEQ – that issues permits and permit renewals is also a lobbyist for the oil, gas, and minerals industry. Nevertheless, the battle to protect this natural heritage is a noble and vital one that will persist. As with every other sensitive and rare environmental resource, if no one scrutinizes the lax protection of our natural heritage, before you know it, it will be gone.

AG Pruitt testifies before a congressional committee on issues surrounding energy and the environment

“Polluting Pruitt:” A Wolf to Guard the Hen House?

Guest article by Dakota Raynes, Co-Organizer of Stop Fracking Payne County (OK)

President Trump recently tapped Oklahoma Attorney General Scott Pruitt to head the Environmental Protection Agency (EPA), even though Pruitt is a self-proclaimed “leading advocate against the EPA’s activist agenda.” Pruitt is currently opposing investigation of Exxon Mobile’s handling of climate-change science based on the belief that climate change science is not yet settled and “debate should be encouraged in classrooms, public forums, and the halls of Congress.” Senate confirmation hearings regarding Pruitt’s nomination are currently ongoing – many questions have focused on Pruitt’s legacy as AG of OK and what that tells us about actions he might take as head of the EPA.

Pruitt’s Past as AG

Elected in 2010, Pruitt’s six-year tenure illuminates the full extent of the troubling stances he takes. For instance, he has fought against the overturn of DOMA, same-sex marriage rights, granting legal status to undocumented immigrants, the Affordable Care Act, access to safe and affordable birth control and abortions, and Dodd-Frank Wall Street reform. These actions demonstrate Pruitt’s inability to accept or implement procedures, policies, and programs supported by a majority of US residents, members of the nations’ highest courts, and even his own colleagues.

A Focus on Environmental Issues

More specifically related to environmental issues, he has openly criticized the EPA in congressional hearings and op-ed pieces. Due to his belief that the EPA frequently abuses its authority, Pruitt’s office has filed 14 antiregulatory lawsuits against the EPA. Investigative reporters uncovered that in 13 of these cases co-litigators included companies that had contributed significant amounts of money to Pruitt and/or Pruitt-affiliated political action committees (PACs). He also routinely joins lawsuits against other states. For example, Pruitt and five other Attorneys General challenged a California law banning the sale of eggs laid by hens living in cramped conditions, but a US District Judge ruled they lacked legal standing because they were representing the economic interests of a few industrial egg producers rather than the interests of their broader constituents.

Several such lawsuits are still pending, which legal experts and others claim presents a conflict of interest should Pruitt become the new Director of the EPA. When asked specifically about this issue during Senate confirmation hearings, Pruitt refused to recuse himself from the lawsuits, saying he would leave such a decision up to the EPA’s legal counsel team. Notably, across the course of his six-years as AG, Pruitt’s office has distributed more than 700 news releases announcing the office’s actions, his speeches and public appearances, and efforts to challenge federal regulations. More than 50 of these releases promoted the office’s efforts to sue the EPA, but not once has a release described actions the office has taken to enforce environmental laws or to hold violators accountable for their actions.

Potential Conflicts of Interest

In OK, Pruitt has made many choices, that when viewed together, strongly suggest that his loyalties reside with the industries that have donated hundreds of thousands of dollars to his election campaigns rather than with the people he is sworn to protect. Here is a short list of the most troubling examples:

  • Pruitt’s predecessor had filed suit against Tyson, Cargill, and a number of other poultry producers in OK due to inappropriate disposal of an estimated 300,000 tons of animal waste per year, which was causing toxic algae blooms along the Illinois River. But shortly after his election, Pruitt dropped the case, citing a need for more research. Some have questioned whether his decision was impacted by the fact that the poultry industry had donated at least $40,000 to his campaign that year.
  • He also quickly dismantled the Attorney General’s in-house environmental protection unit, a team of four attorneys and a criminal investigator, and replaced it with the state’s first “federalism unit,” which was created to litigate against overreach by the federal government, mostly the EPA. Pruitt has repeatedly made it clear that he believes states should handle environmental issues, regardless of the fact that environmental issues frequently cause problems that cross geopolitical boundaries such as state lines (OK’s induced seismicity issue1 is a key example, more information about induced seismicity can be found here).
  • In 2013, he created a coalition of 9 Attorneys General, major energy CEOs, and their lawyers and brought them all to OK for a strategizing session regarding how to stop government and citizen responses to the ills of the oil and gas industry; it was an all-expenses paid event funded by Mercatus, a right-wing think tank favored by the Koch brothers.
    1. Notably, the energy industry is Pruitt’s second largest campaign contributor. When he came up for re-election in 2013, he chose Harold Hamm (CEO of Continental Resources, one of the largest oil companies in OK) to co-chair his campaign. Shortly after winning reelection in 2014, Pruitt joined forces with key industry players including Oklahoma Gas and Electric and the Domestic Energy Producers Alliance (chaired by Hamm) to file several antiregulatory lawsuits, which include attempts to block the Clean Power Plan and Waters of the US rule.
    2. Pruitt has also served as leader of the Republican Association of Attorneys General, which has collected at least $4.2 million in donations from fossil-fuel related companies since 2013.
  • Recently, local investigative reporters discovered that Pruitt’s office failed to follow a state law requiring state agencies to disclose spending on outside attorneys. Their examination illuminated that Pruitt has spent more than $1 million on legal fees since FY2012 – a total that does not include costs directly related to lawsuits against the EPA or the Affordable Care Act.

Induced-Seismicity and Wastewater Disposal

OK Map of Recent Earthquakes for Pruitt article

Map of Oklahoma Class II Injection Wells and Volumes 2011 to 2015 (Barrels). Click image to explore a full screen, dynamic map.

Oklahoma recently became the earthquake capital of the world due to a phenomenon referred to as injection-induced seismicity. While OK has not historically been known as a seismically active area, thousands of tremors have shaken the state since the shale gas boom began.

Several researchers have used geospatial analysis to demonstrate how these quakes are caused by the high-pressure injection of oil and gas industry wastes such as the flowback and produced water created by the unconventional oil and gas production process known as hydraulic fracturing. The map above shows where injection wells (tan dots) are located and where earthquakes (green dots) occurred from 2011-2015.

Oklahomans have been harmed by the implicitly pro-fracking stance Pruitt has taken, as evidenced by his lack of action regarding induced seismicity – as well as air, water, and soil contamination due to oil and gas industry activities. Several people, including Johnson Bridgewater (Director of OK Chapter of the Sierra Club) have noted that:

There are various places where the attorney general’s office could have stepped in to fix this overall problem…Its job is to protect citizens. Other states were proactive and took these issues on…[yet] Pruitt has been completely silent in the face of a major environmental problem for the state and its taxpayers.

Specifically, the AG’s office could have responded to the legal question of whether the state could limit or ban transport of fracking-related wastewater, sent by other states for disposal in underground injection wells in OK.

He also did nothing to address the phenomenally low earthquake insurance claim approval rate; after the 5.8M quake shook Pawnee in September of 2016, 274 earthquake damage claims were filed but only 4 paid out. Estimates of statewide approval rates generally suggest that approximately 1% of claimants receive funds to aid repairs.

Lastly, there are a number of class action lawsuits against a variety of industry actors regarding earthquake damages, yet Pruitt’s office has not entered any of these as an intervenor even though AGs in other states have done so.

Pruitt not at fault?

Photo Credit: JIM BECKEL/The Oklahoman

Earthquake damage. Photo Credit: Jim Beckel/The Oklahoman

Pruitt was recently called out by investigative reporters who used open-records requests to reveal that letters, briefs, and lawsuits that he submitted were written in whole or in part by leading energy firms such as Devon (another of OK’s largest oil and gas companies). Pruitt’s response was that he had done nothing wrong, nothing even potentially problematic. Rather, he said, of course he was working closely with industry and isn’t that what he should be doing. Some would argue that as AG what he should be doing is working closely with the people of Oklahoma, especially those whose homes, lives, and livelihoods have crumbled under the weight of attempting to repair earthquake damage due to industry activities.

Historical AG Influence

It is important to remember, though, that what’s happening with Pruitt is not isolated. Rather, as several long-time reporters have noted, increased attention to developing beneficial relationships with AGs is a result of historical processes.

About 20 years ago more than 40 state AGs banded together to challenge the tobacco industry, which led to a historic $206 billion settlement decision. Later, Microsoft, the pharmaceutical industry, and the financial services industry each faced similar multistate challenges regarding the legality or illegality of particular business practices.

As some AGs began hiring outside law firms to investigate and sue corporations, industry leaders realized that AGs’ actions were far more powerful and immediate than those of legislative bodies. So, they began a heretofore unprecedented campaign to massively increase their influence at this level.

Several people have critiqued the ways in which such actions undermine democratic processes, prompt troubling questions about ethics, and negatively impact attorney generals’ abilities to fulfill their duties to the state and its residents.

A Mission at Risk

Those of us on the frontlines here in OK have seen just how powerful such coalitions can be, how much sway they can have on local and state officials, how they destabilize people’s faith and trust in the systems that are supposed to protect them, and how coalitions undercut people’s hope and desire to be civically engaged. The mission of the US Environmental Protection Agency is to protect human health and the environment. If confirmed to lead the EPA, it is very likely Pruitt will prioritize his relationships with industry over the health and welfare of the people and environment he’s directed to protect.

Footnotes

  1. To learn more about induced seismicity read an exclusive FracTracker two-part series from former VTSO researcher Ariel Conn: Part I and Part II. Additionally, the USGS has created an Induced Earthquakes landing page as part of their Earthquake Hazards Program.

Hypothetical Impacts of Unconventional Drilling In Allegheny County

With tens of thousands of wells scattered across the countryside, Southwestern Pennsylvania is no stranger to oil and gas development. New, industrial scale extraction methods are already well entrenched, with over 3,600 of these unconventional wells drilled so far in that part of the state, mostly from the well known Marcellus Shale formation.

Southwestern Pennsylvania is also home to the Pittsburgh Metropolitan Area, a seven county region with over 2.3 million people. Just over half of this population is in Allegheny County, where unconventional drilling has become more common in recent years, along with all of its associated impacts. In the following interactive story map, the FracTracker Alliance takes a look at current impacts in more urban and suburban environments, plus projects what future impacts could look like, based on leasing activity.

hypothetical impacts map

By Matt Kelso, Manager of Data & Technology

Oklahoma and Kansas Class II Injection Wells and Earthquakes

By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance
In collaboration with Caleb Gallemore, Assistant Professor in International Affairs, Lafayette University

The September 3rd magnitude 5.8 earthquake in Pawnee, Oklahoma, is the most violent example of induced seismicity, or “man-made” earthquakes, in U.S. history, causing Oklahoma governor Mary Fallin to declare a state of emergency. This was followed by a magnitude 4.5 earthquake on November 1st prompting the Oklahoma Corporation Commission (OCC) and U.S. EPA to put restrictions on injection wells within a 10-mile radius of the Pawnee quake.

And then on Sunday, November 6th, a magnitude 5.0 earthquake shook central Oklahoma about a mile west of the Cushing Hub, the largest commercial crude oil storage center in North America capable of storing 54 million barrels of crude. This is the equivalent of 2.8 times the U.S. daily oil refinery capacity and 3.1 times the daily oil refinery capacity of all of North America. This massive hub in the North American oil landscape also happens to be the southern terminus of the controversial Keystone pipeline complex, which would transport 590,000 barrel per day over more than 2,000 miles (Fig. 1). Furthermore, this quake demonstrated the growing connectivity between Class II injection well associated induced seismicity and oil transport/storage in the heart of the US version of Saudi Arabia’s Ghawar Oil Fields. This increasing connectivity between O&G waste, production, and processing (i.e., Hydrocarbon Industrial Complex) will eventually impact the wallets of every American.

North American Oil Refinery Capacity, Pipelines, and Cushing, OK

Figure 1. The Keystone Pipeline would transport 590,000 bpd over more than 2,000 miles.

This latest earthquake caused Cushing schools to close. Magellan Midstream Partners, the major pipeline and storage facility operator in the region, also shut down in order to “check the integrity of our assets.” Compounding concerns about induced seismicity, the Cushing Hub is the primary price settlement point for West Texas Intermediate that, along with Brent Crude, determines the global price of crude oil and by association what Americans pay for fuel at the pump, at their homes, and in their businesses.

Given the significant increase in seismic activity across the U.S. Great Plains, along with the potential environmental, public health, and economic risks at stake, we thought it was time to compile an inventory of Class II injection well volumes. Because growing evidence points to the relationship between induced seismicity and oil and gas waste disposal, our initial analysis focuses on Oklahoma and Kansas. The maps and the associated data downloads in this article represent the first time Class II injection well volumes have been compiled in a searchable and interactive fashion for any state outside Ohio (where FracTracker has compiled class II volumes since 2010). Oklahoma and Kansas Class II injection well data are available to the public, albeit in disparate formats and diffuse locations. Our synthesis makes this data easier to navigate for concerned citizens, policy makers, and journalists.

Induced Seismicity Past, Present, and Future

inducedseismicity_figure

Figure 2. Central U.S. earthquakes 1973-August 15, 2015 according to the U.S. Geological Survey (Note: Based on our analysis this exponential increasing earthquakes has been accompanied by a 300 feet per quarter increase in the average depth of earthquakes across Oklahoma, Kansas, and Texas).

Oklahoma, along with Arkansas, Kansas, Ohio, and Texas, is at the top of the induced seismicity list, specifically with regard to quakes in excess of magnitude 4.0. However, as the USGS and Virginia Tech Seismological Observatory (VTSO)[1] have recently documented, an average of only 21 earthquakes of magnitude 3.0 or greater occurred in the Central/Eastern US between 1973 and 2008. This trend jumped to an average of 99 between 2009 and 2013. In 2014 there were a staggering 659 quakes. The exponential increase in induced seismic events can be seen in Figure 2 from a recent USGS publication titled “High-rate injection is associated with the increase in U.S. mid-continent seismicity,” where the authors note:

“An unprecedented increase in earthquakes in the U.S. mid-continent began in 2009. Many of these earthquakes have been documented as induced by wastewater injection…We find that the entire increase in earthquake rate is associated with fluid injection wells. High-rate injection wells (>300,000 barrels per month) are much more likely to be associated with earthquakes than lower-rate wells.”

hydraulic-fracturing-freshwater-demand

Figure 3. Average freshwater demand per hydraulically fractured well across four U.S. shale plays and the annual percent increase in each of those plays.

This trend suggests that induced seismicity is the new normal and will likely increase given that: 1) freshwater demand per hydraulically fractured well is rising all over the country, from 11-15% per year in the Marcellus and Bakken to 20-22% in the Denver and Midland formations, 2) the amount of produced brine wastewater parallels these increases almost 1-to-1, and 3) the unconventional oil and gas industry is using more and more water as they begin to explore the periphery of primary shale plays or in less productive secondary and tertiary plays (Fig. 3).

Oklahoma

The September, 2016, Pawnee County Earthquake

This first map focuses on the September, 2016 Pawnee, OK Magnitude 5.8 earthquake that many people believe was caused by injecting high volume hydraulic fracturing (HVHF) waste into class II injection wells in Oklahoma and Kansas. This map includes all Oklahoma and Kansas Class II injection wells as well as Oklahoma’s primary geologic faults and fractures.

Oklahoma and Kansas Class II injection wells and geologic faults


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Pawnee, Oklahoma 5.8 magnitude earthquake, September, 2016 & Active Class II Injection Wells

Figure 4. The September, 2016 Pawnee, Oklahoma 5.8M earthquake, neighboring active Class II injection wells, underlying geologic faults and fractures.

Of note on this map is the geological connectivity across Oklahoma resulting from the state’s 129 faults and fractures. Also present are several high volume wells including Territory Resources LLC’s Oldham #5 (1.45 miles from the epicenter, injecting 257 million gallons between 2011 and 2014) and Doyle #5 wells (0.36 miles from the epicenter, injecting 61 million gallons between 2011 and 2015), Staghorn Energy LLC’s Hudgins #1 well (1.43 miles from the epicenter, injecting 11 million gallons between 2011 and 2015 into the Red Fork formation), and Cooke Co Production Co.’s Laird #3-35 well (1.41 miles from the epicenter, injecting 6.5 million gallons between 2011 and 2015). Figure 4 shows a closeup view of these wells relative to the location of the Pawnee quake.

Class II Salt Water Disposal (SWD) Injection Well Volumes

This second map includes annual volumes of disposed wastewater across 10,297 Class II injection wells in Oklahoma between 2011 and 2015 (Note: 2015 volumes also include monthly totals). Additionally, we have included Oklahoma’s geologic faults and fractures for context given the recent uptick in Oklahoma and Kansas’ induced seismicity activity.

Annual volumes of class II injection wells disposal in Oklahoma (2011-2015)


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Oklahoma statistics for 2011 to 2015 (Table 1):

  1. Maximum volume to date (for a single Class II injection well): 105,979,598 barrels, or 4,080,214,523 gallons (68,003,574 gallons per month), for the New Dominion, LLC “Chambers #1” well in Oklahoma County.
  2. Total Volume to Date: 10,655,395,179 barrels or 410,232,714,392 gallons (6,837,211,907 gallons per month).
  3. Mean volume to date across the 10,927 Class II injection wells: approximately 975,144 barrels per well or 37,543,044 gallons (625,717 gallons per month).
  4. This map also includes 632 Class II wells injecting waste into the Arbuckle Formation which is believed to be the primary geological formation responsible for the 5.0 magnitude last week in Cushing.

Kansas

Below is an inventory of monthly oil and gas waste volumes (barrels) disposed across 4,555 Class II injection wells in Kansas between 2011 and 2015. This map will be updated in the Spring of 2017 to include 2016 volumes. A preponderance of this data comes from 2015 with a scattering of volume reports across Kansas between 2011 and 2014.

Monthly Class II injection wells volumes in Kansas (2011-2015)


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Kansas statistics for 2015 (Table 1):

  1. Maximum volume to date (for a single Class II injection well): 9,016,471 barrels, or 347,134,134 gallons (28,927,845 gallons per month), for the Sinclair Prairie Oil Co. “H.J. Vohs #8” well in Rooks County. This is a well that was initially permitted and completed between 1949 and 1950.
  2. Total Volume to date: 1,060,123,330 barrels or 40,814,748,205 gallons (3,401,229,017 gallons per month).
  3. Mean volume to date across the 4,555 Class II injection wells: approximately 232,738 barrels per well or 8,960,413 gallons (746,701 gallons per month).

Table 1. Summary of Class II SWD Injection Well Volumes across Kansas and Oklahoma

 

 

Sum Average Maximum
No. of Class II
SWD Wells
Barrels Sum To Date Per Year Sum To Date Per Year
Kansas* 4,555 1.06 BB 232,738 9.02 MB
Oklahoma** 10,927 10.66 BB 975,143 195,029 105.98 MB 21.20 MB

* Wells in the counties of Barton (279 wells), Ellis (397 wells), Rooks (220 wells), Russell (199 wells), and Ness (187 wells) account for 29% of Kansas’ active Class II wells.

** Wells in the counties of Carter (1,792 wells), Creek (946 wells), Pontotoc (684 wells), Seminole (476 wells), and Stephens (1,302 wells) account for 48% of Oklahoma’s active Class II wells.

Conclusion

If the U.S. EPA’s Underground Injection Control (UIC) estimates are to be believed, the above Class II volumes account for 19.3% of the “over 2 billion gallons of brine…injected in the United States every day,” and if the connectivity between injection well associated induced seismicity and oil transport/storage continues to grow, this issue will likely impact the lives of every American.

Given how critical the Cushing Hub is to US energy security and price stability one could easily argue that a major accident there could result in a sudden disruption to fuel supplies and an exponential increase in “prices at the pump” that would make the 240% late 1970s Energy Crisis spike look like a mere blip on the radar. The days of $4.15 per gallon prices the country experienced in the summer of 2008 would again become a reality.

In sum, the risks posed by Class II injection wells and are not just a problem for insurance companies and residents of rural Oklahomans and Kansans, induced seismic activity is a potential threat to our nation’s security and economy.

Downloads

FracTracker Induced Seismicity Infographic (print quality)

Oklahoma Class II SWD Injection Well Annual Volumes 2011 to 2015 (Barrels)

Kansas Class II SWD Injection Well Monthly Volumes 2011 to 2015 (Barrels)

Footnotes

[1] To learn more about Induced Seismicity read an exclusive FracTracker two-part series from former VTSO researcher Ariel Conn: Part I and Part II. Additionally, the USGS has created an Induced Earthquakes landing page as part of their Earthquake Hazards Program.

Sabal Pipeline Map

The Sabal Trail Pipeline: A Sinking Feeling

Construction is underway for a $3.2 billion, 515-mile-long interstate gas pipeline, running from central Alabama, through southwestern Georgia, and deep into Central Florida. The Sabal Trail Pipeline is a project of Duke Energy, NextEra Energy, and Spectra Energy. Spectra is the fossil fuel corporation responsible for other controversial pipelines also under construction – notably the Algonquin Incremental Market (AIM) Project. AIM, the target of ongoing protests in the Hudson Valley (NY) and elsewhere, would run from central New Jersey to ports in the Boston, MA area, passing within a few hundred feet of Indian Point Nuclear Power Plant on the Hudson River.

The Sabal Trail project is touted by Spectra to be crucial to aiding economic development along its route, and fueling gas-fired power generators in the Southeast United States. Environmentalists, however, view the project quite differently. Such development plans rarely come without a cost to communities, and to the environment.

A Unique Geology

Reflecting its geological origins as part of a shallow ancient ocean, the southeastern United States is underlain by porous limestone bedrock, known as karst. Water running through the karst bedrock flows not only through small pores, but often through extensive underground caves. When under under pressure, water can bubble up to the surface in a multitude of freshwater springs throughout the region. It’s not hard to imagine how contamination to the limestone aquifer in one area can spread rapidly and widely.

The karst bedrock, due to the sometimes large voids in its structure, is also prone to the formation of sinkholes, some of which are small; others are large enough to swallow whole buildings. Recognizing these risks, opponents of the Sabal Trail pipeline frequently cite the inherent danger of pipelines bending and rupturing should the ground beneath them give way, leading to potentially dangerous gas leakages or explosions.

One piece of recent research from the University of Georgia maps the prevalence of sinkholes in Doughterty County, GA, one of the many counties the Sabal Trail pipeline would pass through.  For reference, FracTracker has added the path of the pipeline to the Dougherty County map, above.

In the interactive map below, we show the full proposed pipeline route and associated compressor stations. Karst geology, documented sinkholes, and springs near the route of the pipeline are also shown. The double-arrows in the upper right corner of the map will launch a full-screen view of the map, including a map legend. Use the “Layers” dropdown along the top bar of that map to turn on locations of nearby schools and hospitals that could be impacted by a nearby pipeline emergency. In addition, a “Bookmarks” dropdown menu along the same top bar that will allow zooming to locations along the pipeline mentioned in this article.

Map of the proposed Sabal Trail pipeline route, karst geology, and known sinkholes

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Growing Opposition

In October 2015, the United States Environmental Protection Agency (EPA) issued a scathing letter detailing the impacts that the proposed pipeline would have on the Floridan Aquifer, water quality, and ecology in this region of sensitive karst geology. Two months later, however, in mid-December, the EPA suddenly reversed its position. While reasons included an endorsement of industry’s choices to avoid “many of the most sensitive areas” that could be impacted, ABC News has suggested that political favoritism could have played a role, as well.  This video, published on November 24, 2016 by ABC/FirstCoast News, describes that situation, and also includes excellent footage of construction impacts.

Currently, the construction is proceeding. Federal Energy Regulatory Commission (FERC) has granted eminent domain to industry to build the project through seized private property. Although all federal permits for the pipeline construction are in place, a joint lawsuit filed by the Sierra Club, the Gulf Restoration Network, and Flint Riverkeeper has challenged that permitting process. There is opposition to the pipeline in Alabama, Georgia, and Florida–the three states in which construction is occurring.

The video clips below documents the noise associated with the pipeline’s construction, as well as views of the sinkhole terrain along its route.

Sabal Trail gas pipeline noise pollution at the Santa Fe River (Nov. 25, 2016).
Credit: Merrillee on Vimeo.

Sabal Trail gas transmission, at O’Brien (Hildreth) Compressor Station in Northern Florida.
Credit: Merrillee on Vimeo.

Water Protectors

As winter descends on the northern Plains, thousands of indigenous people representing hundreds of tribes, as well as non-Native allies, have gathered in camps near the Sioux Standing Rock Reservation to pray and protest the Dakota Access Pipeline (DAPL), which would drill an oil pipeline through sacred Native lands and under the Missouri River. Participants in this movement are united by the words “Water Is Life” (Mni Wiconi), in recognition of the threats that an oil spill would present to their homeland and the source of drinking water for the tribe. Hundreds of arrests of peaceful protesters have been made there in recent months, many resulting in serious injuries to the protesters as water cannons, rubber bullets, concussion grenades, and attack dogs have been used in efforts to intimidate the activists.

Coordination among First Nations groups against other fossil fuel infrastructure is happening elsewhere, too. For example, in September 2016, at least fifty US and Canadian aboriginal groups signed a treaty, saying they will work together to fight proposals that would bring crude oil from the Alberta tar sands via pipeline, tanker, and rail.

The protests against the Sabal Trail Project are similarly themed to those at Standing Rock, but have not resulted in violence towards protesters thus far. Along the Suwanee River in Florida, peaceful protesters have assembled at the Sacred Waters encampment and, on November 12, 2016, faced off with authorities in an effort to stop pipeline drilling under the Santa Fe River between Branford and Fort White, Florida.  14 people were arrested in that protest. Demonstrations at the site continue, with a dawn march and demonstration that began just after sunrise on November 26th. No arrests were made on that day. Another protest encampment, the Crystal Waters Camp, is also in place near Fort Drum, Florida, where observers noted hydrocarbon releases from the pipeline construction into Fort Drum Creek and destruction of wildlife by a pipeline crew. Still other protests about the potential environmental risks posed by the Sabal Trail have taken place recently in both Orlando and Live Oak, Florida.

Even in the phases of construction, environmentalists in Georgia discovered that the Sabal Trail pipeline had started leaking drilling mud from a pilot hole into the Withlacooche River in late October, and continued to ooze turbid mud for at least three weeks. Environmental advocates from the WWALS (the Withlacoochee, Alapaha, Little, and Upper Suwannee River) Watershed Coalition raised concerns that if a pilot hole could cause such a leakage, what could happen once full-scale directional drilling was occurring?

By Karen Edelstein, Eastern Program Coordinator

The Mississippi Fracking Fight: Saving Forests, Woodpeckers, and the Climate

By Wendy Park, senior attorney with the Center for Biological Diversity

 

If the Bureau of Land Management (BLM) gets its way, large areas of Mississippi’s Bienville and Homochitto national forests will be opened up to destructive fracking. This would harm one of the last strongholds for the rare and beautiful red-cockaded woodpecker, create a new source of climate pollution, and fragment our public forests with roads, drilling pads and industrial equipment. That’s why we’re fighting back.

My colleagues and I at the Center for Biological Diversity believe that all species, great and small, must be preserved to ensure a healthy and diverse planet. Through science, law and media, we defend endangered animals and plants, and the land air, water, and climate they need. As an attorney with the Center’s Public Lands Program, I am helping to grow the “Keep It in the Ground” movement, calling on President Obama to halt new leases on federal lands for fracking, mining, and drilling that only benefit private corporations.

That step, which the president can take without congressional approval, would align U.S. energy policies with its climate goals and keep up to 450 billion tons of greenhouse gas pollution from entering the atmosphere. Already leased federal fossil fuels will last far beyond the point when the world will exceed the carbon pollution limits set out in the Paris Agreement, which seeks to limit warming to 1.5 °C above pre-industrial levels. That limit is expected to be exceeded in a little over four years. We simply cannot afford any more new leases.

Fracking Will Threaten Prime Woodpecker Habitat

In Mississippi, our concerns over the impact of fracking on the rare red-cockaded woodpecker and other species led us to administratively protest the proposed BLM auction of more than 4,200 acres of public land for oil and gas leases the Homochitto and Bienville national forests. The red-cockaded woodpecker is already in trouble. Loss of habitat and other pressures have shrunk its population to about 1% of its historic levels, or roughly 12,000 birds. In approving the auction of leases to oil and gas companies, BLM failed to meet its obligation to protect these and other species by relying on outdated forest plans, ignoring the impact of habitat fragmentation, not considering the effects of fracking on the woodpecker, and ignoring the potential greenhouse gas emissions from oil and gas taken from these public lands. The public was also not adequately notified of BLM’s plans.

 

Mississippi National Forests, Potential BLM Oil & Gas Leasing Parcels, and Red Cockaded Woodpecker Sightings


View map fullscreenHow FracTracker maps work

Fracking Consequences Ignored

According to the National Forest Service’s 2014 Forest Plan Environmental Impact Statement, core populations of the red-cockaded woodpecker live in both the Bienville and Homochitto national forests, which provide some of the most important habitat for the species in the state. The Bienville district contains the state’s largest population of these birds and is largely untouched by oil and gas development. The current woodpecker population is far below the target set by the U.S. Fish and Wildlife Service’s recovery plan. A healthy and fully recovered population will require large areas of mature forest. But the destruction of habitat caused by clearing land for drilling pads, roads, and pipelines will fragment the forest, undermining the species’ survival and recovery.

red-cockaded_woodpecker_insertNew leasing will likely result in hydraulic fracturing and horizontal drilling. In their environmental reviews, BLM and the Forest Service entirely ignore the potential for hydraulic fracturing and horizontal drilling to be used in the Bienville and Homochitto national forests and their effects on the red-cockaded woodpecker. Fracking would have far worse environmental consequences than conventional drilling. Effects include increased pollution from larger rigs; risks of spills and contamination from transporting fracking chemicals and storing at the well pad; concentrated air pollution from housing multiple wells on a single well pad; greater waste generation; increased risks of endocrine disruption, birth defects, and cardiology hospitalization; and the risk of earthquakes caused by wastewater injection and the hydraulic fracturing process (as is evident in recent earthquakes in Oklahoma and other heavily fracked areas).

Greenhouse Gas Emissions and Climate Change

Oil and gas development also results in significant greenhouse gas emissions from construction, operating fossil-fuel powered equipment during production, reclamation, transportation, processing and refining, and combustion of the extracted product. But BLM and the Forest Service have refused to analyze potential emissions or climate change effects from new leasing. Climate change is expected to worsen conditions for the woodpecker, compounding the harms of destructive drilling practices. Extreme weather events will become more frequent in the Southeast U.S. as temperatures rise. Hurricane Katrina resulted in significant losses of woodpecker habitat and birds in the Mississippi national forests. The Forest Service should be redoubling its efforts to restore and preserve habitat, but instead it is turning a blind eye to climate change threats.

At a time when world leaders are meeting in Morocco to discuss the climate crisis and scientists tell us we already have enough oil and gas fields operating to push us past dangerous warming thresholds, it’s deeply disturbing that the Obama administration continues to push for even more oil and gas leases on America’s public lands. The BLM’s refusal to acknowledge and analyze the effects of fracking on the climate, at-risk species, and their habitat, is not only inexcusable it is illegal. The science is clear: The best way to address catastrophic warming — and protect wildlife — is to keep fossil fuels in the ground.

Photographs for this article were sourced from the U.S. Department of Agriculture fair-use photostream.

Clearing land for shale gas pipeline in PA

A Push For Pipelines

By Bill Hughes, WV Community Liaison

For anyone who even casually follows Marcellus and Utica shale gas exploration and production, such as in the active gas fields of West Virginia or Southwestern PA or Ohio, we know there are many concerns surrounding the natural gas production process. These issues range from air pollution, water consumption and contamination, to waste disposal. We know that, after all well the pad drilling and construction traffic are done, we must also have pipelines to get the gas to compressor stations, processing plants, and to markets in the Eastern United States (and likely Europe and Asia in the near future). Gas companies in Wetzel County, WV, and in neighboring tri-state counties, are convinced that building pipelines – really big pipelines – will be the silver bullet to achieving some semblance of stability and profitability.

Problems With Proposed Pipelines

One of the new, very large diameter (42”) proposed gas pipelines getting attention in the press is the Mountain Valley Pipeline, which will originate in the village of Mobley in eastern Wetzel County, WV and extend Southeast, through national forests and over the Appalachian Mountains into the state of Virginia. Even if the residents of Wetzel County and other natural gas fields are guinea pigs for experiments with hydraulic fracturing, we know how to build pipelines, don’t we? The equipment, knowledge, and skill sets needed for pipeline construction is readily available and commonly understood compared to high pressure horizontal drilling with large volumes of slick water. So, what could go wrong?

I can answer that question first hand from my hayfield in Wetzel County. Almost two years ago, EQT wanted to survey my property for a similar proposed pipeline – this one 30” in diameter, called the Ohio Valley Connector (OVC). The application for this project has now been filed with the Federal Energy Regulatory Commission (FERC). The below map shows a section of the OVC as proposed almost two years ago. The red outlined area is my property. The yellow line shows one proposed pathway of the 30” pipeline that would cross our land. Multiple routes were being explored at first. Were this version approved, it would have gone right through my hayfield and under our stream.

A section of the OVC as proposed almost two years ago.

A section of the OVC as proposed almost two years ago. The red outlined area is my property. The yellow line shows one proposed pathway of the 30” pipeline that would cross our land.

Pipeline opponents express concern about habitat fragmentation, the crossing of pristine streams and rivers, erosion and sedimentation issues, spills, gas leaks, and possible explosions. These are all very valid concerns. But the potential for other logistical errors in the building process – from very simple to potentially serious ones – are also worth consideration. In this article I will use my recent personal experience as a detailed and documented example of how a professionally surveyed location on my property contained an error of almost one mile – over 4,000 feet – as part of a pipeline construction planning project. Yes, you read that right.

Part I: How Did We Get To This Point

Before we get to my story, I should review my first contact with EQT on this issue. In February of 2014, an EQT land agent asked me for permission to walk my property for preliminary evaluation of a route that would send their 30” high-pressure pipe through our land, from south to north.

It is important to keep in mind that almost every landowner in Wetzel County has been contacted by mail, phone or in person, by land agents promising cash with a verbal assurance that all will be well. The goal is to get a landowner’s signature on a loosely worded “right of way” (RoW) lease contract, with terms favorable to the gas company, and move on. Unfortunately, pipeline lease offers cannot be ignored. Not objecting or not questioning can sometime leave the landowner with fewer choices later. This is because many of the bigger interstate transmission lines are being proposed as FERC lines. When final approval is granted by FERC, these pipelines will have the legal power of eminent domain, where the property owner is forced to comply. Just filing a FERC application does not grant eminent domain in West Virginia, as it seems to in Virginia, but the potential for eminent domain gives land agents power over landowners.

I was not ready to give them surveying permission (to drive stakes or other permanent markers). Since a natural gas pipeline would affect all my neighbors, however, I agreed to allow a preliminary walk through my property and to hang surveyor ribbons in exchange for answering my questions about the project. For instance, one of my biggest concerns was the potential for significant habitat fragmentation, splitting up the forest and endangering wildlife habitat.

There are many questions residents should consider when approached by land agent. A list of these questions can be found in the appendix below.

I never did get answers to most of my questions in the few e-mail exchanges and phone conversations with EQT. I never saw the surveyors either. They simply came and left their telltale colored ribbons. Later, at a public meeting an EQT representative said the closest they would run the pipe to any residence would be 37.5 feet. That number is correct. I asked twice. They said they had the right to run a pipeline that close to a residence but would do their best not to. The 37.5 feet is just one half of the permanent RoW of 75 feet, which was also only part of a 125 foot RoW requested for construction. A few months later, a very short e-mail said that the final pipeline route had changed and they would not be on my property. For a time we would enjoy some peace and quiet.

A Word On Surveyors

Most folks can relate to the work and responsibility of bookkeepers or Certified Public Accountants (CPAs). They measure and keep track of money. And their balance sheets and ledgers actually have to, well, BALANCE. Think of Surveyors as the CPAs of the land world. When they go up a big hill and down the other side, the keep track of every inch — they will not tolerate losing a few inches here and there. They truly are professionals, measuring and documenting everything with precision. Most of the surveyors I have spoken with are courteous and respectful. They are a credit to their profession. They are aware of the eminent domain threat and their surveying success depends on treating landowners with respect. They are good at what they do. However, as this article will show, their professional success and precision depends on whether or not they are given the correct route to survey.

Part II: Surveyor Stakes and Flags

Over the next year we enjoyed peace and quiet with no more surveyors’ intrusions. However, in my regular travels throughout the natural gas fields here, countless signs of surveyor activity were visible. Even with the temporary slowdown in drilling, the proposed pipeline installations kept these surveyors busy. Assorted types of stakes and ribbons and markings are impossible to miss along our roads. I usually notice many of the newer surveyor’s flags and the normal wooden stakes used to mark out future well pads, access roads, compressor stations, and more recently pipelines. Given that survey markings are never taken down when no longer needed, the old ones sometimes hide the new ones.

It can be difficult keeping track of all of them and hard at first to identify why they are there. Even if sometimes I am not sure what a stake and flag might indicate, when one shows up very unexpectedly in what is essentially my front yard, it is impossible to not see it. That is what happened in August of 2015. Despite being unable to get our hay cut due to excessive rain the previous month, the colored flags were highly visible. Below shows one of the stakes with surveyor’s tape, and the hay driven down where the surveyors had parked their trucks in my field alongside my access road.

A surveyor stake alongside my access road.

A surveyor stake alongside my access road.

To call it trespassing might not be legally defensible yet. The stakes were, after all, near a public roadway – but the pins and stakes and flags were on my property. Incidents like this, whether intentional or accidental, are what have given the natural gas companies a reputation as bad neighbors. There were surveyors’ stakes and flags at two different locations, my hay was driven down, and I had no idea what all this meant given that I had no communication from anyone at EQT in over 18 months. I consider myself fortunate that the surveyors did not stray into wooded areas where trees might have been cut. It’s been known to happen.

Below shows the two sets of wooden stakes, roughly 70-80 feet apart, with flags and capped steel rebar pins. Both stakes were near the road’s gravel lane, which is a public right of way. Nevertheless, the stakes were clearly on my property. The markings on one side of the stake identify the latitude, longitude, and the elevation above sea level of the point. The other side of the stake identified it as locating the OVC pipeline (seen here as “OVC 6C):

These identifying numbers are unique to this pin which is used to denote a specific type of location called a “control point.” Control points are usually located off to the side of the center-line of the pipeline:

A control point, located off to the side of the center-line of the pipeline.

A control point, located off to the side of the center-line of the pipeline.

It seemed that somehow, without informing me or asking permission to be on my land, EQT had changed their mind on the OVC route and were again planning to run a pipeline through my property. If this was intentional, both EQT and I had a problem. If this was some kind of mistake, then only EQT would have a problem. Either way I could not fathom how this happened. Trespassing, real or perceived, is always a sensitive topic. This is especially true since, when I had initially allowed the surveyor to be on my property, I had not given permission for surveying. Given concerns about eminent domain, I wanted answers quickly. I documented all this with detailed pictures in preparation for contacting EQT representatives in Pittsburgh, PA, with my complaints.

Part III: What Happened & How?

I think it is safe to say that, in light of my well-known activism in documenting all things Marcellus, I am not your average surface owner. I have over 10,000 photographs of Marcellus operations in Wetzel County and I document every aspect of it. Frequently this leads to contacting many state agencies and gas operators directly about problems. I knew which gas company was responsible and I also knew exactly who in Pittsburgh to contact. To their credit, the person I contacted at EQT, immediately responded and it took most of the day to track down what had happen. The short story was that it was all a simple mistake—a 4,300 foot long mistake—but still just a mistake. The long story follows.

The EQT representative assured me that someone would be out to remove their stakes, flags and the steel pins. I told them that they needed to be prompt and that I would not alter or move their property and locating points. The next day, when I got home, the stakes with flags were gone. Just a small bare patch of dirt remained near the white plastic fencepost I had placed to mark the location. However, since I am a cultivated skeptic—adhering to the old Russian proverb made famous by President Reagan, “Trust but Verify”—I grabbed a garden trowel, dug around a bit, and clink, clink. The steel pin had just been driven deeper to look good, just waiting for my tiller to locate someday. I profusely re-painted the pin, photographed it, and proceeded to send another somewhat harsh e-mail to EQT. The pin was removed the next day.

After all the stakes, ribbons, and steel pins were removed, EQT provided further insights into what had transpired. Multiple pipeline routes were being evaluated by EQT in the area. Gas companies always consider a wide range of constraints to pipeline construction such as road and stream crossings, available access roads, permission and cooperation of the many landowners, steepness of terrain, etc. At a certain point in their evaluation, a final route was chosen. But for unknown reasons the surveyor crew was given the old, now abanoned, route on which to establish their control points. The magnitiude of the error can be seen on the map below. The bright blue line is the original path of the OVC pipeline through my property and the red line shows where the FERC filed pipeline route will go. A new control point has now been established near the highway where the pipeline was meant to cross.

The FERC filed OVC pipeline route vs. the accidentally surveyed route.

The FERC filed OVC pipeline route vs. the accidentally surveyed route.

 

Part IV: Lessons To Be Learned

Given the likely impact of many proposed large-diameter, very long, pipelines being planned, it seems useful to examine how these errors can happen. What can we learn from my personal experience with the hundreds of miles of new pipelines constructed in Wetzel County over the past eight years? First, it is important to ask whether or not similar problems are likely to happen elsewhere, or if this was this just an isolated incident. Can we realistically expect better planning on the proposed Mountain Valley Pipeline, which will run for over 300 miles? Can the residents and landowners living along these pipeline RoWs expect more responsible construction and management practices?

In general, many of the pipeline projects with which landowners, such as those in Wetzel County, are familiar with fall into the unregulated, gathering line category. They might be anywhere from six inches in diameter up to sixteen inches. As we review their track record, we have seen every imaginable problem, both during construction and after they were put into operation. We have had gas leaks and condensate spills, hillside mud slips, broken pipes, erosion and sedimentation both during construction and afterwards.

Now for some apparently contradictory assumptions—I am convinced that, for the most part, truck drivers, pipeliners, equipment operators, drilling and fracturing crews, well tenders and service personnel at well sites, all do the best job they can. If they are given the proper tools and materials, accurate directions with trained and experienced supervision, the support resources and the time to do a good job, then they will complete their tasks consistently and proudly. A majority of employees in these positions are dedicated, trained, competent, and hard working. Of course, there are no perfect contractors out there. These guys are human too. And on the midnight shift, we all get tired. In the context of this story, some pipeline contractors are better and more professional than others, some are more experienced, and some have done the larger pipelines. Therefore, despite best intentions, significant errors and accidents will still occur.

The Inherent Contradictions

It seems to me that the fragile link in natural gas production and pipeline projects is simply the weakness of any large organization’s inherent business model. Every organization needs to constantly focus on what I refer to as the “four C’s—Command and Control, then Coordination and Communication—if they are to be at all successful. It is a challenge to manage these on a daily basis even when everyone is in the same big building, working for the same company, speaking the same language. This might be in a university, or a large medical complex, or an industrial manufacturing plant.

But the four C’s are nearly impossible to manage due to the simple fact that the organizational structure of the natural gas industry depends completely on hundreds of sub-contractors. And those companies, in turn, depend on a sprawling and transient, expanding and collapsing, network of hundreds of other diverse and divergent independent contractors. For example, on any given well pad, during the drilling or fracturing process, there might be a few “company” men on site. Those few guys actually work for the gas company in whose name the operating permit is drawn. Everyone else is working for another company, on site temporarily until they are ready to move on, and their loyalty is elsewhere.

In the best of situations, it is next to impossible to get the right piece of information to the right person at just the right time. Effective coordination among company men and contractors is also next to impossible. I have seen this, and listened in, when the drilling company is using one CB radio channel and the nearby pipeline company is using some private business band radio to talk to “their people.” In that case, the pipeline contractors could not talk to the well pad—and it did not matter to them. In other cases, the pilot vehicle drivers will unilaterally decide to use another CB radio channel and not tell everyone. I have also watched while a massive drill rig relocation was significantly delayed simply because a nearby new gas processing plant was simultaneously running at least a hundred dump trucks with gravel on the same narrow roadway. Constant communication is a basic requirement for traffic coordination, but next to impossible to do properly and consistently when these practices are so prevalent.

These examples illustrate how companies are often unable to coordinate their operations. Now, if you can, just try to picture this abysmal lack of command and control, and minimal communication and coordination, in the context of building a 300-mile length of pipeline. The larger the pipeline diameter, and the greater the overall length of the pipeline, the more contractors will be needed. With more contractors and sub-contractors, the more coordination and communication are essential. A FERC permit cannot fix this, nor would having a dozen FERC permits. Unfortunately, I do not envision the four Cs improving anytime soon in the natural gas industry. It seems to be the nature of the beast. If, as I know from personal experience, a major gas company can arrange to locate a surveyed control point 4,300 feet from where it should have been, then good luck with a 300 mile pipeline. Even with well-intentioned, trained employees, massive problems are still sure to come.

The FERC approvals for these pipelines might not be a done deal, but I would not bet against them. So vigilance and preparation will still be of the essence. Citizen groups must be prepared to observe, monitor, and document these projects as they unfold. If massive pipelines like the MVP and OVC are ever built, they should become the most photographed, measured, scrutinized, and documented public works projects since the aqueducts first delivered water to ancient Rome. For the sake of protecting the people and environment of Wetzel County and similar communities, I hope this is the case.

By Bill Hughes, WV Community Liaison, FracTracker Alliance
Read more Field Diary articles.

Appendix: Questions to Ask When Approached by a Land Agent (Landsman)

These questions can be modified to suit your location. The abbreviation “Gas Corp.” is used below to reference a typical natural gas company or a pipeline subsidiary to a natural gas company.  These subsidiaries are frequently called Midstream Companies. Midstream companies build and manage the pipelines, gas processing, and some compressor stations on behalf of natural gas companies.

  1. Please provide a Plain English translation of your landowner initial contract.
  2. What will Gas Corp. be allowed to do, and not allowed to do, short term and long term?
  3. What will Gas Corp. be required to do, and not required to do?
  4. What is the absolute minimum distance this pipeline will be placed away from any dwelling anywhere along its entire length?
  5. What restrictions will there be on the my land after you put in the pipelines?
  6. Who will be overseeing and enforcing any environmental restrictions (erosion and sedimentation, slips, stream crossings, etc.)?
  7.  Who will be responsible for my access road upkeep?
  8. Who will be responsible for long term slips and settlements of surface?
  9. When would this construction begin?
  10. When would all work be completed?
  11. Who would be responsible for long term stability of my land?
  12. Will the pipeline contractor(s) be bound to any of our agreements?
  13. Who are the pipeline contractor(s)?
  14. What will be transported in the pipeline?
  15. Will there be more than one pipe buried?
  16. How wide is the temporary work RoW?
  17. How wide is the permanent RoW?
  18. How deep will the pipeline(s) be buried?
  19. What size pipe will it be; what wall  thickness?
  20. How often will the welds on the individual pipe segments be inspected?
  21. Will there be any above ground pipeline components left visible?
  22. Where will the pipe(s) originate and where will they be going to?
  23. What will the average operating pressure be?
  24. What will the absolute maximum pressure ever be?
  25. At this pressure and diameter, what is the PIR—Potential Impact Radius?
  26. Will all pipeline and excavating and laying equipment be brought in clean and totally free from any invasive species?
  27. How will the disturbed soil be reclaimed?
  28. Will all top soil be kept separate and replaced after pipeline is buried?
  29. Also, After all the above is settled, how much will I be paid per linear foot of pipeline?
Bird’s eye view of a sand mine in Wisconsin. Photo by Ted Auch 2013.

West Central Wisconsin’s Landscape and What Silica Sand Mining Has Done to It

By Ted Auch, Great Lakes Program Coordinator, and Elliott Kurtz, GIS Intern

The Great Lakes may see a major increase in the number of sand mines developed in the name of fracking. What impacts has the area already seen, and does future development mean for the region’s ecosystem and land use?

Introduction

Sand is a necessary component of today’s oil and gas extraction industry for use in propping open the cracks that fracking creates. Silica sand is a highly sought after proppant for this purpose and often found in Wisconsin and Michigan. At the present time here in Ohio our Utica laterals are averaging 4,300-5,000 tons of silica sand or “proppant” with demand increasing by 85+ tons per lateral per quarter.

Wisconsin’s 125+ silica sand mines and processing facilities are spread out across 15,739 square miles of the state’s West Central region, adjacent to the Minnesota border in the Northern Mississippi Valley. These mines have dramatically altered the landscape while generating proppant for the shale gas industry; approximately 2.5 million tons of sand are extracted per mine. The length of the average shale gas lateral well grows by > 50 feet per quarter, so we expect silica sand usage will grow from 5,500 tons to > 8,000 tons per lateral. To meet this increase in demand, additional mines are being proposed near the Great Lakes.

Migration of the sand industry from the Southwest to the Great Lakes in search of this silica sand has had a large impact on regional ecosystem productivity and watershed resilience[1]. The land in the Great Lakes region is more productive, from a soil and biomass perspective; much of the Southwest sandstone geology is dominated by scrublands that have accrue plant biomass at much slower rates, while the Great Lakes host productive forests and agricultural land. Great Lakes ecosystems produce 1.92 times more soil organic matter and 1.46 times more perennial biomass than Southwestern ecosystems.

Effects on the Great Lakes

Quantifying what the landscape looks like now will serve as a baseline for understanding how the silica sand industry will have altered the overall landscape, much like Appalachia is doing today in the aftermath of strip-mining and Mountaintop Removal Mining[2]. West Central Wisconsin (WCW) has a chance to learn from the admittedly short-cited and myopic mistakes of their brethren across the coalfields of Appalachia.

Herein we aim to present numbers speaking to the diversity and distribution of WCW’s “working landscape” across eight types of land-cover. We will then present numbers speaking to how the silica mining industry has altered the region to date and what these numbers mean for reclamation. The folks at UC Berkeley’s Department of Environmental Science, Policy , and Management describe “Working Landscapes” as follows:

a broad term that expresses the goal of fostering landscapes where production of market goods and ecosystem services is mutually reinforcing. It means working with people as partners to create landscapes and ecosystems that benefit humanity and the planet… A goal is finding management and policy synergies—practices and policies that enhance production of multiple ecosystem services as well as goods for the market…Collaborative management processes can help discover synergies and create better decisions and policy. Incentives can help private landowners support management that benefits society.

Methods

We used the 1993 WISCLAND satellite imagery to determine how WCW’s landscape is partitioned and then we applied these data to an updated inventory of silica sand mine boundaries to determine what existed within their boundaries prior to mining. The point locations of Wisconsin’s current inventory of silica sand mines was determined using the “Geocode Address” function in ArcMap 10.2 using the Composite_US Address Locator. Addresses were drawn from mine inventory information originally maintained by the West Central WI Regional Planning Commission (WCWRPC) and now managed by the WI Department of Natural Resources’ Mines, pits and quarries division. Meanwhile current mine extent boundary polygons were determined using one of three satellite data-sets:

  1. 2013 imagery from the USDA National Agriculture Imagery Program (NAIP),
  2. 2014 ArcMap 10.2 World Imagery, and
  3. 2014 Google Satellite.

What We Found

Land Cover Types Replaced by Silica Sand Mining

Sand-LandEffects

Fig 1. Square mileage of various land cover types replaced by silica sand mining in WCW

Thirty-nine percent of the WCW landscape is currently allocated to forests, 43% to agriculture broadly speaking, and 13% is occupied by various types of wetlands. Open waters occupy 2.6% of the landscape with tertiary uses including barren lands (1.3%), golf courses (0.03%), high and low-density urban areas (0.9%), and miscellaneous shrublands (0.6%) (See Figure 1).

Effects by Land Cover Type

Figure 2. Forest Cover in WCW

Fig 2. Forest Cover in WCW

Figure 3. Agricultural Cover

Fig 3. Agricultural Cover

Figure 4. Open Water & Wetland Cover

Fig 4. Open Water & Wetland Cover

Figure 5. Forested Wetland Cover

Fig 5. Forested Wetland Cover

Figure 6. Lowland Shrub Wetland Cover

Fig 6. Lowland Shrub Wetlands

Figure 7. Miscellaneous Cover

Fig 7. Miscellaneous Cover

Figure 2. The wood in these forests has a current stumpage value of $253-936 million and by way of photosynthesis accumulates 63 to 131 million tons of CO2 and has accumulated 4.8-9.8 billion tons of CO2 if we assumed that on average forests in this region are 65-85 years old. Putting a finer point on WCW forest cover and associated quantifiables is difficult because most of these tracts (2.7 million acres) fall within a catchall category called “Mixed Forest”. Pine (2.3% of the region), Aspen (4.7%), and Oak (3.8%) most of the remaining 1.2 million forested acres with much less sugar (Acer saccharum) and soft (Acer rubrum) maple acreage than we expected scattered in a horseshoe fashion across the Northeastern portion of the study area.

Figure 3. Seven different agricultural land-uses occupy 4.3 million WCW acres with forage crops and grasslands constituting 29% of the region followed by 1.4 million acres of row crops and miscellaneous agricultural activities. Additionally, 2% of WI’s 19,700 cranberry bog acres are within the study area generating $4.02 million worth of cranberries per year. The larger agricultural categories generate $3.2 billion worth of commodities.

Figure 4. Nearly 16% of WCW is characterized by open waters or various types of wetlands with a total area of 2,396 square miles clustered primarily in two Northeast and one Southeast segment. Open waters occupy 398 square miles with forested wetlands – possibly vernal pool-type systems – amounting to 5.4% of the region or 841 square miles. Lowland shrub and emergent/wet meadows occupy 540 and 618 square miles, respectively.

Figure 5. Of the nine types of wetlands present in this region the forested broad-leaved deciduous and emergent/wet meadow variety constitute the largest fraction of the region at 1,107 square miles (7.1% of region). Some percentage of the former would likely be defined by Wisconsin DNR as vernal pools, which do the following according to their Ephemeral Pond program. The WI DNR doesn’t include silica sand mining in its list of 14 threats to vernal pools or potential conservation actions, however.

These ponds are depressions with impeded drainage (usually in forest landscapes), that hold water for a period of time following snowmelt and spring rains but typically dry out by mid-summer…They flourish with productivity during their brief existence and provide critical breeding habitat for certain invertebrates, as well as for many amphibians such as wood frogs and salamanders. They also provide feeding, resting and breeding habitat for songbirds and a source of food for many mammals. Ephemeral ponds contribute in many ways to the biodiversity of a woodlot, forest stand and the larger landscape…they all broadly fit into a community context by the following attributes: their placement in woodlands, isolation, small size, hydrology, length of time they hold water, and composition of the biological community (lacking fish as permanent predators).

Figure 6. Broad-leaved evergreen lowland shrub wetlands constitute ≈2.1% of the region or 319 square miles with most occurring around the Legacy Boggs silica mines and several cranberry operations turned silica mines in Jackson County. Meanwhile broad-leaved deciduous and needle-leaved lowland shrub wetlands are largely outside the current extent of silica sand mining in the region occupying 1.9% of the region with 293 square miles spread out within the northeastern 1/5th of the study area.

Figure 7. Finally, miscellaneous land-covers include 200 square miles of barren land, 145 square miles of low/high intensity urban areas including the cities of Eau Claire (Pop. 67,545) and Stevens Point (Pop. 26,670) as well as towns like Marshfield, Wisconsin Rapids, Merrill, and Rib Mountain-Weston. WCW also hosts 3,204 acres (0.03% of region) worth of golf courses which amounts to roughly 21 courses assuming the average course is 157 acres. Shrublands broadly defined occur throughout 0.6% of the region scattered throughout the southeast corner and north-central sixth of the region, with the both amalgamations poised to experience significant replacement or alteration as they are adjacent to two large silica mine groupings.

Producing Mine Land-Use/Land-Cover Change

To date we have established the current extent of land-use/land-cover change associated with 25 producing silica mines occupying 12 square miles of WCW. These mines have displaced 3 square miles of forests and 7 square miles of agricultural land-cover. These forested tracts accumulated 31,446-64,610 tons of CO2 per year or 2.4-4.9 million tons over the average lifespan of a typical Wisconsin forest. These values equate to the emissions of 144,401-295,956 Wisconsinites or 2.5-5.1% of the state’s population. The annual wood that was once generated on these parcels would have had a market value of $126,097-197,084 per year. Meanwhile the above agricultural lands would be generating roughly $1.5-3.3 million in commodities if they had not been displaced.

However, putting aside measurable market valuations it turns out the most concerning result of this analysis is that these mines have displaces 871 acres of wetlands which equals 11% of all mined lands. This alteration includes 158 acres of formerly forested wetlands, 352 acres of lowland shrub wetlands, and 361 acres of emergent/wet meadows. As we mentioned previously, the chance that these wetlands will be reconstituted to support their original plant and animal assemblages is doubtful.

We know that the St. Peter Sandstone formation is the primary target of the silica sand industry with respect to providing proppant for the shale gas industry. We also know that this formation extend across seven states and approximately 8,884 square miles, with all 91 square miles overlain by wetlands in Wisconsin. To this end carbon-rich grasslands soils or Mollisols, which we discussed earlier, sit atop 36% of the St. Peter Sandstone and given that these soils are alread endangered from past agricultural practices as well as current O&G exploration this is just another example of how soils stand to be dramatically altered by the full extent of the North American Hydrocarbon Industrial Complex. The following IFs would undoubtedly have a dramatic effect on the ability of the ecosystems overlying the St. Peter Sandstone to capture and store CO2 to the extent that they are today not to mention dramatically alter the landscape’s ability to capture, store, and purify precipitation inputs.

  • IF silica sand mining continues at the rate it is on currently
  • IF reclamation continues to result in “very poor stand of grass with some woody plants of very poor quality and little value on the whole for wildlife. Some areas may be reclaimed as crop land, however it is our opinion that substantial inputs such as commercial fertilizer as well as irrigation will be required in most if not all cases in order to produce an average crop.”
  • IF the highly productive temperate forests described above are not reassembled on similar acreage to their extent prior to mining and reclamation is largely to the very poor stands of grass mentione above
    • For example: Great Lakes forests like the ones sitting atop the St. Peter Sandstone capture 20.9 tons of CO2 per acre per year Vs their likely grass/scrublands replacement which capture 10.6-12.8 tons of CO2 per acre per year… You do the math!
  • “None two sites are capable of supporting the growing of food. They grow trees and some cover grass, but that is all. General scientific research says that the reclaimed soils lose up to 75% of their agricultural productivity.”

Quote from a concerned citizen:

I often wonder what it was like before the boom, before fortunes were built on castles of sand and resultant moonscapes stretched as far as the eye could see. In the past few years alone, the nickname the “Silica Sand Capital of the World” has become a curse rather than a blessing for the citizens of LaSalle County, Illinois. Here, the frac sand industry continues to proliferate and threaten thewellbeing of our people and rural ecosystem.

Additional Testimonials

References & Resources

  1. The US Forest Service defined Watershed Resilience as “Over time, all watersheds experience a variety of disturbance events such as fires and floods [and mining]. Resilient watersheds have the ability to recover promptly from such events and even be renewed by them. Much as treating forests can make them more resilient to wildfire, watershed restoration projects can improve watershed resilience to both natural and human disturbances.”
  2. Great example: Virginia Tech’s Powell River Project
Bird’s eye view of a sand mine in Wisconsin. Photo by Ted Auch 2013.

Quick Sand: Frack Sand Mining in Wisconsin

Each silica sand mine displaces 871 acres of wetlands and more than 12 square miles of forests and agriculture land in Wisconsin to provide the shale gas industry with fracking proppant.

By Juliana Henao, Communications Intern

Silica sand is used by the oil and gas industry as a way to prop open the fractures made during fracking – and is also referred to as a proppant. The industry’s demand for silica sand is steadily increasing (i.e., 4-5K tons per shale lateral, +86 tons per lateral per quarter), directly affecting the Great Lakes, their ecosystems, and land use. Silica sand is often found in Wisconsin and Michigan, which have felt the effects of increased sand mining demands through altered landscapes, impacted ecosystem productivity, and altering watershed resilience; these impacts will only continue to increase as the demand for silica sand increases.

To better understand frack sand mining’s current and potential effects, FracTracker’s Ted Auch and intern Elliott Kurtz, with generous support from the Save The Hills Alliance, explored mining and land use changes data in West Central Wisconsin (WCW). In their research paper, Auch and Kurtz show the current and future environmental impacts of increased sand mining in WCW in order to supply the oil and gas industry with sand. Not only does this research illustrate what is at risk in the WCW landscape, it also showcases what sand mining has already done to the region.

Key Frack Sand Mining Findings

Land alterations due to silica sand mining in WI

Sixteen percent, or 2,396 square miles, of the West Central Wisconsin (WCW) is made up of wetlands or open waters. These and the other existing WCW landscapes are unquestionably profitable. The forests buffer climate change impacts – to date accumulating between 4.8-9.8 billion tons of CO2 assuming they are 65-85 years old – and have a current stumpage value of $253-936 million.

The 25 producing silica mines in this region occupy 12 square miles of WCW and have already displaced:

  • 3 mi2 of forests
  • 7 mi2 of agricultural land-cover
  • 1.36 mi2 of wetlands (equal to 11% of all mined lands)
    Formerly, these wetlands were one of three types:

    • 18% (158 acres) forested wetlands
    • 41% (353 acres) lowland shrub wetlands, and
    • 41% (361 acres) emergent/wet meadows
Breakdown of the current landscape types near these expanding mines, based on an analysis of satellite imagery

Breakdown of the current landscape types near these expanding mines, based on an analysis of satellite imagery

Why Wisconsin?

There are more than 125 silica sand mines throughout WCW, a stretch of ~16,000 square miles. Previously, the mining industry focused their efforts in Oklahoma and Texas’s Riley, Hickory/Brady, and Old Creek formations, where the land is not as agriculturally or ecologically productive as WCW. Now, more and more mines are being proposed and built in the WCW region. We wanted to determine what this change would mean for such an ecosystem diverse area of Wisconsin – many of which are considered “globally imperiled” or “globally rare” including oak savanna, dry prairies, southern dry-mesic forests, pine barrens, moist cliffs and oak openings.

The St. Peter Sandstone – along with the early Devonian and much smaller Sylvania Sandstone in Southeastern Michigan – is the primary target of the silica sand industry. Carbon-rich grassland soils cover 36% of the St. Peter, where they aid the ecosystem by capturing and sorting 20.9 tons of CO2 per year, as well as purifying precipitation inputs. This ecosystem, amongst many others around sand mining activities, will be dramatically altered if silica sand mining continues at its increasing rate. We will see CO2 capturing levels drop from 20.9 tons to 10.6 tons per acre per year if the highly productive temperate forests are not reassembled and reclaimed to their original acreage, as well as a significant loss (75%) in agricultural productivity on sites that are not reclaimed properly.

Out-of-state mining companies are settling into Wisconsin and displacing the land at a very high rate. As the president of Iowa’s Allamakee County Protectors Ric Zarwell told us by email “Frac sand mining companies do not come from the area where I live.  So efforts to destroy landscapes for frac sand are going to involve Neighbors Opposing Invaders.”

A high demand in silica sand from the shale gas industry will continue to drive this influx of mining companies into WI, providing a potentially collapsed ecosystem in the future. Factors at play include additional – and often much larger – mines under consideration, the average shale gas lateral grows by > 50 feet per quarter, and silica sand usage will grow from 5,500 tons to > 8,000 tons per lateral (i.e., 85 tons per quarter per lateral). Auch and Kurtz’s research paper describes in detail where how much silica sand might be needed in the future, as well as a detailed set of maps depicting land cover and usage in WI.