By Isabelle Weber, FracTracker Alliance Spring 2019 Intern
Feature photo of oil and gas drilling in North Dakota, and is by by Nick Lund, NPCA, 2014
Although there are some federal regulations in place to protect the environment indirectly from fracking in the United States, the regulations that try to keep fracking in check are largely implemented at the state governing level. This has led to a patchwork of regulations that differ in strictness from state to state. This leads to the concern that there will be a race to the bottom where states lower the strictness of their regulations in order to draw in more fracking. While it might be tempting to welcome an industry that often creates a temporary economic spike, the costs of mitigating the environmental damage from fracking far out-weighs the profit gained. Germany, Scotland, and France are examples of countries that have taken more appropriate regulatory measures to protect their populations from the risks involved in unconventional oil and gas development.
The Shortfalls of State by State Regulations
For a detailed overview of how fracking regulation differs between states, check out the Resources for the Future report, The State of State Shale Gas Regulation, which analyzes 25 regulatory elements and how they differ between states. Two of their maps that attest to this vast difference in regulation are the “Fracturing Fluid Disclosure Requirements” map as well as the “Venting Regulations” map.
The “Fracturing Fluid Disclosure Requirements” map shows regulatory differences between states regarding whether or not the chemical mixture used to break up rock formations must be made known to the public. “Disclosure” means that the chemical mixture is made known to the public and “No Regulation” means that there is nothing that obligates companies to share this information, which usually implies this information is not available.
Fig 1. Map of fracking fluid disclosure requirements by state, from Resources for the Future’s report, “The State of State Shale Gas Regulation.” Original data from US Energy Information Administration.
Note from the editor: There are several exemptions that allow states to limit the scope of reporting chemicals used in underground fluid injection for fracking. For example, all states that require chemical disclosure are entitled to exemptions for chemicals that are considered trade secrets.
Concealing the identity of chemicals increases the risk of harm from chemical exposure for people and the environment. Emergency first responders are especially at risk, as they may have to act quickly to put out a fracking-induced fire without knowing the safety measures necessary to avoid exposure to dangerous chemicals. The population at large is at risk of exposure though several pathways such as leaks, spills, and air emissions. Partnership for Policy Integrity, along with data analysis by FracTracker, investigated the implications of keeping the identity of certain fracking chemicals secret in two states, Ohio and Pennsylvania. These reports point to evidence that exposure to concealed fracking chemicals could have serious health effects including blood toxicity, developmental toxicity, liver toxicity and neurotoxicity.
The second map, “Venting Regulations,” shows which states have regulations that limit or ban venting and which do not. Venting is the direct release of methane from the well site into the atmosphere. Methane has 30 times the green-house gas effect as carbon dioxide. Given methane’s severe impact on the environment, no venting whatsoever should be allowed at well sites.
Fig 2. Map of fracking venting regulations by state, from Resources for the Future’s report, “The State of State Shale Gas Regulation.” Original data from US Energy Information Administration.
Having overarching federal regulatory infrastructure to regulate fracking would help to avoid risks such as toxic chemical exposure and accelerated climate change. Although leaving regulation development to states allows for more specialized laws, there are certain aspects of environmental protection that apply to every area in the United States and are necessary as standard protection against the effects of fracking.
How do other countries regulate fracking?
Stronger federal regulation of fracking has worked well in the past and can be seen in several other countries.
In 2017, Germany passed new legislation that largely banned unconventional hydraulic fracking. The ban on unconventional fracking excludes four experimental wells per state that will be commissioned by the German government to an independent expert commission to identify knowledge gaps and risks with regards to fracking. Conventional fracking also received tighter regulations including a ban on fracking near drinking water sources. In 2021, the ban will be reevaluated, taking into account research results, public perception, long term damage to residents and the environment, and technological advances. This is a perfect example of how a country can use overarching federal regulation to make informed decisions about industry action.
In 2015, Scotland placed a moratorium into effect that halted all fracking in the country. Since 2017, the government has held that the moratorium will stand indefinitely as an effective ban on fracking in the country, but the country is still working on the legislature that will officially ban fracking. Meanwhile, the Scottish government conducted one of the most far-reaching investigations into unconventional oil and gas development, which included a four-month public consultation period. This public consultation garnered 65,000 responses, 65% of which were from former coal mining communities targeted by the fracking industry. Of those responses, 99% of responses opposed fracking.
The Scottish people should be applauded for holding their federal government accountable in fulfilling its responsibility to protect its people and its environment against the effects of fracking.
In December 2017, France passed a law that bans exploration and production of all oil and natural gas by the year 2040. This applies to mainland France as well as all French territories. Although France has limited natural gas resources, it is hoped that the ban will be contagious and spread to other countries. This is a prime example of a country making a decision to protect their environment through regulation.
Although France’s banning of fracking was largely symbolic and may not result in a considerable reduction of greenhouse gases related to natural gas exploration, the country is sending a message to the world that we need to facilitate the end of the fossil fuel era and a move toward renewables.
Back to the US, the world’s leading producer of natural gas
Federal regulation on fracking should be holding the oil and gas industry in check by requiring states to meet basic measures to protect people and the environment. States could then develop more stringent regulations as they see fit. It is important that we come to a national consensus on the environmental and health hazards of fracking, and consequently, to adopt appropriate federal regulations.
By Isabelle Weber, FracTracker Alliance Spring 2019 Intern
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/10/Oil-and-gas-drilling-in-ND.-Photo-by-Nick-Lund-NPCA-2014-feature-scaled.jpg6671500Intern FracTrackerhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngIntern FracTracker2019-10-10 11:50:142021-04-28 11:55:45How State Regulations Hold Us back and What Other Countries are doing about Fracking
Records Show Widespread Use of Secret Fracking Chemicals Poses Risks to Water Supplies, Health in the Buckeye State
A Research Report by Dusty Horwitt, J.D.
Partnership for Policy Integrity
September 16, 2019
This report, by Partnership for Policy Integrity, with mapping and data analysis by FracTracker Alliance, shows that Ohioans may be unknowingly exposed to toxic secret drilling and fracking chemicals through multiple pathways including leaks, spills, air emissions and underground migration at oil and gas production wells.
Evidence compiled by the U.S. Environmental Protection Agency (EPA) including data released in response to a Freedom of Information Act request indicate that these chemicals could have serious health effects including blood toxicity, developmental toxicity, liver toxicity and neurotoxicity.
On this page, you can read the report and use the interactive map to locate oil and gas wells fracked with secret chemicals.
average number of gallons used to frack a single well (2018)
fish died after tens of thousands of gallons of chemicals spilled into a tributary from a natural gas well in Monroe County (2014)
If you are concerned about the findings presented in the Ohio’s Secret Fracking Chemicals report, please consider taking action today. Multiple first responders, and grassroots organizations working on environmental and public health issues in Ohio ask that you complete the form below to send a letter to first responders in your county. If you do not live in Ohio, your letter will be sent to first responders Franklin County, Ohio.
Halt the Harm Network and FracTracker Alliance will send a paper copy of your letter to the appropriate first responder location(s). See below for a map of these locations by Ohio county.
You may compose your own letter or use the example letter below as a guide.
If you are concerned about the findings presented in the Ohio’s Secret Fracking Chemicals report, please consider taking action today. Multiple first responders, and grassroots organizations working on environmental and public health issues in Ohio ask that you complete the form below to send a letter to first responders in your county. If you do not live in Ohio, your letter will be sent to first responders in Franklin County, Ohio.
Halt the Harm Network and FracTracker Alliance will send a paper copy of your letter to the appropriate first responder location(s). See below for a map of these locations by Ohio county.
You may compose your own letter or use the example letter below as a guide.
Thanks to you and all first responders for your selfless acts of service. I am reaching out because I am concerned that there are dangerous chemicals being used at fracking sites in our county and across the county. Because the identity of many of these chemicals are kept secret, any spills or accidents present a significant risk to you as a first responder as well as to the public.
The report “Ohio’s Secret Fracking Chemicals” provides research about secret fracking chemicals and maps of oil and gas wells where secret fracking chemicals were used. The report’s author also interviewed Silverio Caggiano, Battalion Chief with the Youngstown Fire Department and an original member of the Ohio Hazardous Materials and Weapons of Mass Destruction Technical Advisory Committee. The Chief, the data, and the stories paint a clear picture of Ohio’s exposure to a mix of dangerous chemicals, lack of equipment, lack of training, and inadequate information. This failure by the State and other authorities creates risks for your first responders and all of us in the community.
Please join us in the fight against secret chemicals in our community by calling for the following measures to be put in place:
Require full public disclosure of drilling and fracking chemicals in one location where information can be easily searched and sorted (e.g. citizens can locate each well in which toxic chemicals were used).
Require disclosure before drilling and fracking occurs.
Require that no Class II wells for underground fracking wastewater disposal be permitted in Ohio unless disposal companies report all of the following in their permit requests: A) Average and Maximum Volumes, B) Average and Maximum wellhead pressures, C) Groundwater/water source and rate of withdrawal, D) Egress
Require testing of groundwater and well water for a representative number of homes within 2 miles of oil and gas wells and underground injection wells by impartial third parties to guard against migration of toxic chemicals. Data should be collected monthly.
Grant communities the power to determine where, and under what conditions, drilling and fracking occur.
Demand companies that operate underground fracking wastewater injection wells pay for independent third parties to conduct groundwater monitoring and data collection about health impacts.
Require that all haulers transporting fracking wastewater, also known as brine, permitted to operate in Ohio maintain complete manifests for every truck and maintain GPS tracking for all routes into and out of the state as well as across state lines.
Require all brine haulers report the number of trucks in operation and how they go about cleaning each truck on a quarterly basis.
Require that all brine haulers list where they maintain truck yards in addition to where they are domiciled.
Require that all waste landfills in Ohio collect detailed manifest on tonnage of drill cuttings coming into their facilities, source by company and well API, and that all waste be tested for radioactivity level that the level shall not exceed 1-2 picocuries per gram.
You have my full support in requests for this information. It is important to all of us. Please let me know if you have seen the report, reviewed the chemicals, and have appropriate response, training, and equipment in place.
By signing, you accept Halt the Harm Network’s Terms of Service and agree to receive occasional emails following up on your letter, about Ohio fracking, and related public health campaigns. Your information will never be sold. You can unsubscribe at any time.
[i] U.S. Environmental Protection Agency. On Scene Coordinator. Eisenbarth Well Response. Fire Damage on Eisenbarth Well Pad (June 29, 2014). Accessed September 2, 2019 at https://response.epa.gov/site/image_zoom.aspx?site_id=9350&counter=221854&category=.
The Mountaineer State is one of the most stunningly beautiful states in all the United States, despite its complicated and unique relationship with fossil fuels dating back to the West Virginia Coal Wars of 1912 to 1921. This relationship has compromised the state’s distinctive ecosystems and its social cohesion. Instead of remediating or preventing the impacts of fossil fuels, the state’s elected officials have exploited them for political and monetary gain. Understanding this history and the potential next steps in the march of the fossil fuel industry will help those who continue to fight for an alternative future for West Virginia. At the same time, it is critical that we identify legislation that would perpetuate fossil fuel dependence, the individuals who are behind said legislation, and the current extent of the fossil fuel industry, especially considering the developing Appalachian Storage and Trading Hub (ASTH) that is supported by the elected officials in in D.C. and Charleston.
Ohio Power’s Mitchell (Foreground) and Kammer (Background) Coal Power Plants, Marshall County, Combined Capacity 2,345 MegaWatts. Photo by Ted Auch, aerial assistance provided by LightHawk
Impeding Fossil Fuel Developments Threaten West Virginia Once Again
West Virginia has a rich, complicated, and occasionally violent history with coal mining and now is at the vanguard of the High Volume Hydraulic Fracturing (HVHF) revolution. It also happens to sit at the heart of what Appalachian governors, senators, and even land-grant universities are touting is the panacea for all that ails the region: the Appalachian Storage and Trading Hub (ASTH), a key part of the Ohio River Valley petrochemical build out. This puts West Virginia in a peculiar position, with one foot longingly in the past with coal mining and one moving forward with investments in fracking and now the ASTH.
Murray Energy’s Consolidation Coal Mine, Marshall County
This is not to suggest that there are hard feelings between Trump and Murray; a Document Investigations publication reveals an invitation from Murray Energy to host a Trump fundraiser on July 24, 2019 in Wheeling, West Virginia at WesBanco Arena with a cover charge of $150.00 made payable to Trump Victory, Donald Trump and the Republican National Committee’s joint presidential campaign fundraising. West Virginia Governor Jim Justice (who is uncoincidentally a leading booster of the ASTH) indicated he would be in attendance. Additionally, Murray in his rescheduling letter to the West Virginia governor indicated, “Present with us will be Governors Mike DeWine of Ohio, Jim Justice of West Virginia, and Matt Bevins of Kentucky; Senators Shelley Moore Capito and Rob Portman of these states; and Congressman Bill Johnson and Dave McKinley and the House Speaker and Senate President form the two states.”
Declining Jobs, Increasing Automation
After at least seventeen years of 5% declines in net coal production, and 3% increases in hiring, the coal mining industry in West Virginia had had enough. Starting in 2012, they turned the tide on labor by leaning into the automation revolution and in the process, mine labor has declined by 8% per year since then. Automation and an increasing reliance on more blunt methods of mining, including strip-mining and/or Mountaintop Removal, have allowed the mining industry to increase productivity per labor hour by 5.8% to 6.3% per year since 2012, according to data compiled by US Department of Labor’s Office of Mine Safety and Health Administration. All of these savings translate into Mergers And Acquisitions as well as hefty profits for the likes of Murray, private equity and large institutional investors that have no interest in the welfare of Appalachia, its people, and the constant undertone of labor vs. capital throughout the region.
Even with all the corporate, state, and federal subsidies we have still had a rash of bankruptcies in the last three months. Most recently, Revelation Energy and its affiliate Blackjewel, experts in “Vulture Capitalism,” filed for Chapter 11 on July 1st of this year causing countless bounced paychecks among their 1,700 employees across Virginia, Wyoming, Kentucky, and West Virginia.
So while King Coal continues to paint federal regulations as excessively burdensome and the primary impediment to their expansion, it is clear that the enemy of coal miners is not regulations, but rather automation and the urgent attempt to squeeze every last drop of profitability out of a dying industry. even as coal production nationally declines by nearly double digits annually, a signal that the end is near, mining companies are able to continue generating reliable profits thanks to automation and artificial intelligence. This might be why private equity climate change denying titans like Stephen Schwarzman are investing so heavily in the likes of MIT’s School of Artificial Intelligence. The growing discrepancy between coal production and coal jobs was pointed out in a recent Columbia University report on the failure of states, counties, and communities to prepare themselves for the day when their status as “company towns” will switch from a point of pride to a curse. The Columbia researchers pointed out that:
“Employment in the coal mining industry declined by over 50 percent in West Virginia, Ohio, and Kentucky between 2011 and 2016. State-level impacts mask even more severe effects at local levels. In Mingo County, West Virginia, coal mining employed over 1,400 people at the end of 2011. By the end of 2016, that number had fallen below 500. Countywide, employment fell from 8,513 to 4,878 over this period . . . suggesting there could be important labor market spillovers from mining to the broader economy.”
A Bloody History Haunts West Virginia’s Coal Fields
The last time West Virginia experienced “important labor market spillovers” was during the West Virginia Coal Wars of 1912 to 1921. West Virginia University Press, in summarizing the book “Life, Work, and Rebellion in the Coal Fields: The Southern West Virginia Miners, 1880-1922” by David Alan Corbin, describes this violent moment in the state’s history:
“Between 1880 and 1922, the coal fields of southern West Virginia witnessed two bloody and protracted strikes, the formation of two competing unions, and the largest armed conflict in American labor history – a week-long battle between 20,000 coal miners and 5,000 state police, deputy sheriffs, and mine guards. These events resulted in an untold number of deaths, indictments of over 550 coal miners for insurrection and treason, and four declarations of martial law. Corbin argues that these violent events were collective and militant acts of aggression interconnected and conditioned by decades of oppression. His study goes a long way toward breaking down the old stereotypes of Appalachian and coal-mining culture”
The Coal Wars culminated in the August 1921 Battle of Blair Mountain, the largest labor uprising in United States history which resulted in a deadly standoff between 10,000 armed coal miners and 3,000 strikebreakers called the Logan Defenders. The battle resulted in a casualty range of 20 to 100 as well as the treason conviction of some 22+ United Mine Workers of America members. This crushed the union, and the larger effect was a chill throughout Appalachia for more than a decade.
A similar chill is beginning to percolate as part of the fear around resistance or questioning of the ASTH and its myriad tentacles. This chill is coupled with a growing ambivalence and resignation to the most recent colonization of the Ohio River Valley by yet another iteration of the fossil fuel industrial complex.
How Can Appalachia Escape the Tight Grip of the Hydrocarbon Industrial Complex?
The state’s historical labor strife is worth mentioning to emphasize that Appalachia has been thrown under the “natural resource curse” bus before, and it has not responded kindly (see documentary “Harlan County USA” directed by Barbara Kopple). This might be why industry stakeholders fund the likes of the Koch Brothers-backed American Legislative Executive Council in efforts to pass dubiously titled “critical infrastructure” bills that they’ve written in states including the ASTH states of Ohio, Pennsylvania, Kentucky, and West Virginia.  It also might be why West Virginia Senator Manchin is trying to separate himself from his prior optimism about the supposed $84 billion China would invest in ASTH related projects across the state and his willingness to compromise the safety of his own constituents for the sake of profiteering state-backed firms in China, Saudi Arabia, and Thailand.
“So far, the entire project, which was hailed as the salvation of West Virginia’s economy at the time, looks like nothing but smoke and confetti. There’s been no movement and the Justice administration rarely mentions it unless asked. The reply has typically been a guarded ‘it’s happening’ and not much else. It’s time for state government to level with the people of West Virginia on what exactly is happening here. Not only did the announcement raise false hopes, but the question of national security is valid and important. We urge the governor or someone in his administration to give an official update on the project.”
In the interim, West Virginia’s elected officials continue to prop up coal as the Mountaineer State’s salvation. But the gig will be up eventually. It appears that there are two ways to exit this zero-sum relationship with the fossil fuel industry according to the neoliberal economic model we espouse here in the United States: 1) A Glide Path strategy that will allow West Virginia to methodically transition to a more diversified economy, or 2) an extremely painful Jump Condition type transition over a much shorter period of time that will likely last no more than a couple of years and leave West Virginians very angry and looking for someone to blame.
Those of us that accept climate change as fact, advocate for the Green New Deals of the world, and work towards a renewable energy future can easily dismiss either pathway’s impacts on Appalachia with the mantra, “Hey, they [Appalachia] made their bed now they have to lie in it!” However, this would be counter to the social contract narrative we have created for this country and would be incredibly hypocritical given that the primary steroid that fueled American Exceptionalism/Capitalism was cheap and abundant domestic fossil fuels. As Kim Kelly of Teen Vogue so perfectly put it in laying out her very personal connections to the struggle between the need to pay bills and the environmental impacts of fossil fuel reliant jobs: “Make no mistake: The coal miner and pipeline worker know about the environmental costs of their labor, but when faced with the choice of feeding their kids or putting down their tools in the name of saving the planet, the pressures of capitalism tend to win; their choice is made for them.”
Cravat Coal Mine Slurry Pond, Marshall County, West Virginia
Americans rationalize our dependence on fossil fuels on one hand, while simultaneously hectoring those who work tirelessly to get the stuff out of the ground and invest in the companies that employ them by way of 401Ks or other investment vehicles. This hypocrisy is not lost on Appalachia nor should it be. Climate advocates should work with states like West Virginia to transition to a more just future that does not include a doubling down on fossil fuels by way of the ASTH and fracking. If not, the social and political divisions in this country will pale in comparison to what will likely result from a piecemeal and confrontational transition away from the fossil fuel industrial complex that we’ve been told we can’t live without.
Furthermore, we can’t address these issues without acknowledging the selective interventionist policy our government has deployed in the name of “nation building” in the Middle East and elsewhere. Folks like John Perkins, Naomi Klein, and Joseph Stiglitz have demonstrated that our interventionist policy is just a poor cover for the true modus operandi which would be resource control from Saudi Arabia to the most recent example being the effort by the Trump administration to foment opposition to Venezuelan leader Nicholas Maduro. If the latter example isn’t primarily about oil than why do the bi-partisan sanctions include exceptions to allow Chevron, Halliburton, and Schlumberger to continue to operate in Venezuela?
A Path Forward
The Green New Deal is a first step in establishing a path forward for the decarbonization of the US economy and it correctly includes calls for a transition that “would ensure protections for coal miners and other impacted fossil fuel workers.” While mostly nebulous and aspirational at this point, the Green New Deal offers much needed hope and guidance towards a future where economic growth is decoupled from CO2 emissions. Yet, it will have to address the underlying issues associated with economic inequality and the fact that states like West Virginia will have to be involved in the decision-making process rather than having the Green New Deal foisted on them. Otherwise, the Mountaineer State’s politicians in D.C. and Charleston will continue to get away with toying with their constituents’ hopes and dreams with proclamations that the ASTH and rumored infrastructure proposals will provide salvation. In reality, the ASTH is just another corporatist stunt to optimize shareholder return on the backs of Appalachians. This tension was summarized beautifully and succinctly by United Mine Workers of America spokesman Phil Smith who told Reuters, “We’ve heard words like ‘just transition’ before, but what does that really mean? Our members are worried about putting food on the table.”
“ . . . the need to maximize profits for a relatively small section of the U.S. population has shaped the development of America’s most powerful institutions . . . the need for higher profits and endless growth has intensified environmental destruction, resource depletion, instability, social and political inequality, and even global warming. These problems have become systemic and solutions therefore require long-term systemic change . . . [and the development of] alternative institutions. As these alternatives evolve and grow, they will place the U.S. economy on a path to a new system. Systemic change will come about gradually by the will of people who purposefully steer the development of the economic institutions in their communities in a positive and healthy direction. To this end Mindful Economics lays a foundation for building new alternatives that are democratic, locally-based and ecologically sustainable. Such alternatives are not only viable, they can be found all across the United States. Through a network of alternative institutions, people can begin to build alternatives to capitalism and provide hope for future generations.”
Ecotrust’s Conservation Economy website offers a road map for how Appalachia can move towards an alternative future that “integrates Social, Natural, and Economic Capital” (see the pattern map below). Appalachia has been stripped of much of its economic capital but it still has a bountiful supply of social and natural capital!
Conservation Economy’s Pattern Map
We constructed a map that illustrates West Virginia’s past, present, and future dependence on fossil fuels. The map shows 16,864 oil, gas, and coal parcels as well as those that are rumored to be of interest to the fossil fuel industrial complex in the near future. The parcels average 164 acres in size and amount to 2,770,310 acres or 4,329 square miles. These parcels amount to 17.9% of West Virginia but are largely concentrated in the counties of Boone, Kanawha, Logan, Wyoming, McDowell, Mingo, and Fayette.
Also included in this map are:
annual production data for 880 mines between 2001 and 2017 and
annual oil, natural gas, and natural gas liquid (NGL) production for 3,689 unconventional wells between 2002 and 2018.
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance with invaluable data compilation assistance from Gary Allison
 If you aren’t familiar with this term I would refer you to Columbia University’s data for Boone County, West Virginia: “The numbers suggest that about a third of Boone County’s revenues directly depended on coal in the form of property taxes on coal mines and severance taxes. In 2015, 21 percent of Boone County’s labor force and 17 percent of its total personal income were tied to coal. Coal property (including both the mineral deposit and industrial equipment) amounted to 57 percent of Boone County’s total property valuation. Property taxes on all property generated about half of Boone County’s general fund budget, which means that property taxes just on coal brought in around 30 percent of the county’s general fund. Property taxes on coal also funded about $14.2 million of the $60.3 million school budget (24 percent). In total, coal-related property taxes generated approximately $21 million for Boone County’s schools, the county government, and specific services.”
 ALEC finalized their “Model Policy” in December, 2017, and gave it the ultimate Orwellian title of “Critical Infrastructure Protection Act.” Many elected officials throughout the fossil fuel network’s Heartland have introduced this legislation nearly verbatim, including Ohio State Senator Frank Hoagland’s S.B. 33, which represents much of Ohio’s Ohio River Valley, where the ASTH would have its most pronounced impacts.
If this article was helpful to you, please contribute to FracTracker today. Any amount is greatly appreciated!
FracTracker is closely mapping and following the petrochemical build-out in Appalachia, as the oil and gas industry invests in petrochemical manufacturing. Much of the national attention on the build-out revolves around the Appalachian Storage Hub (ASH), a venture spearheaded by Appalachian Development Group.
The ASH involves a network of infrastructure to store and transport natural gas liquids and finds support across the political spectrum. Elected officials are collaborating with the private sector and foreign investors to further development of the ASH, citing benefits such as national security, increased revenue, job creation, and energy independence.
Left out of the discussion are the increased environmental and public health burdens the ASH would place on the region, and the fact that natural gas liquids are the feedstock of products such as plastic and resins, not energy.
The “Shale Revolution” brought on by high-volume hydraulic fracturing (fracking) in this region encompasses thousands of wells drilled into the Marcellus and Utica-Point Pleasant shale plays across much of the Allegheny Plateau. This area spans from north of Scranton-Wilkes Barre, Pennsylvania, just outside the Catskills Mountains to the East in Susquehanna County, Pennsylvania, and down to the West Virginia counties of Logan, Boone, and Lincoln. The westernmost extent of the fracking experiment in the Marcellus and Utica shale plays is in Noble and Guernsey Counties in Ohio.
Along the way, producing wells have exhibited steeper and steeper declines during the first five years of production, leading the industry to develop what they refer to as “super laterals.” These laterals (the horizontal portion of a well) exceed 3 miles in length and require in excess of 15 million gallons of freshwater and 15,000 tons of silica sand (aka, “proppant”).
The resource-intense super laterals are one way the industry is dealing with growing pressure from investors, lenders, the media, state governments, and the public to reduce supply costs and turn a profit, while also maintaining production. (Note: unfortunately these sources of pressures are listed from most to least concerning to industry itself!)
Another way the fracking industry is hoping to make a profit is by investing in the region’s natural gas liquids (NGLs), such as ethane, propane, and butane, to support the petrochemical industry.
The Appalachian Storage Hub
Continued oil and gas development are part of a nascent effort to establish a mega-infrastructure petrochemical complex, the Appalachian Storage Hub (ASH). For those that aren’t familiar with the ASH it could be framed as the fracking industry’s last best attempt to lock in their necessity across Appalachia and nationwide. The ASH was defined in the West Virginia Executive as a way to revitalize the Mountain State and would consist of the following:
“a proposed underground storage facility that would be used to store and transport natural gas liquids (NGLs) extracted from the Marcellus, Utica and Rogersville shales across Kentucky, Ohio, Pennsylvania and West Virginia. Construction of this hub would not only lead to revenue and job creation in the natural gas industry but would also further enable manufacturing companies to come to the Mountain State, as the petrochemicals produced by shale are necessary materials in most manufacturing supply chains…[with] the raw materials available in the region’s Marcellus Shale alone…estimated to be worth more than $2 trillion, and an estimated 20 percent of this shale is composed largely of ethane, propane and butane NGLs that can be utilized by the petrochemical industry in the manufacturing of consumer goods.”
This is yet another example of fracking rhetoric that appeals to American’s sense of patriotism and need for cheaper consumer goods (in this case, plastics), given that they are seeing little to no growth in wages.
While a specific location for underground storage has not been announced, the infrastructure associated with the ASH (such as pipelines, compressor stations, and processing stations) would stretch from outside Pittsburgh down to Catlettsburg, Kentucky, with the latter currently the home of a sizeable Marathon Oil refinery. The ASH “would act like an interstate highway, with on-ramps and off-ramps feeding manufacturing hubs along its length and drawing from the available ethane storage fields. The piping would sit above-ground and follow the Ohio and Kanawha river valley.”
The politics of the ASH – from Columbus and Charleston to Washington DC
Elected officials across the quad-state region are supporting this effort invoking, not surprisingly, its importance for national security and energy independence.
West Virginia Senator Joe Manchin (D) went so far as to introduce “Senate Bill 1064 – Appalachian Energy for National Security Act.” This bill would require Secretary of Energy Rick Perry and his staff to “to conduct a study on the national security implications of building ethane and other natural-gas-liquids-related petrochemical infrastructure in the United States, and for other purposes.”
Interestingly, the West Virginia Senator told the West Virginia Roundtable Inc’s membership meeting that the study would not examine the “national security implications” but rather the “additional security benefits” of an Appalachian Storage Hub and cited the following to pave the way for the national security study he is proposing: “the shale resource endowment of the Appalachian Basin is so bountiful that, if the Appalachian Basin were an independent country, the Appalachian Basin would be the third largest producer of natural gas in the world.”
Senator Manchin is not the only politician of either party to unabashedly holler from the Appalachian Mountaintops the benefits of the ASH. Former Ohio Governor, and 2016 POTUS primary participant, John Kasich (R) has been a fervent supporter of such a regional planning scheme. He is particularly outspoken in favor of the joint proposal by Thailand-based PTT Global Chemical and Daelim to build an ethane cracker in Dilles Bottom, Ohio, across the Ohio River from Moundsville, West Virginia. The ethane cracker would convert the region’s fracked ethane into ethylene to make polyethylene plastic. This proposed project could be connected to the underground storage component of the ASH.
Dilles Bottom, OH ethane cracker site. Photo by Ted Auch, aerial assistance provided by LightHawk.
Not to be outdone in the ASH cheerleading department, West Virginia Governor Jim Justice (R), who can’t seem to find any common ground with Democrats in general nor Senator Manchin specifically, is collaborating with quad-state governors on the benefits of the ASH. All the while, these players ignore or dismiss the environmental, social, and economic costs of such an “all in” bet on petrochemicals and plastics.
Even the region’s land-grant universities have gotten in on the act, with West Virginia University’s Appalachian Oil and Natural Gas Research Consortium and Energy Institute leading the way. WVU’s Energy Institute Director Brian Anderson pointed out that, “Appalachia is poised for a renaissance of the petrochemical industry due to the availability of natural gas liquids. A critical path for this rebirth is through the development of infrastructure to support the industry. The Appalachian Storage Hub study is a first step for realizing that necessary infrastructure.”
utilize a new or significantly improved technology;
avoid, reduce or sequester greenhouse gases;
be located in the United States; and,
have a reasonable prospect of repayment.
This type of Public-Private Investment Program is central planning at its finest, in spite of the likelihood that the prospects of the ASH meeting the second and fourth conditions above are dubious at best (even if the project utilizes carbon capture and storage technologies).
Public-Private Investment Programs have a dubious past. In her book “Water Wars,” Vandana Shiva discusses the role of these programs globally and the involvement of institutions like the World Bank and International Monetary Fund:
“public-private partnerships”…implies public participation, democracy, and accountability. But it disguises the fact that the public-private partnership arrangements usually entail public funds being available for the privatization of public goods…[and] have mushroomed under the guise of attracting private capital and curbing public-sector employment.”
In response to the Department of Energy’s Title XVII largesse, Congresswoman Pramila Jayapal and Ilhan Omar introduced Amendment 105 in Rule II on HR 2740. According to Food and Water Watch, this amendment would restrict “the types of projects the Department of Energy could financially back. It would block the funding for ALL projects that wouldn’t mitigate climate change.”
The only condition of Department of Energy’s Title XVII loan program ASH is guaranteed to meet is the third (be located in the United States), but as we’ve already mentioned, the level of foreign money involved complicates the domestic facade.
Foreign involvement in the ASH lends credence to Senator Manchin’s and others’ concerns about where profits from the ASH will go, and who will be reaping the benefits of cheap natural gas. The fact that the ASH is being heavily backed by foreign money is the reason Senator Manchin raised an issue with the outsized role of state actors like Saudi Arabia and China as well as likely state-backed private investments like PTT Global Chemical’s. The Senator even cited how a potential $83.7 billion investment in West Virginia from China’s state-owned energy company, China Energy, would compromise “domestic manufacturing and national security opportunities.”
With all of the discussion and legislation focused on energy and national security, many don’t realize the output of the ASH would be the production of petroleum-based products: mainly plastic, but also fertilizers, paints, resins, and other chemical products.
Bills like this and the not unrelated “critical infrastructure” bills being shopped around by the American Legislative Exchange Council will amplify the rural vs urban and local vs state oversight divisions running rampant throughout the United States. The reason for this is that yet another natural resource boom/bust will be foisted on Central Appalachia to fuel urban growth and, in this instance, the growth and prosperity of foreign states like China.
Instead of working night and day to advocate for Appalachia and Americans more broadly, we have legislation in statehouses around the country that would make it harder to demonstrate or voice concerns about proposals associated with the ASH and similar regional planning projects stretching down into the Gulf of Mexico.
Producing wells mapped
Impacts from the ASH and associated ethane cracker proposals will include but are not limited to: an increase in the permitting of natural gas wells, an increase in associated gas gathering pipelines across the Allegheny Plateau, and an exponential increase in the production of plastics, all of which are harmful to the region’s environment and the planet.
The production of the region’s fracked wells will determine the long-term viability of the ASH. From our reading of things, the permitting trend we see in Ohio will have to hit another exponential inflection point to “feed the beast” as it were. Figure 1 shows an overall decline in the number of wells drilled monthly in Ohio.
Figure 2, below it, shows the relationship between the number of wells that are permitted verse those that are actually drilled.
Figures 1. Monthly (in blue) and cumulative (in orange) unconventional oil and gas wells drilled in Ohio, January, 2013 to November, 2018
Figure 2. Permitted Vs Drilled Wells in Ohio, January, 2013 to November, 2018
That supply-demand on steroids interaction will likely result in an increased reliance on “super laterals” by the high-volume hydraulic fracturing industry. These laterals require 5-8 times more water, chemicals, and proppant than unconventional laterals did between 2010 and 2012.
Given this, we felt it critical to map not just the environmental impacts of this model of fracking but also the nuts and bolts of production over time. The map below shows the supply-demand links between the fracking industry and the ASH, not as discrete pieces or groupings of infrastructure, but rather a continuum of up and downstream patterns.
The current iteration of the map shows production values for oil, natural gas, and natural gas liquids, how production for any given well changes over time, and production declines in newer wells relative to those that were fracked at the outset of the region’s “Shale Revolution.” Working with volunteer Gary Allison, we have compiled and mapped monthly (Pennsylvania and West Virginia) and quarterly (Ohio) natural gas, condensate, and natural gas liquids from 2002 to 2018.
This map includes 15,682 producing wells in Pennsylvania, 3,689 in West Virginia, and 2,064 in Ohio. We’ve also included and will be updating petrochemical projects associated with the ASH, either existing or proposed, across the quad-states including the proposed ethane cracker in Dilles Bottom, Ohio and the ethane cracker under construction in Beaver County, Pennsylvania, along with two rumored projects in West Virginia.
We will continue to update this map on a quarterly basis, will be adding Kentucky data in the coming months, and will be sure to update rumored/proposed petrochemical infrastructure as they cross our radar. However, we can’t be everywhere at once so if anyone reading this hears of legitimate rumors or conversations taking place at the county or township level that cite tapping into the ASH’s infrastructural network, please be sure to contact us directly at firstname.lastname@example.org.
By Ted Auch, Great Lakes Program Coordinator, FracTracker Alliance with invaluable data compilation assistance from Gary Allison
Feature Photo: Ethane cracker plant under construction in Beaver County, PA. Photo by Ted Auch, aerial assistance provided by LightHawk.
 For a detailed analysis of the HVHF’s increasing resource demand and how lateral length has increased in the last decade the reader is referred to our analysis titled “A Disturbing Tale of Diminishing Returns in Ohio” Figures 12 and 13.
 Note: For those Bluegrass State residents or interested parties, Kentucky data is on its way!
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/07/Cracker-Plant-2-scaled.jpg6831500Ted Auch, PhDhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngTed Auch, PhD2019-07-23 14:37:052021-04-15 14:56:27The Underlying Politics and Unconventional Well Fundamentals of an Appalachian Storage Hub
California regulators halt well permitting after Consumer Watchdog and FracTracker reveal a surge in well permits under California Governor Newsom
October 24th, 2019 update:
There have been several exciting updates since FracTracker Alliance and Consumer Watchdog released a report on fracking and regulatory corruption under Governor Newsom’s administration, detailed in the article below.
On July 11th, 2019, immediately following the report’s release, Governor Newsom fired Ken Harris, head of California’s Division of Oil, Gas, and Geothermal Resources (DOGGR).
“The Governor has long held concerns about fracking and its impacts on Californians and our environment, and knows that ultimately California and our global partners will need to transition away from oil and gas extraction. In the weeks ahead, our office will work with you to find new leadership of (the division) that share this point of view and can run the division accordingly.”
FracTracker Alliance supports the governor’s decision and hopes that new leadership acts in the best interests of Californians while moving the state towards 100% renewable energy.
Two months later in September, it was announced that no new fracking permits had been approved in California since the report was issued. We’re thrilled to see this immediate cessation. Yet, while new fracking activity has halted, other forms of oil and gas development continue to threaten Californian’s health and natural resources.
FracTracker Alliance’s review of public records found that DOGGR issued approximately 1,200 permits for steam injection and other “enhanced recovery” techniques through September 2nd, a 60% increase from the 749 permits issued in the same period last year. Sources within DOGGR revealed that at least 40 illegal oil spills from wells were ongoing in Kern and Santa Barbara Counties.
A final development came on October 12th, when Governor Newsom signed a bill to prevent oil and gas development on state lands. As state lands often neighbor federal lands, this bill will play a role in protecting federal land from pipelines, wells, and other polluting infrastructure. Newsom also changed the name of DOGGR to the “Geologic Energy Management Division,” and modified its mission to include protecting public health and environmental quality.
We remain hopeful that Newsom will take a bold stance in leading California away from fossil fuels.
Original July 11th, 2019 FracTracker article:
FracTracker Alliance and Consumer Watchdog have uncovered new data showing an increase in oil and gas permitting by California regulators in 2019 compared to 2018, calling into question Governor Gavin Newsom’s climate commitment. Even more concerning, this investigation found that state regulators are heavily invested in the oil companies they regulate.
FracTracker Alliance’s new report with Consumer Watchdog compares oil and gas permitting policies of the current Governor Gavin Newsom’s administration with that of former Governor Jerry Brown’s administration.
The former lieutenant governor to Brown, Governor Newsom has set out to make a name for himself. As part of stepping out of Brown’s shadow, Newsom has expressed support for a Just Transition away from fossil fuels. Governor Newsom’s 2020 budget plan includes environmental justice measures and an unprecedented investment to plan for this transition that includes investments in job training.
Yet five months into Governor Newsom’s first term, regulators are on track to allow companies to drill and “frack” more new oil and gas wells than Brown allowed in 2018. The question now is: will Governor Newsom actually take the next step that Brown could not, and prioritize the reduction of oil extraction in California?
In addition, the Consumer Watchdog report reveals that eight California regulators with the Division of Oil, Gas, and Geothermal Resources (DOGGR) are heavily invested in the oil companies they regulate. FracTracker and Consumer Watchdog are calling for the the removal of DOGGR officials with conflicts of interest, and an immediate freeze on new well approval. Read the letter to Governor Newsom here.
Governor Brown’s Legacy
Around the world, Brown is recognized as a climate warrior. His support of solar energy technology and criticisms of the nuclear and fossil fuel industry was ultimately unique in the late 1970’s.
While Brown championed the reduction of greenhouse gas emissions, his policies in California were contradictory. While front-line communities called for setbacks from schools, playgrounds, hospitals and other sensitive receptors, Brown ignored these requests. Instead he sought to spur oil production in the state. Brown even used state funds to explore his private properties for oil and mineral resources that could be exploited for personal profit.
Brown’s terms in the Governor’s office show trends of increasing oil and gas production. The chart in Figure 1 shows that during his first term (1979-1983), California oil extraction grew towards a peak in production. Then in 2011 at the start of Brown’s second term (2011-2019), crude oil production again inflected and continued to increase through 2015, ending a 25-year period of relatively consistent reduction.
We are therefore interested in looking at existing data to understand if moving forward, Governor Newsom will continue Brown’s legacy of support for California oil production. We start by looking at the first half of 2019, the beginning of Governor Newsom’s term, to see if his administration will also allow the oil and gas industry to increase extraction in California.
Figure 1. Chart of California’s historic oil production, from the EIA
The FracTracker Alliance has collaborated with the non-profit Consumer Watchdog to review records of oil and gas well permits issued in 2018 and thus far into 2019.
Records of approved permits were obtained from the CA Department of Conservation’s Division of Oil Gas and Geothermal Resources (DOGGR). Weekly summaries of approved permits for the 52 weeks of 2018 and the first 22 weeks of 2019 (January 1st-June 3rd) were compiled, cleaned, and analyzed. Notices of well stimulations were also included in this analysis. The data is mapped here in the Consumer Watchdog report, as well as in more detail below in the map in Figure 2.
Figure 2. Map of California’s Permits, 2018 and 2019
At FracTracker, we are known for more than simply mapping, so we have, of course, extracted all the information that we can from this data. The dataset of DOGGR permits included details on the type of permit as well as when, where, and who the permits were granted. With this information we were able to answer several questions.
Of particular note and worthy of prefacing the data analysis was the observation of the very low numbers of permits granted in the LA Basin and Southern California, as compared to the Central Valley and Central Coast of California.
First, what are the types of permits issued?
Regulators require operators to apply for permits for a number of activities at well sites. This dataset includes permits to drill wells, including re-drilling existing wells, permits to rework existing wells, and permits to “sidetrack”. Well stimulations using techniques such as hydraulic fracturing and acid fracturing also require permits, as outline in CA State Bill 4.
How many permits have regulators issued?
In 2018, DOGGR approved 4,368 permits, including 2,124 permits to drill wells. In 2019, DOGGR approved 2,366 permits from January 1 – June 3, including 1,212 permits to drill wells. At that rate, DOGGR will approve 5,607 total permits by the end of 2019, including 2,872 wells.
That is an increase of 28.3% for total permits and an increase of 35.3% for drilling oil and gas wells.
DOGGR also issued 222 permits for well stimulations in 2018. So far in 2019, DOGGR has issued 191 permits for well stimulations, an increase of 103.2%.
Who is applying for permits?
As shown in Table 1 below, the operators Chevron U.S.A. Inc., Aera Energy LLC ( a joint conglomerate of Shell Oil Company and ExxonMobil), and Berry Petroleum Company, LLC dominate the drilling permit counts for both 2018 and 2019.
Aera has obtained the most drilling permits thus far into 2019, while Chevron obtained the most permits in 2018, almost 100 more than Aera. In 2019, Chevron was issued almost 3 times the amount of rework permits as Aera, and both have outpaced Berry Petroleum.
Table 1. Permit Counts by Operator
Where are the permits being issued?
Data presented in Table 2 indicate which fields are being targeted for drilling and rework permits. While the 2019 data represents less than half the year, the number of drilling permits is almost equal to the total drilling permit count for 2018.
Majority players in the Midway-Sunset field are Berry Petroleum and Chevron. South Belridge is dominated by Aera Energy and Berry Petroleum. The Cymric field is mostly Chevron and Aera Energy; McKittrick is mostly Area Energy and Berry Petroleum. The Kern River field, which has by far the most reworks (most likely due to its massive size and age) is entirely Chevron.
The details of this analysis show that DOGGR has allowed for a modest increase in permits for oil and gas wells in 2019. The increase in well stimulations in 2019 is estimated to be larger, at 103.2%.
There was the consideration that this could be a seasonal phenomenon since we extrapolated from data encompassing just less than the first half of the year. But upon reviewing data for several other years, that does not seem to be the case. The general trend was instead increasing numbers of permits as each year progresses, with smaller permit counts through the first half of the year.
Oil prices do not provide much explanation either. The chart in Figure 3 shows that crude prices were higher in 2018 than they have been for the vast majority of 2019. The increase in permits could be the result of oil and gas operators like Chevron and Aera anticipating a stricter regulatory climate under Governor Newsom. Operators may be securing as many permits as possible, while DOGGR is still liberally issuing them. This could be a consequence of the Governor’s recognition of the need for California to begin a managed decline of fossil fuel production and end oil drilling in California.
Could this be an early industry death rattle?
Figure 3. Crude prices in 2018 and 2019
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/07/inglewood-field-ca-feature-1-scaled.jpg6671500Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2019-07-11 14:48:462021-04-15 14:56:28Permitting New Oil and Gas Wells Under the Newsom Administration
A new bill proposed by California State Assembly Member Al Muratsuchi (D), AB345, seeks to establish a minimum setback distance of 2,500′ between oil and gas wells and sensitive sites including occupied dwellings, schools, healthcare facilities, and playgrounds. A setback distance for oil and gas development is necessary from a public health standpoint, as the literature unequivocally shows that oil and gas wells and the associated infrastructure pose a significant risk to the communities that live near them.
FracTracker Alliance conducted a spatial analysis to understand the impact a 2,500’ well setback would have on oil and gas expansion in California. In a previous report, The Sky’s Limit California (Oil Change Internal, 2018), Fractracker data showed that 8,493 active or newly permitted oil and gas wells were located within a 2,500’ buffer of sensitive sites. At the time it was estimated that 850,000 Californians lived within the setback distance of at least one of these oil and gas wells.
This does not bode well for Californians, as a recently published FracTracker literature review found that health impacts resulting from living near oil and gas development include cancer, infant mortality, depression, pneumonia, asthma, skin-related hospitalizations, and other general health symptoms. Studies also showed that health impacts increased with the density of oil and gas development, suggesting that health impacts are dose dependent. Living closer to more oil and gas sites means you are exposed to more health-threatening contamination.
An established setback is therefore necessary to alleviate some of these health burdens carried by the most vulnerable Environmental Justice (EJ) communities. Health assessments by the Los Angeles County Department of Health and studies on ambient air quality near oil fields by Occidental College Researchers support the assumption that 2,500′ is the necessary distance to help alleviate the harsh conditions of degraded air quality. Living at a distance beyond 2,500′ from an oil and gas site does not mean you are not impacted by air and water contamination. Rather the concentrations of contaminants will be less harmful. In fact studies showed that health impacts increased with proximity to oil and gas, with associated impacts potentially experienced by communities living at distances up to 9.3 miles (Currie et al. 2017) and 10 miles (Whitworth et al. 2017).
Assembly Bill 345
This analysis assesses the potential impact of State Assembly member Al Muratsuchi’s Assembly Bill 345 on California’s oil and gas extraction and production. Specifically, AB345 establishes a minimum 2,500’ setback requirement for future oil and gas development. It does not however directly address existing oil and gas permits.
The bill includes the following stipulations and definitions:
All new oil and gas development, that is not on federal land, are required to be located at least 2,500′ from residences, schools, childcare facilities, playgrounds, hospitals, or health clinics.
In this case the redrilling of a previously plugged and abandoned oil or gas well or other rework operation is to be considered new oil and gas development.
“Oil and gas development” means exploration for and drilling production and processing of oil, gas or other gaseous and liquid hydrocarbons; the flowlines; and the treatment of waste associated with that exploration, drilling, production, and processing.
“Oil and gas development” also includes hydraulic fracturing and other stimulation activities.
“Rework operations” means operations performed in the well bore of an oil or gas well after the well is completed and equipped for production, done for the purpose of securing, restoring, or improving hydrocarbon production in the subsurface interval that is the open to production in the well bore.
The bill does not include routine repairs or well maintenance work.
Figure 1. Map of Wells within a 2,500′ Setback Distance from Sensitive Receptor Sites. The map below shows the oil and gas wells and permits that fall within the 2,500′ setback distance from sensitive receptor sites. Summaries of these well counts and discussions of these well types are included below as well.
Map of Wells within a 2,500′ Setback Distance from Sensitive Receptor Sites
The California Environmental Justice Alliance (CEJA) has just released their 2018 Environmental Justice Agency Assessment, which used FracTracker’s data and mapping to assess environmental equity in the state regulation of oil permitting and drilling. The report issued the Division of Oil, Gas, and Geothermal Resources (DOGGR) a failing grade of ‘F’. According to the report, “DOGGR is aware that the proposed locations of many drilling activities are in or near EJ communities, but approves permits irrespective of known health and safety risks associated with neighborhood drilling.”
FracTracker’s analysis of low income communities in Kern County shows the following:
There are 16,690 active oil and gas production wells located in census blocks with median household incomes of less than 80% of Kern’s area median income (AMI).
Therefore about 25% (16,690 out of 67,327 total) of Kern’s oil and gas wells are located within low-income communities.
Of these 16,690 wells, 5,364 of them are located within the 2,500′ setback distance from sensitive receptor sites such as schools and hospitals (32%) vs 13.1% for the rest of the state.
Using freshly published Division of Oil, Gas, and Geothermal Resources (DOGGR) data (6/3/19), we find that there are 9,835 active wells that fall within the 2,500’ setback distance, representing 13.1% of the total 74,775 active wells in the state.
There are 6,558 idle wells that fall within the 2,500’ setback distance, of nearly 30,000 total idle wells in the state. Putting these idle wells back online would be blocked if the wells require reworks to restart or ramp up production. For the most part operators do not intend for most idle wells to come back online. Rather operators are just avoiding the costs of plugging and properly abandoning the wells. To learn more about this issue, see our recent coverage of idle wells here.
Of the 3,783 permitted wells not yet in production, or “new wells,” 298 (7.8%) are located within the 2,500’ buffer zone.
Getting a count of plugged wells within the setback distance is more difficult because there is not a complete dataset, but there are over 30,000 wells in areas with active production that would be blocked from being redrilled. In total there are 122,209 plugged wells listed in the DOGGR database.
We also looked at permit applications that were approved in 2018, including permits for drilling new wells, well reworks, deepening wells and well sidetracks. This may be the most insightful of all the analyses.
Within the 2018 permit data, we find that 4,369 permits were approved. Of those 518 permits (about 12%) were granted within the proposed 2,500’ setback. Of the permits 25% were for new drilling, 73% were for reworks, and 2% were for deepening existing wells. By county, 42% were in Kern, 24% were in Los Angeles, 14% in Ventura, 6% in Santa Barbara, 3% in Fresno, and 2% or less in Glenn, Monterey, Sutter, San Joaquin, Colusa, Solano, Orange and Tehama, in descending order.
In LA, Rule 1148.2 requires operators to notify the South Coast Air Quality Management District (SCAQMD) of activities at well sites, including stimulations and reworks. These data points are reiterative of the “permits” discussed above, but the dataset is specific to the SCAQMD and includes additional activities. Of the 1,361 reports made to the air district since the beginning of 2018 through April 1, 2019; 634 (47%) were for wells that would be impacted by the setback distance; 412 incidences were for something other than “well maintenance” of which 348 were for gravel packing, 4 for matrix acidizing, and 65 were for well drilling. We are not sure where gravel packing falls, in reference to AB345.
A major consideration is that this rule may force many active wells into an idle status. If the onus of plugging wells falls on the state, these additional idle wells could be a major liability for the public. Fortunately AB1328 recently defined new idle well rules. The rules entice operators to plug and abandon idle wells. If rule 1328 is effective at reducing the stock of idle wells, these two bills could complement each other. (For more information on idle wells, read FracTracker’s recent analysis, here: https://www.fractracker.org/2019/04/idle-wells-are-a-major-risk/)
State Bill 4 Well Stimulation Reporting
We also analyzed data reported to DOGGR under the well stimulation requirements of CA State Bill 4 (SB4), the 2013 bill that set a framework for regulating hydraulic fracturing in California. Part of the bill required an independent scientific study to be conducted on oil and gas well stimulation, including acid well stimulation and hydraulic fracturing. Since 2016 operators have been required to secure special permits to stimulate wells, which includes hydraulic fracturing and several other techniques. To learn more about this state regulation read FracTracker’s coverage of SB4. From January 1, 2016 to April 1, 2019, there have been 576 well stimulation treatment permits granted under the SB4 regulations. Only 1 hydraulic fracturing event, permitted in Goleta, would have been impacted by a 2,500’ setback in 2018.
Support for AB345
After being approved by the CA Assembly Natural Resources Committee in a 7-6 vote, the bill did not make it up for a vote in the Senate Appropriations Committee during the 2019 legislative session. The bill was described by the committee as “promising policies that need more time for discussion.” AB345 is now a two-year bill in the state Senate and will be reconsidered by the committee in January of 2020. The Chairperson of the Appropriations Committee, Lorena Gonzalez, indicated her general support for the policy and committed to working with the author to find a way to move the bill forward at the end of the session.
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
Feature image by David McNew, Getty Images
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/06/SignalHill_DavidMcNew_GettyImages_edit.jpg400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2019-07-02 12:03:382021-04-15 14:56:29Impact of a 2,500′ Oil and Gas Well Setback in California
Contact: Lee Ziesche, email@example.com, 954-415-6282
Interactive Map Shows Expansion of Fracked Gas Infrastructure in New York State
And showcases powerful community resistance to it
New York, NY – A little over a year after 55 New Yorkers were arrested outside of Governor Cuomo’s door calling on him to be a true climate leader and halt the expansion of fracked gas infrastructure in New York State, grassroots advocates Sane Energy Project re-launched the You Are Here (YAH) map, an interactive map that shows an expanding system of fracked infrastructure approved by the Governor.
“When Governor Cuomo announced New York’s climate goals in early 2019, it’s clear there is no room for more extractive energy, like fossil fuels.” said Kim Fraczek, Director of Sane Energy Project, “Yet, I look at the You Are Here Map, and I see a web of fracked gas pipelines and power plants trapping communities, poisoning our water, and contributing to climate change.”
Sane Energy originally launched the YAH map in 2014 on the eve of the historic People’s Climate March, and since then, has been working with communities that resist fracked gas infrastructure to update the map and tell their stories.
“If you read the paper, you might think Governor Cuomo is a climate leader, but one look at the YAH Map and you know that isn’t true. Communities across the state are living with the risks of Governor Cuomo’s unprecedented buildout of fracked gas infrastructure,” said Courtney Williams, a mother of two young children living within 400 feet of the AIM fracked gas pipeline. “The Governor has done nothing to address the risks posed by the “Algonquin” Pipeline running under Indian Point Nuclear Power Plant. That is the center of a bullseye that puts 20 million people in danger.”
Fracked gas infrastructure poses many of the same health risks as fracking and the YAH map exposes a major hypocrisy when it comes to Governor Cuomo’s environmental credentials. The Governor has promised a Green New Deal for New York, but climate science has found the expansion of fracking and fracked gas infrastructure is increasing greenhouse gas emissions in the United States.
“The YAH map has been an invaluable organizing tool. The mothers I work with see the map and instantly understand how they are connected across geography and they feel less alone. This solidarity among mothers is how we build our power ,” said Lisa Marshall who began organizing with Mothers Out Front to oppose the expansion of the Dominion fracked gas pipeline in the Southern Tier and a compressor station built near her home in Horseheads, New York. “One look at the map and it’s obvious that Governor Cuomo hasn’t done enough to preserve a livable climate for our children.”
“Community resistance beat fracking and the Constitution Pipeline in our area,” said Kate O’Donnell of Concerned Citizens of Oneonta and Compressor Free Franklin. “Yet smaller, lesser known infrastructure like bomb trucks and a proposed gas decompressor station and 25 % increase in gas supply still threaten our communities.”
The YAH map was built in partnership with FracTracker, a non-profit that shares maps, images, data, and analysis related to the oil and gas industry hoping that a better informed public will be able to make better informed decisions regarding the world’s energy future.
“It has been a privilege to collaborate with Sane Energy Project to bring our different expertise to visualizing the extent of the destruction from the fossil fuel industry. We look forward to moving these detrimental projects to the WINS layer, as communities organize together to take control of their energy future. Only then, can we see a true expansion of renewable energy and sustainable communities,” said Karen Edelstein, Eastern Program Coordinator at Fractracker Alliance.
Throughout May and June Sane Energy Project and 350.org will be traveling across the state on the ‘Sit, Stand Sing’ tour to communities featured on the map to hold trainings on nonviolent direct action and building organizing skills that connect together the communities of resistance.
“Resistance to fracking infrastructure always starts with small, volunteer led community groups,” said Lee Ziesche, Sane Energy Community Engagement Coordinator. “When these fracked gas projects come to town they’re up against one of the most powerful industries in the world. The You Are Here Map and ‘Sit, Stand Sing’ tour will connect these fights and help build the power we need to stop the harm and make a just transition to community owned renewable energy.”
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/04/YouAreHereMap2.png6671500Guest Authorhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngGuest Author2019-04-24 15:49:052021-04-15 14:56:34Release: The 2019 You Are Here map launches, showing New York’s hurdles to climate leadership
Designating a well as “idle” is a temporary solution for operators, but comes at a great economic and environmental cost to Californians
Idle wells are oil and gas wells which are not in use for production, injection, or other purposes, but also have not been permanently sealed. During a well’s productive phase, it is pumping and producing oil and/or natural gas which profit its operators, such as Exxon, Shell, or California Resources Corporation. When the formations of underground oil pools have been drained, production of oil and gas decreases. Certain techniques such as hydraulic fracturing may be used to stimulate additional production, but at some point operators decide a well is no longer economically sound to produce oil or gas. Operators are supposed to retire the wells by filling the well-bores with cement to permanently seal the well, a process called “plugging.”
A second, impermanent option is for operators to forego plugging the well to a later date and designate the well as idle. Instead of plugging a well, operators cap the well. Capping a well is much cheaper than plugging a well and wells can be capped and left “idle” for indefinite amounts of time.
Unplugged wells can leak explosive gases into neighborhoods and leach toxic fluids into drinking waters. Plugging a well helps protect groundwater and air quality, and prevents greenhouse gasses from escaping and expediting climate change. Therefore it’s important that idle wells are plugged.
Wells are left idle for two main reasons: either the cost of plugging is prohibitive, or there may be potential for future extraction when oil and gas prices will fetch a higher profit margin. While idle wells are touted by industry as assets, they are in fact liabilities. Idle wells are often dumped to smaller or questionable operators.
Wells that have passed their production phase can also be “orphaned.” In some cases, it is possible that the owner and operator may be dead! Or, as often happens, the smaller operators go out of business with no money left over to plug their wells or resume pumping. When idle wells are orphaned from their operators, the state becomes responsible for the proper plugging and abandonment.
The cost to plug a well can be prohibitively high for small operators. If the operators (who profited from the well) don’t plug it, the costs are externalized to states, and therefore, the public. For example, the state of California plugged two wells in the Echo Park neighborhood of Los Angeles at a cost of over $1 million. The costs are much higher in urban areas than, say, the farmland and oilfields of the Central Valley.
Since 1977, California has permanently sealed about 1,400 orphan wells at a cost of $29.5 million, according to reports by the Division of Oil, Gas, and Geothermal Resources (DOGGR). That’s an average cost of about $21,000 per well, not accounting for inflation. From 2002-2018, DOGGR plugged about 600 wells at a cost of $18.6 million; an average cost of about $31,000.
The map above shows the locations of idle wells in California. There are 29,515 wells listed as idle and 122,467 plugged or buried wells as of the most recent DOGGR data, downloaded 3/20/19. There are a total of 245,116 oil and gas wells in the state, including active, idle, new (permitted) or plugged.
Of the over 29,000 wells are listed as idle, only 3,088 (10.4%) reported production in 2018. Operators recovered 338,201 barrels of oil and 178,871 cubic feet of gas from them in 2018. Operators injected 1,550,436,085 gallons of water/steam into idle injection wells in 2018, and 137,908,884 cubic feet of gas.
The tables below (Tables 1-3) provide the rankings for idle well counts by operator, oil field, and county (respectively). Chevron, Aera, Shell, and California Resources Corporation have the most idle wells. The majority of the Chevron idle wells are located in the Midway Sunset Field. Well over half of all idle wells are located in Kern County.
Table 1. Idle Well Counts by Operator
Idle Well Count
Chevron U.S.A. Inc.
Aera Energy LLC
California Resources Production Corporation
California Resources Elk Hills, LLC
Berry Petroleum Company, LLC
E & B Natural Resources Management Corporation
Sentinel Peak Resources California LLC
HVI Cat Canyon, Inc.
Seneca Resources Company, LLC
Crimson Resource Management Corp.
Table 2. Idle Well Counts by Oil Field
Count by Field
Table 3. Idle Well Counts by County
Count by County
San Luis Obispo
According to the Western States Petroleum Association (WSPA) the count of idle wells in California has increased from just over 20,000 idle wells in 2015 to nearly 30,000 wells in 2018! That’s an increase of nearly 50% in just 3 years!
A U.S. EPA report on idle wells published in 2011 warned that existing monitoring requirements of idle wells in California was “not consistent with adequate protection” of underground sources of drinking water. Idle wells may have leaks and damage that go unnoticed for years, according to an assessment by the state Department of Conservation (DOC). The California Council on Science and Technology is actively researching this and many other issues associated with idle and orphaned wells. The published report will include policy recommendations considering the determined risks. The report will determine the following:
State liability for the plugging and abandoning of deserted and orphaned wells and decommissioning facilities attendant to such wells
Assessment of costs associated with plugging and abandoning deserted and orphaned wells and decommissioning facilities attendant to such wells
Exploration of mechanisms to ameliorate plugging, abandoning, and decommissioning burdens on the state, including examples from other regions and questions for policy makers to consider based on state policies
As of 2018, new CA legislation is in effect to incentivize operators to properly plug and abandon their stocks of idle wells. In California, idle wells are defined as wells that have not had a 6-month continuous period of production over a 2-year period (previously a 5-year period). The new regulations require operators to pay idle well fees. The fees also contribute towards the plugging and proper abandonment of California’s existing stock of orphaned wells. The new fees are meant to act as bonds to cover the cost of plugging wells, but the fees are far too low:
$150 for each well that has been idle for 3 years or longer, but less than 8 years
$300 for each well that has been idle for 8 years or longer, but less than 15 years
$750 for each well that has been idle for 15 years or longer, but less than 20 years
$1,500 for each well that has been idle for 20 years or longer
Operators are also allowed to forego idle well fees if they institute long-term idle well management and elimination plans. These management plans require operators to plug a certain number of idle wells each year.
In February 2019, State Assembly member Chris Holden introduced an idle oil well emissions reporting bill. Assembly bill 1328 requires operators to monitor idle and abandoned wells for leaks. Operators are also required to report hydrocarbon emission leaks discovered during the well plugging process. The collected results will then be reported publicly by the CA Department of Conservation. According to Holden, “Assembly Bill 1328 will help solve a critical knowledge gap associated with aging oil and gas infrastructure in California.”
While the majority of idle wells are located in Kern County, many are also located in California’s South Coast region. Due to the long history and high density of wells in the Los Angeles, the city has additional regulations. City rules indicate that oil wells left idle for over one year must be shut down or reactivated within a month after the city fire chief tells them to do so.
Who is responsible?
All of California’s wells, from Kern County to three miles offshore, on private and public lands, are managed by DOGGR, a division of the state’s Department of Conservation. Responsibilities include establishing and enforcing the requirements and procedures for permitting wells, managing drilling and production, and at the end of a well’s lifecycle, plugging and “abandoning” it.
To help ensure operator liability for the entire lifetime of a well, bonds or well fees are required in most states. In 2018, California updated the bonding requirements for newly permitted oil and gas wells. These fees are in addition to the aforementioned idle well fees. Operators have the option of paying a blanket bond or a bond amount per well. In 2018, these fees raised $4.3 million.
Individual well fees:
Wells less than 10,000 feet deep: $10,000
Wells more than 10,000 feet deep: $25,000
Less than 50 wells: $200,000
50 to 500 wells: $400,000
500 to 10,000 wells: $2,000,000
Over 10,000 wells: $3,000,000
With an average cost of at least $31,000 to plug a well, California’s new bonding requirements are still insufficient. Neither the updated individual nor blanket fees provide even half the cost required to plug a typical well.
Strategies for the managed decline of the fossil fuel industry are necessary to make the proposal a reality. Requiring the industry operators to shut down, plug and properly abandon wells is a step in the right direction, but California’s new bonding and idle well fees are far too low to cover the cost of orphan wells or to encourage the plugging of idle wells. Additionally, it must be stated that even properly abandoned wells have a legacy of causing groundwater contamination and leaking greenhouse gases such as methane and other toxic VOCs into the atmosphere.
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2019/03/IdleWellsHathaway_resize.jpg400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2019-04-03 11:30:582021-04-15 14:56:34Idle Wells are a Major Risk
Pittsburgh, PA – Yesterday, the Pennsylvania Department of Environmental Protection (DEP) announced their decision to issue a permit for the construction of Shell’s Falcon ethane pipeline project in southwest PA. FracTracker Alliance is extremely disappointed that DEP is allowing this project to proceed despite heavy opposition from the public and unaddressed concerns for the safety and well-being of nearby residents and the surrounding environment.
The past year has seen countless issues from the construction of new pipelines in the Commonwealth – from hundreds of “inadvertent returns,” (spills of bentonite drilling mud) along the path of the Mariner East II project to the catastrophic explosion of the week-old Revolution Pipeline in Beaver County. These reoccurring and serious incidents make it clear that oil and gas midstream companies are rushing to put infrastructure in place, and DEP and other regulatory agencies have been failing in their mission to adequately supervise the process.
According to data from the US Pipeline and Hazardous Materials Safety Administration, there were 108 pipeline incidents in Pennsylvania between January 2010 and mid-July 2018, resulting in 8 fatalities, 15 injuries, requiring over 1,100 people to be evacuated from their homes, and causing more than $66 million in property damage. This track record, which does not include the Revolution Pipeline explosion in September of 2018, is frankly unacceptable.
Certainly, the Commonwealth has invested heavily in the Shell Ethane Cracker facility, offering steep tax subsidies and even paying the global petrochemical giant $2.10 for every barrel of ethane it consumes from Pennsylvania wells, equivalent to $1.6 billion over the next 25 years. It appears to FracTracker that these business arrangements have made the continued extraction and exploitation of hydrocarbons the priority for DEP, not protecting the environment and health and safety of Pennsylvanians, as the mission of the Department suggests is their focus. DEP’s decision also traces an unfortunate pattern of opaqueness and poor timing by announcing unpopular decisions right before the holidays.
Fundamentally, oil and gas companies like Shell exist to make profits, and will therefore make decisions to maximize earnings and limit their costs, if left to their own devices. This approach is often directly at odds with public safety, so Pennsylvania entrusts DEP to oversee the operations. FracTracker feels that with their decision to move forward with the project on December 20, 2018, DEP brushed over dozens of substantial concerns regarding the Falcon ethane pipeline project, and therefore failed in this mission. We remain unconvinced that the “appropriate construction techniques and special conditions” required by DEP will adequately protect the environment and health and safety of residents along the Falcon pipeline route.
Dec. 21st Update: After this article was written, FracTracker learned that Ohio’s EPA issued an air quality permit for the cracker plant in Belmont County, Ohio on December 21st. The short public comment period and the rush to issue permits again illustrates that significant public health and environmental concerns are given minimal importance versus corporate wishes and political expediency. The regulatory paradigm is broken. The public has been ill served by the agencies entrusted to safeguard their interests. A collective regional voice should be raised in protest.
Started in 2010 as a southwestern Pennsylvania area website, FracTracker Alliance is now a national organization with regional offices across the United States in Pennsylvania, Washington DC, New York, Ohio, and California. The organization’s mission is to study, map, and communicate the risks of oil and gas development to protect our planet and support the renewable energy transformation. Its goal is to support advocacy groups at the local, regional and national level, informing their actions to positively shape our nation’s energy future. www.fractracker.org
Learn more about FracTracker’s coverage of the Falcon ethane pipeline project by exploring the posts below:
Offshore drilling in the United States federal waters has caused the most environmentally destructive disasters in North America. Yet, new policy is pushing for the expansion of offshore drilling, particularly off the coast of California.
Offshore Drilling History
In 1969, Union Oil’s offshore rig Platform A had a blowout that leaked 100,000 barrels into the Santa Barbara Channel, one of the most biologically diverse marine environments in the world. The spill lasted ten days and killed an estimated 3,500 sea birds, as well as an untold number of marine mammals. Unbelievably, the Santa Barbara spill is only the third largest spill in U.S. waters. It follows the 1989 Exxon Valdez and the 2010 Deepwater Horizon spills. These incidents keep getting bigger.
More offshore drilling means a higher risk of catastrophe, additional contamination of air and water locally, and more greenhouse gas emissions globally.
Federal Moratorium on California Offshore Leases
Up until the beginning of 2018, further oil and gas development using offshore oil rig platforms seemed quite unlikely. After the 1969 oil spill from Platform A and the subsequent ban on further leasing in state waters, the risk of another devastating oil spill was too large for even the federal government to consider new leases. The fact that the moratorium lasted through 16 years of Bush presidencies is truly a victory. Across the aisle, expanding offshore operations has been opposed. In Florida, even Republican Governor Rick Scott teamed up with environmental groups to fight the Department of Interior’s recent sales of offshore leases.
Southern California has a legacy of oil extraction, particularly Los Angeles. It’s not just the federal government that is keen on continuing this legacy. While the state has not permitted the leasing of new blocks in offshore waters, Governor Brown’s policies have been very friendly to the oil and gas industry. According to Oil Change International’s Sky’s the Limit report: “Under the Brown administration, the state has permitted the drilling of more than 20,000 new wells,” including 5,000 offshore wells in state waters. About 2,000 of these offshore wells have been drilled since 2012.
Southern California is the main target for future offshore leasing. The Monterey Shale formation, which underlies the city of Los Angeles and expands north offshore to the Ventura Coast, is thought to contain the largest conventional oil plays left IN THE WORLD! The map above shows the locations of state and federal offshore oil and gas wells and the rigs that service them. It also shows historical wells off the coast of Northern California.
Northern California, both onshore and offshore, sits on top of major reserves of natural gas, which may also be developed given the political climate. With an increase in the price of natural gas, operators will be developing these gas fields. Some operators, such as Chevron, have already drilled natural gas wells in northern California, but have left the wells “shut in” (capped) until production becomes more profitable.
FracTracker, in collaboration with Earthworks, recently teamed up with the Center for Biological Diversity and Greenpeace International to get up close to offshore oil rigs. As a certified Optical Gas Imaging Thermographer, Kyle Ferrar (Western Program Coordinator for FracTracker Alliance and California Community Empowerment Project Organizer for Earthworks), took footage of the offshore oil rigs.
Using infrared technology, we were able to visualize and record emissions and leaks of volatile hydrocarbons and other greenhouse gases coming from these offshore sites. We documented many cases of intense flaring from the rigs, including several cases where the poorly burning flare allowed hydrocarbons to be leaked to the atmosphere prior to complete combustion of CO2.
Below you can view a compilation of the footage we were able to capture from small pontoon boats.
FracTracker has looked at offshore oil and gas drilling from many different angles. We have looked to the past, and found the most egregious environmental damages in U.S. history. We have analyzed the data and shown where, when, and how much offshore drilling is happening in California. We have demonstrated that much of the drilling and many of the proposed leases are in protected and sensitive habitats. We have looked at policy and found that both Governor Brown and President Trump are aligned to promote more oil and gas development. We have even looked at the rigs in person in multiple spectrums of light and found that these operations continuously leak and emit greenhouse gases and other air toxins.
No matter which way you look at offshore oil and gas drilling, it is clearly one of the most threatening methods of oil and gas extraction in use today.
By Kyle Ferrar, Western Program Coordinator, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2018/10/CA-Offshore-Feature.png400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2018-11-05 14:32:422021-04-15 14:57:10The Feds Trump California’s State Ban on Offshore Oil Drilling