By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance
In collaboration with the environmental advocacy groups Earthworks, Center for Biological Diversity, and Clean Water Action, The FracTracker Alliance has completed a proximity analysis of the locations of California’s Class II oil and gas wastewater injection wells to “recently” active fault zones in California. The results of the analysis can be found in the On Shaky Ground report, available for download at www.ShakyGround.org.1
Production of oil and natural gas results in a large and growing waste stream. Using current projections for oil development, the report projects a potential 9 trillion gallons of wastewater over the lifetime of the Monterey shale. In California the majority of wastewater is injected deep underground for disposal in wells deemed Class II wastewater injection. The connection between seismic activity and underground injections of fluid has been well established, but with the current surge of shale resource development the occurrence of earthquakes in typically seismically inactive regions has increased, including a recent event in Ohio covered by the LA Times. While both hydraulic fracturing and wastewater injection wells have been linked to the induction of seismic activity, the impacts of underground injection wells used for disposal are better documented and linked to larger magnitude earthquakes.
Therefore, while hydraulic fracturing of oil and gas wells has also been documented to induce seismic activity, the focus of this report is underground injection of waste fluids.
Active CA Faults
A spatial overview of the wastewater injection activity in California and recently active faults can be viewed in Figure 1, below.
Figure 1. California’s Faults and Wastewater Injection Wells. With this and all maps on this page, click on the arrows in the upper right hand corner of the map to view it fullscreen and to see the legend and more details.
The focus of the On Shaky Ground report outlines the relationship between does a thorough job reviewing the literature that shows how the underground injection of fluids induces seismic activity. The proximity analysis of wastewater injection wells, conducted by The FracTracker Alliance, provides insight into the spatial distribution of the injection wells. In addition, the report M7.8 earthquake along the San Andreas fault could cause 1,800 fatalities and nearly $213 billion in economic damages.2 To complement the report and provide further information on the potential impacts of earthquakes in California, FracTracker created the maps in Figure 2 and Figure 3.
Shaking Assessments
Figure 2 presents shaking amplification and shaking hazards assessments. The dataset is generated from seismic evaluations. When there is an earthquake, the ground will amplify the seismic activity in certain ways. The amount of amplification is typically dependent on distance to the earthquake event and the material that comprises the Earth’s crust. Softer materials, such as areas of San Francisco built on landfills, will typically shake more than areas comprised of bedrock at the surface. The type of shaking, whether it is low frequency or high frequency will also present varying hazards for different types of structures. Low frequency shaking is more hazardous to larger buildings and infrastructure, whereas high frequency events can be more damaging to smaller structure such as single family houses. Various assessments have been conducted throughout the state, the majority by the California Geological Survey and the United States Geological Survey.
Figure 2. California Earthquake Shaking Amplification and Class II Injection Wells
Landslide Hazards
Below, Figure 3. Southern California Landslide and Hazard Zones expands upon the map included in the On Shaky Ground report; during an earthquake liquefaction of soil and landslides represent some of the greatest hazards. Liquefaction refers to the solid earth becoming “liquid-like”, whereas water-saturated, unconsolidated sediments are transformed into a substance that acts like a liquid, often in an earthquake. By undermining the foundations of infrastructure and buildings, liquefaction can cause serious damage. The highest hazard areas shown by the liquefaction hazard maps are concentrated in regions of man-made landfill, especially fill that was placed many decades ago in areas that were once submerged bay floor. Such areas along the Bay margins are found in San Francisco, Oakland and Alameda Island, as well as other places around San Francisco Bay. Other potentially hazardous areas include those along some of the larger streams, which produce the loose young soils that are particularly susceptible to liquefaction. Liquefaction risks have been estimated by USGS and CGS specifically for the East Bay, multiple fault-slip scenarios for Santa Clara and for all the Bay Area in separate assessments. There are not regional liquefaction risk estimate maps available outside of the bay area, although the CGS has identified regions of liquefaction and landslide hazards zones for the metropolitan areas surrounding the Bay Area and Los Angeles. These maps outline the areas where liquefaction and landslides have occurred in the past and can be expected given a standard set of conservative assumptions, therefore there exist certain zoning codes and building requirements for infrastructure.
Figure 3. California Liquefaction/Landslide Hazards and Class II Injection Wells
Press Contacts
For more information about this report, please reach out to one of the following media contacts:
Arbelaez, J., Wolf, S., Grinberg, A. 2014. On Shaky Ground. Earthworks, Center for Biological Diversity, Clean Water Action. Available at ShakyGround.org
Jones, L.M. et al. 2008. The Shakeout Scenario. USGS Open File Report 2008-1150. U.S. Department of the Interior, U.S. Geological Survey.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2014/03/shakyground-cover.jpg600464Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2014-03-15 20:37:072020-07-21 10:42:23Class II Oil and Gas Wastewater Injection and Seismic Hazards in CA
By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance
California Regulations.
As confusing as you may think the regulatory structure is in your state (if you are not fortunate enough to be a Californian), just know that California’s regulatory structure is more complicated. Nothing in California’s recent history has clarified this point like the current debate over “fracking” regulations (hydraulic fracturing, as well as acidizing and other stimulation techniques). Since the passage of California State Bill 4 (SB-4), there have been significant concerns for self-rule and self-determination for individual communities. Further complicating the issue are the fracking activities being conducted from the offshore oil rig platforms located in federal waters. In addition to federal regulation, the California Department of Conservation’s Division of Oil, Gas, and Geothermal Resources is the premier regulatory authority for oil and gas drilling and production in the state. The State Water Resources Control Board and the Regional Water Quality Control Board hold jurisdiction over the states surface and groundwater resources, while the California Air Districts regulate air quality along with the California Air Resources Board. It is no surprise that a report published by the Wheeler Institute from the University of California, Berkeley found that this regulatory structure where several state and federal agencies share responsibility is not conducive to ensuring hydraulic fracturing is conducted safely.[1]
A Ban in Los Angeles, CA
The most recent local regulatory activity comes from the Los Angeles City Council. On Friday February 28, 2014, the City Council voted on and passed a resolution to draft language for a citywide ban of all stimulation techniques. The resolution calls for city zoning code to be amended in order to prohibit hydraulic fracturing activities in L.A. until the practices are proven to be safe. A final vote will then be cast to approve the final language. If it passes, Los Angeles will be the largest city in the United States to ban hydraulic fracturing. The FracTracker “Local Actions and Regulations Map” has been updated to include the Los Angeles resolution/ordinance, as well as the resolution supporting a statewide ban by the San Francisco Board of Supervisors, the moratorium in Santa Cruz County, and a resolution by the University of California, Berkeley Student Government. See all California’s local actions and regulations in the figure below. Click on the green checked boxes for a description of each action.
Click on the arrows in the upper right hand corner of the map for the legend and to view the map fullscreen.
State Bill 4 Preemption
Since the passage of California’s new regulatory bill SB-4, there has been a lot of confusion and debate whether the new state regulations preempt local jurisdictions from passing their own laws and regulations, and specifically moratoriums and bans. The county of Santa Cruz has a moratorium on fracking, but it was passed prior to the enactment of SB-4. Additionally Santa Cruz County is not a hotbed of drilling activity like Los Angeles or Kern. The team of lawyers representing the county of Ventura, where wells are actively being stimulated, came to a very different conclusion than the Los Angeles City Council. After reviewing SB-4, Ventura County came to the conclusion that lower jurisdictions were blocked from enacting local moratoriums. Draft minutes from the December 17, 2013 meeting quote, “The legal analysis provided by County Counsel indicates that the County is largely preempted from actively regulating well stimulation treatment activities at both new and existing wells. However, the County is required under CEQA to assess and address the potential environmental impacts from such activities requiring a discretionary County approval of new well sites.”[2]
On the other hand, independent analyses of the language in California SB-4 show that the legal-ese does not contain any provision that supersedes related local regulations. Rather, the bill preserves the right of local governments to impose additional environmental regulations.[3] The regulations do not expressively comment on the ability of local regulations to pass a moratorium or permanent ban. Additionally, DOGGR has supported a court decision that the SB-4 language expressly prohibits the state regulatory agency from enforcing the California Environmental Quality Act (according to the Division of Oil, Gas and Geothermal Resources).[4] As for local measures, a recent article by Edgcomb and Wilke (2013) provides multiple examples of precedence in California and other states for local environmental bans and regulations in conjunction with less restrictive state law.[3] Of course, any attempt to pass a ban on fossil fuel extraction or development activities where resource development is actively occurring will most likely be met with litigation and a lawsuit from industry groups such as the Western States Petroleum Association. Industry representatives charge that the ordinance is an unconstitutional “taking” of previously leased mineral rights by private property owners.[5,6] Pay close attention to this fight in Los Angeles, as there will be repercussions relevant to all local governments in the state of California, particularly those considering bans or moratoriums.
[1] Kiparsky, Michael and Hein, Jayni Foley. 2013. Regulation of Hydraulic Fracturing in California, a Wastewater and Water Quality Perspective. Wheeler Institute for Water Law and Policy. Center for Law Energy and the Environment, University of California Berkeley School of Law.
[2] Ventura County Board of Supervisors. December 17, 2013. Meeting Minutes and Video. Accessed March 2, 2014. [http://www.ventura.org/bos-archives/agendas-documents-and-broadcasts]
[2] Edgcomb, John D Esq. and Wilke, Mary E Esq. January 10, 2014. Can Local Governments Ban Fracking After New California Fracking Legislation? Accessed March 3, 2014. [http://californiafrackinglaw.com/can-local-governments-ban-fracking-after-new-california-fracking-legislation/]
[3] Hein, Jayni Foley. November 18, 2013. State Releases New Fracking Regulations amid SB 4 Criticism, Controversy. Accessed February 27, 2014. [http://blogs.berkeley.edu/2013/11/18/state-releases-new-fracking-regulations-amid-sb-4-criticism-controversy/]
[4] Fine, Howard. February 28, 2014. L.A. Council Orders Fracking Moratorium Ordinance. Los Angeles Business Journal. [http://labusinessjournal.com/news/2014/feb/28/l-council-orders-fracking-moratorium-ordinance/]
[5] Collier, Robert. March 3, 2014. L.A. fracking moratorium – the difficult road ahead. Climate Speak. Accessed March 4, 2014. [http://www.climatespeak.com/2014/03/la-fracking-moratorium.html]
[6] Higgins, Bill. Schwartz, Andrew. Kautz, Barbara. 2006. Regulatory Takings and Land Use Regulation: A Primer for Public Agency Staff. Institute for Local Government. Available at [http://www.ca-ilg.org/sites/main/files/file-attachments/resources__Takings_1.pdf]
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2014/03/CA-Local-govt-actions-map-thumb.jpg505394Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2014-03-04 17:25:552020-07-21 10:41:55What Does Los Angeles Mean for Local Bans and Moratoria in California?
Many people ask us how many wells have been hydraulically fractured in the United States. It is an excellent question, but not one that is easily answered; most states don’t release data on well stimulation activities. Also, since the data are released by state regulatory agencies, it is necessary to obtain data from each state that has oil and gas data to even begin the conversation. We’ve finally had a chance to complete that task, and have been able to aggregate the following totals:
Oil and gas summary data of drilled wells in the United States.
While data on hydraulically fractured wells is rarely made available, the slant of the wells are often made accessible. The well types are as follows:
Directional: Directional wells are those where the top and the bottom of the holes do not line up vertically. In some cases, the deviation is fairly slight. These are also known as deviated or slant wells.
Horizontal: Horizontal wells are directional wells, where the well bore makes something of an “L” shape. States may have their own definition for horizontal wells. In Alaska, these wells are defined as those deviating at least 80° from vertical. Currently, operators are able to drill horizontally for several miles.
Directional or Horizontal: These wells are known to be directional, but whether they are classified as horizontal or not could not be determined from the available data. In many cases, the directionality was determined by the presence of directional sidetrack codes in the well’s API number.
Vertical: Wells in which the top hole and bottom hole locations are in alignment. States may have differing tolerances for what constitutes a vertical well, as opposed to directional.
Hydraulically Fractured: As each state releases data differently, it wasn’t always possible to get consistent data. These wells are known to be hydraulically fractured, but the slant of the well is unknown.
Not Fractured: These wells have not been hydraulically fractured, and the slant of the well is unknown.
Unknown: Nothing is known about the slant, stimulation, or target formation of the well in question.
Unknown (Shale Formation): Nothing is known about the slant or stimulation of the wells in question; however, it is known that the target formation is a major shale play. Therefore, it is probable that the well has been hydraulically fractured, with a strong possibility of being drilled horizontally.
Wells that have been hydraulically fractured might appear in any of the eight categories, with the obvious exception of “Not Fractured.” Categories that are very likely to be fractured include, “Horizontal”, “Hydraulically Fractured”, and “Unknown (Shale Formation),” the total of which is about 32,000 wells. However, that number doesn’t include any wells from Texas or Colorado, where we know thousands wells have been drilled into major shale formations, but the data had to be placed into categories that were more vague.
Oil and gas wells in the United States, as of February 2014. Location data were not available for Maryland (n=104), North Carolina (n=2), and Texas (n=303,909). To access the legend and other map tools, click the expanding arrows icon in the top-right corner.
The standard that we attempted to reach for all of the well totals was for wells that have been drilled but have not yet been plugged, which is a broad spectrum of the well’s life-cycle. In some cases, decisions had to be made in terms of which wells to include, due to imperfect metadata.
No location data were available for Maryland, North Carolina, or Texas. The first two have very few wells, and officials in Maryland said that they expect to have the data available within about a month. Texas location data is available for purchase, however such data cannot be redistributed, so it was not included on the map.
It should not be assumed that all of the wells that are shown in the map above the shale plays and shale basin layers are actually drilled into shale. In many cases, however, shale is considered a source rock, where hydrocarbons are developed, before the oil and gas products migrate upward into shallower, more conventional formations.
The raw data oil and gas data is available for download on our site in shapefile format.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2014/03/US-ShaleViewer-Feature.jpg400900Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2014-03-04 12:37:152020-07-21 10:41:55Over 1.1 Million Active Oil and Gas Wells in the US
By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance
Introduction
California passed State Bill 4 (SB4) in September, 2013 to develop and establish a regulatory structure for unconventional resource extraction (hydraulic fracturing, acidizing, and other stimulation techniques) for the state. As a feature of the current version of the regulations, oil and gas drilling/development operators are required to notify the California Department of Conservation’s Division of Oil Gas and Geothermal Resources (DOGGR), as well as neighboring property owners, 30 days prior to stimulating an oil or gas well. In addition to property owners having the right to request baseline water sampling within the the following 20 days, DOGGR posts the well stimulation notices to their website.
Current State of Oil and Gas Production
The DOGGR dataset of well stimulation notices was downloaded, mapped, the dataset explored, and well-site proximity to certain sites of interest were evaluated using GIS techniques. First, the newest set of well stimulation notices, posted 1/17/14 were compared to a previous version of the same dataset, downloaded 12/27/13. When the two datasets are compared there are several distinct differences. The new dataset has an additional field identifying the date of permit approval and fields for latitude/longitude coordinates. This is an improvement, but there is much more data collected in the DOGGR stimulation notification forms that can be provided digitally in the dataset, including sources of water, amount of water used for stimulation, disposal methods, etc… An additional 60 wells have been added to the dataset, making the total count now 249 stimulation notices, with 37 stimulated by acid matrix (acidizing), 212 hydraulically fractured, and 3 by both. Of the 249, 59 look to be new wells as the API identifcation numbers are not listed in the DOGGR “AllWells.zip” database here, while 187 are reworks of existing wells. A difference of particular interest is the discrepancy in latitudes and longitudes listed for several well-sites. The largest discrepancy shows a difference of almost 10,000 feet for an Aera Energy well (API 3051341) approved for stimulation December 23, 2013. The majority of the well stimulations (246/249) are located in Kern County, and the remaining three are located in Ventura County.
Figure 1. Stimulation Notices and Past/Present Oil and Gas Wells Click on the arrows in the upper right hand corner of the map for the legend and to view the map fullscreen.
Well Spacing
As can be seen in Figure 1, the well stimulations are planned for heavily developed oil and gas fields where hydraulic fracturing has been used by operators in the past. California is the 4th largest oil producing state in the nation, which means a high density of oil and gas wells. Many other states limit the amount of wells drilled in a set amount of space in support of safer development and extraction. In Ohio, unconventional wells (>4,000 foot depths) have a 1,000 foot spacing requirement , West Virginia has a 3,000 foot requirement for deep wells , and the Texas Railroad Commission has set a 1,200 foot well spacing requirement. Using Texas’s setback as an example buffer for analysis, 241/249 of the DOGGR new stimulations are within 1,200 feet of an active oil and gas well. Of the 364 hydraulically fractured oil and gas wells DOGGR has listed as “New” (they are not yet producing, but are permitted and may be in development), 351 are within 1,200 feet of a well identified in DOGGR’s database as an active oil and gas well. One of the industry promoted benefits of using stimulations such as hydraulic fracturing is the ability to decrease the number of well-sites necessary to extract resources and therefore decrease the surface impact of wells. This does not look to be the practice in California.
Environmental Media
Following this initial review of oil and gas production/development, three additional maps were created to visualize the environmental media threatened by contamination events such as fugitive emissions, spills or well-casing failures. The maps are focused on themes of freshwater resources, ambient air quality, and conservation areas.
Freshwater Resources
Figure 2. New Wells, Stimulation Notices and California’s Freshwater Resources Click on the arrows in the upper right hand corner of the map for the legend and to view the map fullscreen.
Freshwater resources are limited in arid regions of California, and the state is currently suffering from the worst drought on record. In light of these issues, the FracMapper map “New Well Stimulations and California Freshwater Resources” includes map layers focused on groundwater withdrawals, groundwater availability, Class II wastewater injection wells, watershed basins, and the United States Geological Survey’s (USGS) National Hydrography Data-set (NHD). Since California does not have a buffer rule for streams and waterways, we used the setback regulation from Pennsylvania for an analysis of the proximity of the well stimulation notices to streams and rivers. In Pennsylvania, 300 feet is the minimum setback allowed for hydraulic fracturing near recognized surface waters. Of the 246 wells listed for new stimulation, 26 are within 300 feet of a waterway identified in the USGS’s NHD. The watersheds layer shows the drainage areas for these well locations. As a side note, the state of Colorado does not allow well-sites located within 100 year flood plains after the flash floods in September 2013 that caused over 890 barrels of oil condensates to be spilled into waterways. Also featured in Figure 2 are the predominant shallow aquifers in California. The current well stimulations posted by DOGGR are located in the Elk Hills (Occidental Inc.), Lost Hills (Chevron), Belridge and Ventura (both Aera Production) oil fields and have all exempted out of a groundwater monitoring plans based on aquifer exemptions, even though the aquifers are a source of irrigation for the neighboring agriculture. Stimulation notices by Vintage Production in the Rose oil field, located in crop fields on farms, are accompanied by a groundwater and surface water monitoring plan. Take notice of the source water wells on the map that provide freshwater for both the acidizing and hydraulic fracturing operations and the Class II oil and gas wastewater injection wells that dispose of the produced waters. Produced wastewaters may also be injected into Class II enhanced oil recovery water flood wells, and several of the stimulation notices have indicated the use of produced waters for hydraulic fracturing.
Ambient Air Quality
Figure 3. California New Wells, Stimulation Notices and Air Quality Click on the arrows in the upper right hand corner of the map for the legend and to view the map fullscreen.
Impacts to ambient air quality resulting from oil and gas fields employing stimulation techniques have been documented in areas like Wyoming’s Upper Green River Basin , the Uintah Basin of Utah , and the city of Dish, Texas . Typically, ozone is considered a summertime issue in urban environments, but the biggest threat to air quality in these regions has been elevated concentrations of ozone, particularly in the winter time. Ozone levels in these regions have been measured at concentrations higher than would typically be seen in Los Angeles or New York City. In Figure 3, the state and federal ozone attainment layers show that the areas with the highest concentrations of “new” wells and the DOGGR New Stimulation Notices do not pass ambient air criteria standards to qualify as “attainment” status for either state or federal ambient ozone compliance, meaning their ambient concentrations reach levels above health standards. Other air pollutants known to be released during oil and gas development, stimulation, and production include volatile organic compounds (VOCs) such as Benzene, Toluene, Ethylbenzene and xylene (BTEX); carbon monoxide (CO); hydrogen sulfide (H2S), Nitrogen Oxides (NOx), and sulfur dioxide (SO2), and methane (CH4), a potent greenhouse gas. It is important to point out that ground level ozone is not emitted directly but rather is created by chemical reactions between NOx and VOCs. Besides ozone, all these other air pollutants are in “attainment” in California except NOx in Los Angeles County. There have not been any stimulation notices posted in Los Angeles County, but the South Coast Air Quality Monitoring District identifies 662 recent wells that have been stimulated using hydraulic fracturing, acidizing, or gravel packing. See the Local Actions map of California for these well sites.
Conservation Areas
Figure 4. New Wells, Stimulation Notices and Conservation Areas Click on the arrows in the upper right hand corner of the map for the legend and to view the map fullscreen.
The map in Figure 4, “New Well Stimulations and Conservation Lands”, features land use planning maps developed by California and Federal agencies for conservation of the environment for multiple uses, ranging from recreation to farming and agriculture. Many of the Stimulation Notices as well as “new” well sites located in Kern County are located in or along the boundary of the San Joaquin Valley Conservation Opportunity; land identified by the California Department of Fish and Game, Parks and Recreations, and Transportation (Caltrans) as important for wildlife connectivity. Oil and gas development inevitably results in loss of habitat for native species. Habitat disturbance and fragmentation of the natural ecosystems can pose risks particularly for endangered species like the San Joaquin Kit Fox, California Condor, and the blunt-nosed leopard lizards.
The California Rangeland Priority Conservation Areas layer was created to identify the most important areas for priority efforts to conserve the Oak Savannah grasslands of high diversity that host many grassland birds, native plants, and threatened vernal pool species. The areas of high biodiversity value are marked in red as “critical conservation areas”. The majority of the new well stimulations are encroaching on the borders of these “critical areas,” particularly in the Belridge oil field. The CA Farmland Mapping and Monitoring Program map layer rates land according to soil quality to analyze impacts on California’s agricultural resources. The majority of new stimulations and new oil wells are located on the border of areas designated as “prime farmland,” particularly the Belridge and Lost Hills fields. The Rose field on the other hand is located within the “prime farmland” and “farmland of statewide importance.” Also, well-sites from all fields in Kern County are located on Williamson Act Agricultural Preserve Land Parcels. By enrolling in the program these areas can take advantage of reduced tax rates as they are important buffers to reduce urban sprawl and over-development. Although the point of the act was to protect California’s important farmland and agriculture, some parcels enrolled in the Williamson Agricultural Preserve Act program even house stimulation notice sites and “new” hydraulically fractured wells.
Discussion
While allowing hydraulic fracturing, acidizing and other stimulations until January 1, 2015 under temporary regulations, SB4 requires the state of California to complete an Environmental Impact Review (EIR). New regulations will then be developed on the recommendations of the EIR. The regulations will be enforced by the Division of Oil, Gas, and Geothermal Resources (DOGGR), the agency currently responsible for issuing drilling permits to operators in the state. In some municipalities of California, an additional “land-use” development permit is required from the local land-use agency (Air district, Water District, County, other local municipality or any combination) for an operator to be granted permission to drill a well. In most areas of California a “land-use” permit is not required, and only the state permit from DOGGR is necessary. A simple explanation is DOGGR grants the permit for everything that occurs underground, and in some locations a separate regulatory body approves the permit for what occurs above the ground at the surface. The exceptions are San Benito County which has a 500 foot setback from roads and buildings, Santa Cruz County, which passed a moratorium, Santa Barbara with a de facto ban*, and the South Coast Air quality Monitoring District’s notification requirements, permitting a well stimulation (such as “fracking” or “acidizing”). For the rest of the state permitting a well stimulation is essentially the same as permitting a conventional well-site, although it should be recognized that some counties like Ventura have setback and buffer provisions for all (conventional and unconventional) oil and gas wells. Additionally, DOGGR’s provisional regulations do require chemical disclosures to FracFocus and public notifications to local residents 30 days in advance, but lacks public health and safety provisions such as setbacks, continuous air monitoring, and the majority of wells in the notices are exempt from groundwater monitoring, While public notifications and chemical disclosures are all important for liability and tracking purposes, they are no substitute for environmental and engineering standards of practice including setbacks and other primary protection regulations to prevent environmental contamination. The state-sponsored EIR is intended to inform these types of rules, but that leaves a year of development without these protections. *Santa Barbara County requires all operators using hydraulic fracturing to obtain an oil drilling production plan from the Santa Barbara County Planning Commission. No operator has applied for a permit since the rule’s passing in 2011.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2014/01/Screen-Shot-2014-01-31-at-9.54.49-AM-e1457121535831.png317765Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2014-01-31 15:18:252020-07-21 10:41:53Mapping California’s State Bill 4 (SB4) Well Stimulation Notices
By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance
On October 16th, the Environmental Defense Center released a report focused on the use of hydraulic fracturing by offshore oil drilling platforms off the coast of California.1 The full report can be found on the EDC’s website. I was asked to assist in creating the report’s GIS maps, the results of which are described partially in the article below and are shown on the right. An interactive map of this data, overlaid with additional data layers including oil spills and offshore wells is below.
Regulation of Offshore Drilling
California has 24 offshore oil rigs, with only one of them located, and therefore regulated, in state waters. In the map below, the regulated platform is labeled as “Holly.” The rest of the platforms, including platform “A” which was responsible for the Santa Barbara oil spill of 1969, are located in federal waters beyond the “outer continental shelf” (OCS) boundary, shown in the map with a dashed line.
International, federal, and state laws are interrelated legal regimes that impact development of offshore oil, gas and other mineral resources in the US. Governance is bifurcated between state and federal law. States have authority in the “three-geographical-mile” area extending from their coasts. Federal regulatory regime governs minerals located under federal waters that extend out past state boundaries at least 200nautical miles from shore. This is known as the “exclusive economic zone,” for which coastal nations have the sovereign right to explore, exploit, conserve, and manage marine resources. The basis for most federal regulations is the Outer Continental Shelf Lands Act (OCSLA), which provides the system for offshore oil and gas exploration, leasing, and ultimate development. Regulations range from health, safety, resource conservation and environmental standards to requirements for production-based royalties and in some cases royalty relief and other development incentives. The moratoria on offshore leasing on many areas of the outer continental shelf were lifted in 2008 by President Bush and the 110th congress. Prior to that, several areas were made available for leasing in 2006 including the Aleutians and the Gulf. Recent changes to authorities regulating offshore development resulted after the Mineral Management Service was implicated in numerous scandals, including uncollected royalties estimated to amount to $160 million in 2006 alone.2 Offshore resource extraction is now regulated by the Bureau of Ocean Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement, both agencies of the Department of the Interior.
Investigating Hydraulic Fracturing
A recent freedom of information act request filed by the Environmental Defense Center (the group was formed in response to the 1969 Santa Barbara oil spill) identified 15 offshore drilling operations that used hydraulic fracturing. (Update: recent information from the FOIA shows 203 frac’ing operations from 6 different rig platforms!)4. This number is most likely a vast underestimation, as the Bureau of Safety and Environmental Enforcement (BSEE) estimates 12% of offshore operations in the Gulf use hydraulic fracturing. These “frac” operations were conducted without notifying the necessary regulatory agencies. The majority of this activity was conducted from the platforms Gilda and Gail, both labeled in the maps. While these offshore energy resources may be oil-rich, the fossil fuel resources pale in comparison to the biodiversity and ecological productivity of the Santa Barbara Channel and the California Channel Islands. The geography of the Channel Islands was formed by the cold-water swells of Northern California meeting with the warm-water swells of Southern California. This convergence resulted in a plethora of ecological microcosms in addition to the critical and sensitive habitats of endangered and threatened species shown in the maps.
Recently, the Department of the Interior approved four more hydraulic fracturing operations at these offshore platforms. Take note of the many ecological preserves and areas of protected/sensitive habitat in the midst of the many offshore wells and platforms. The map layer showing historic oil spills deserves special attention, with focus on the spills at platforms Gail and Gilda. Seeing this, it is alarming that the proposals were not required to conduct environmental impact assessments, and were instead granted “categorical exemptions” from the environmental analyses and public transparency actions strictly required by the National Environmental Policy Act. These actions (or lack thereof) in such an ecologically complex environment, especially considering it is the historical site of the US’s third largest oil spill, raises serious questions of compliance with other federal laws including the Clean Water Act, Endangered Species Act, Marine Mammal Protection Act, and Coastal Zone Management Act.3
Policy Recommendations
Additionally, the EDC report makes several policy recommendations:
Place a moratorium on offshore hydraulic fracturing, or “fracking,” and other forms of well stimulation unless and until such technologies are proven safe through a public and transparent comprehensive scientific review
Prohibit the use of categorical exclusions to authorize offshore fracking and other forms of well stimulation
Formally evaluate offshore fracking and other forms of well stimulation through a Programmatic Environmental Impact Statement
Initiate consistency reviews with the California Coastal Commission for all exploration plans, development plans, drilling or modification proposals involving fracking
Ensure that all fracking proposals comply with the Endangered Species Act and Marine Mammal Protection Act
Review and revise the Clean Water Act permit governing offshore oil platforms to directly address chemicals in frac flowback and other wastewater, either establishing effluent limitations for those chemicals or denying discharge altogether
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2013/10/Offshore-CA-Feature.jpg400900Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2013-10-20 18:07:042020-07-21 10:41:35Hydraulic Fracturing Offshore Wells on the California Coast
By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance
The potential for large scale oil development in the Monterey and other shale basins has raised concern in California communities over the use of hydraulic fracturing and other unconventional well stimulation techniques, such as acidizing. The fact that DOGGR was not tracking the use of these techniques, much less regulating them, has led to a variety of actions being taken by local governments. Several groups including county directors, city councils, and neighborhood and community councils have passed resolutions supporting state-wide bans on hydraulic fracturing and other controversial stimulation techniques. As can be seen in the following map, several of them are located within the greater LA metropolitan area, which is currently considering a local moratorium.
This map shows the local civic groups [green check marks] in the LA metropolitan area that have passed resolutions supporting statewide bans/moratoriums on hydraulic fracturing and other controversial stimulation activities. Click on the map to view larger image.
Two local jurisdictions, the South Coast Air Quality Management District and the County of Santa Barbara, have enacted their own measures to regulate oil and gas development. Both require notification of drilling techniques, and Santa Barbara County requires operators to file for a unique permit when using hydraulic fracturing. Data from the county of Santa Barbara’s permitting program was not readily accessible – although it may well be that they have not issued any permits. The South Coast Air Quality Management District is charged with managing the air quality for Orange County, the city of Los Angeles and the surrounding urban centers of Riverside and San Bernardino. In the spring of 2013, the SCAQMD passed Southern California rule 1148.2. The rule requires oil operators to submit specific reports of well activity documenting drilling, chemical use and the well stimulation techniques employed, directly to the SCAQMD. Reportable methods include acidification, gravel packing, and hydraulic fracturing. The rule was implemented June 2, 2013. The database of well-site data is readily accessible via the web. Web users can obtain individual well summaries of drilling activity and chemical-use reports, or download the full data sets. The site is user-friendly and the data is easily accessible. Unfortunately, the currently available data set is missing some of the most important information, specifically well API numbers – the unique identifier for all wells drilled in the United States. This data gap makes it impossible to compare or cross-reference this data set with others.
FracTracker has mapped the well-sites reported on the SCAQMD in the new map on the California page titled California Local Actions, Monitoring and Regulations. This map outlines the boundaries of SCAQMD and other sub-state regulatory agencies that have elected to manage the drilling activity. Details on the programs are provided in the map layers. The data published by the SCAQMD has been included in the map. In the map above, if you compare the SCAQMD data layer to the Hydraulically Fractured dataset derived by combining DOGGR and FracFocus data, you can see that the two data sets do not look to include the same well sites. Unfortunately, it cannot be known whether this is merely an issue of slightly dissimilar coordinates or legitimate data gaps; the SCAQMD data set lacks the API identifier for the majority of well sites reported. Because the regulatory landscape tends to follow the political leadership that reflects the interests of the constituency, legislative districts have also been included as a viewable map layer. Be active in your democracy.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2013/09/AQMD-Wellsites.jpg4471052Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2013-09-07 14:20:492020-07-21 10:41:19Local Actions and Local Regulations in California
By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance
Environmental regulations in California are considered conservative by most state standards. To name a few practices, the state has developed an air quality review board that conducts independent toxicological assessments on a level competitive with the U.S. EPA, and the state instituted the U.S.’s first green house gas cap and trade program. But most recently the California Department of Conservation’s Division of Oil, Gas and Geothermal Resources (DOGGR) has been criticized in the media for its lack of monitoring of hydraulic fracturing activity. DOGGR has been responsive to criticism and preemptive of legislative action and has begun a full review of all well-sites in California to identify which wells have been hydraulically fractured and plan to monitor future hydraulic fracturing. Additionally they have maintained historical records of all wells drilled, plugged, and abandoned in the state in web-accessible databases, which include data for oil and gas, geothermal, and injection wells, as well as other types of support wells such as pressure maintenance, steam flood etc.. The data is also viewable in map format on the DOGGR’s online mapping system (DOMS).
To understand what is missing from the DOGGR dataset, it was compared to the dataset extracted from FracFocus.org by SkyTruth. The map “Hydraulic Fracturing in California” compares these two datasets, which can be viewed individually or together as one dataset with duplicates removed. It is interesting to note the SkyTruth dataset categorizes 237 wells as hydraulically fractured that DOGGR does not, and identifies three wells (API #’s 11112215, 23727206, and 10120788) not identified in the DOGGR database. For the some of these 237 wells, DOGGR identifies them as new, which means they were recently drilled and hydraulically fractured and DOGGR will be updating their database. Many are identified as active oil and gas wells., while the rest are identified as well types other than oil and gas. Also the SkyTruth dataset from FracFocus data contains additional information about each well-site, which DOGGR does not provide. This includes volumes of water used for hydraulic fracturing and the fracture date, both of which are vital pieces of monitoring information.
The California State Legislature is currently reviewing California Senate Bill 4 (CA SB 4) written by Sen. Fran Pavley (D-Agoura Hills), which would put in place a regulatory structure for permitting and monitoring hydraulic fracturing and other activity. A caveat for acidification is also included that would require companies to obtain a specific permit from the state before acidizing a well. The bill has received criticism from both industry and environmentalists. While it does not call for a moratorium or regulate what chemicals are used, it is the first legislation that requires a full disclosure of all hydraulic fracturing fluid additives, including those considered proprietary. This is the last of at least seven bills on the issue, the majority of which have been turned down by lawmakers. The most conservative bills (Assemblywoman Mitchell; D-Culver City) proposed moratoriums on hydraulic fracturing in the state. Earlier this year lawmakers approved a bill (Sen. Pavley; D-Agoura Hills) that would direct the state to complete and independent scientific risk assessment of hydraulic fracturing. The bill directs permitters to deny permits if the study is not finished by January 1, 2015, and also requires public notice before drilling as well as disclosure of chemicals (besides those considered proprietary). In May, a bill (Sen. Wold; D-Davis) was passed requiring drillers to file a $100,000 indemnity bond for each well, with an optional blanket indemnity bond of $5 million for operators with over 20 wells. Another bill (Jackson; D-Santa Barbara) that would require monitoring of both transportation and disposal of wastewater was tabled until next year.
Although hydraulic fracturing has been conducted in California for over a decade, it was not monitored or regulated, and the majority of Californians were not aware of it. Industry groups have portrayed the lack of attention as a testament to its environmental neutrality, but Californians living smack dab in the middle of the drilling tend to tell a different story. The issue is now receiving attention because hydraulic fracturing is such a hotbed topic of contention, along with the potential future of the billions of barrels of oil in the Monterey Shale. The unconventional extraction technology necessary to recover the oil from these deep shale formations is state of the art, which means it is not tried and true. The methods include a combination of high tech approaches, such as horizontal drilling, high volume hydraulic fracturing, and acidification to name a few. Realize: if this technology existed for the last 60 years, the Monterey Shale would already have been developed long ago, along with the rest of the U.S. deep shale formations.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2013/08/California-Hydraulic-Fracturing-Map.jpg558493Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2013-08-23 20:37:582020-07-21 10:41:19Keeping Track of Hydraulic Fracturing in California
By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance
The FracTracker Alliance has just recently opened a new office based out of Berkeley, California. As a first step in addressing the unique issues of oil and gas extraction in the Golden State, FracTracker has queried the data that is published by the state’s regulatory agencies, and has translated those datasets into various maps that highlight specific issues. As a first step in this process, FracTracker transcribed the well-site data that is publicly available from the California Department of Conservation’s (DOC) Division of Oil, Gas and Geothermal Resources (DOGGR).
This first phase of analysis is presented in FracMapper on the California page, here. FracTracker has translated the entire DOGGR database into a map layer that can be viewed on the California Shale Viewer map, here. The California Shale Viewer will be continuously updated to map the expanding oil and gas development as it occurs. Featured map layers on the California Shale Viewer focus on hydraulic fracturing in the state of California. The hydraulic fracturing well-site data comes from two sources. First, the layer “CA Hydraulically Fractured Wells Identified by DOGGR” portrays the maps identified by regulatory agency as having been hydraulically fractured. The DOGGR is aware that their dataset is not complete in terms of identifying all wells that have been hydraulically fractured. The second source of data is from our friends at SkyTruth, and provided in the layer “CA Hydraulically Fractured Wells Identified by SkyTruth”. Using a crowd-source platform, SkyTruth has generated a dataset based on the information reported to FracFocus.org. FracFocus.org refuses to provide aggregated datasets of their well-site data. These hydraulically fractured well-sites can be viewed as a individual datasets in the California Shale Viewer, or as a combined layer in the map “California Hydraulically Fractured and Conventional Oil and Gas Wells” map, where you are also able to view the dataset of wells FracFocus identifies as hydraulically fractured, but DOGGR does not.
More information concerning the many different types of wells drilled in California and the status of these wells (whether they are planned, active, idle or plugged) can be found in the “Well Type” map and “Well Status” map, also available on the FracTracker California page.
By Kyle Ferrar, CA Program Coordinator, FracTracker Alliance
The “Science, Democracy, and Community Decisions on Fracking” forum hosted by The Union of Concerned Scientists focused on the full spectrum of the broad range of issues accompanying unconventional resource extraction and hydraulic fracturing. The meeting included a full day of roundtable discussions focused on three topics, with participants handpicked and assigned to one of three groups. Roundtable discussions with invited participants convened July 24th, with a public forum held the following day. Participants included leading thinkers and experts from academia, industry, nonprofit organizations, and government. The working groups focused on one of three topics:
The current state of science and technical knowledge
Public policy and the regulatory framework for managing development
Public Access to data and resources.
The FracTracker Alliance participated in the public access discussions. The chair(s) of each of the three committees presented their findings during the public forum on July 25th, followed by “dynamic public discussion.”
The public forum began with opening remarks from Kathleen Rest, Executive Director of UCS, and Edward A. Parson, Professor of law and Co-Director of the Emmet Center on Climate Change and the Environment at the UCLA Law School, and a warm greeting from U.S. Congressman Henry A Waxman, via telecast as Congress is currently in session. Opening remarks by Adrienne Alvord (UCS) introduced the three committees and their respective charges. A short video, filmed and produced by UCS, presenting the need for public awareness on the issue of hydraulic fracturing and unconventional resource development was then exhibited. The video can be found on the UCS website.
The committee discussing the current state of science and knowledge gaps was chaired by Kevin Hurst, former Assistant Director of energy R&D for the White House Office of Science and Technology Policy. In his presentation Kevin acknowledged the various risks of media contamination, including groundwater, soil, surface water, and air, that have occurred during both conventional and unconventional oil and gas extraction, but felt that his committee had reached an overall consensus within his group that when best practices are employed responsibly, these risks can be managed effectively. Specifically, the risks to groundwater and green-house gas emissions are relatively similar to the risks associated with conventional resource development (vertically drilled oil and natural gas wells that are not “frac’ed”). The risk management issues result from the scale of development. Proper management will necessarily require comprehensive monitoring plans, including all media as well as wildlife and public health, necessarily from industry but also from the public sector and citizens. Monitoring will need to be consistent, transparent, and widespread. For each particular failure that has been realized, there will need to be a collaboration between industry and regulatory bodies (state and federal) to drive down risk. For data collection on a comprehensive scale there will also need to be collaboration between public and private institutions for a coalition that supports public engagement.
Kate Konschnik, Policy Director of the Environmental Law and Policy program at the Harvard Law School and former chief environmental counsel to U.S. senator Sheldon Whitehouse, presented on behalf of the policy working group. Kate began by addressing what is working and what is not working in terms of the goals of the many interest groups focused on hydraulic fracturing issues. Among other interests they include moratoriums and a complete ban. In the case of local rural interests groundwater protection has been a main focus, whereas in urban communities it is typically a concern for air quality. On a global scale green-house gas emissions are the focus. On all levels these are progressive issues due to the difference of scale as compared to previous oil and gas activity in most parts of the United States. To manage this scale of development there are both regulatory and non-regulatory tools. Regulatory tools include roles for the federal, state, tribal, and local governments such as the role the EPA has in supporting green completions of well-heads, although they could be required as addressed in the clean air act. Non-regulatory bodies possess other tools such as shareholder interests and actions and third party certifications such as LEED certifications. In regards to regulatory action, there seems to be a lack of will to apply existing rules on the books, whereas there is also the capacity for new rules that need to be created in such a way that authority is shared without duplicating efforts and with clear response plans. Having government regulatory agencies lead the charge in data collection is important to inspire innovation to reduce risks, develop performance standards from the ground level and will address the trust issue for accountability and continued improvement of technologies. Information that needs to be collected includes baseline data and ongoing monitoring in a consistent format across multiple states, as well as chemical disclosures.
The third working group, focused on issues of public access to information, was chaired by Tom Wilbur, author of Under the Surface: Fracking, Fortunes, and the Fate of the Marcellus Shale and Shale Gas Review blog. Tom’s presentation centered on the question, “What can be done to help citizens seek, find, and digest information, while recognizing misinformation, so as to inform decision-making?” Answers should improve access to information that will in turn inform decision-making. The main findings were framed in terms of the best outcome for most people, such that public health and environmental health issues trump issues of trade secrets and non-disclosures. The first finding was that the sources of information need to be trusted, and community generated information is the most trusted. This includes the involvement of regulatory agencies, such as closing the loopholes in the Resource Conservation and Recovery Act of 1976 (hazardous wastes) and the Clean Water Act. Disclosure of all chemicals is therefore also necessary. The full process of data dissemination must also be considered, from translation of data to information, to synthesis of results and conclusions, and then explanations of the implications. Validation of all information by trusted sources is critical.
Additional presenters who had not participated in the roundtable discussions provided insight into the various themes, to tie the discussions together. Amy Jaffy Myers, Executive Director for energy and sustainability at the University of California-Davis, discussed global energy security economic, and geopolitics of frac’ing. Amy explained why the issue of energy independence is so important to the future of the United States. Everyone wants the freedom of mobility to drive cars on liquid fuel and warmth to heat their homes. In turn, the public’s demand for responsible policies should be responded with a commitment from the private sector. Felicia Marcus, Chair of the California State Water Resources Control Board provided the context for why the issue is so important in the State of California, and summarized the current set of draft rules and regulations that are currently being considered by the state legislature. They include provisions for monitoring, transparency, and bonding. Jose Bravo, executive director of the Just Transition Alliance, gave a moving talk about the environmental justice issues that have accompanied oil and natural gas development in California communities. Todd Platts, former U.S. Representative, gave a lecture on the need for information for community-empowerment as well as the need for transparency in a functioning democracy, and Andrew Rosenberg, Director of the Center for Science and Democracy and The Union of Concerned Scientist provided closing remarks, which summed up the entire conference with the words “Informed decisions need to be made on the merits.”
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2013/07/UCSLogo-115x1151.jpg116118Kyle Ferrar, MPHhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngKyle Ferrar, MPH2013-07-27 22:33:322020-07-21 10:41:17Science, Democracy, and Community Decisions on Fracking forum
By Brook Lenker, Executive Director, FracTracker Alliance
The FracTracker Alliance is coming to California. The generous support of the Palo Alto-based 11th Hour Project, a working program of the Schmidt Family Foundation, has enabled us to hire Kyle Ferrar, MPH to be our first program coordinator in the state. Kyle – an accomplished researcher who has studied the fate and effect of contaminants transported through environmental media and has extensive experience in GIS, policy analysis, and risk communication – will have his hands full. While California has a legacy of oil and gas development, the advent and scale of modern extraction technologies poses risks to the complexion of the landscape, the integrity of natural resources, the safety of agricultural commodities, the health of people and animals – wild and domestic – and the fabric of local communities. With two-thirds of the United States’ total estimated shale oil reserves in California’s Monterey Shale (a formation covering 1,750 square miles), the state could soon be overwhelmed by the demand for these energy riches.
In his new role with FracTracker, Kyle will collect and analyze data, develop maps and articles, train and coordinate volunteers, present and display at events and symposia, and network with a variety of organizations, agencies, and the news media – all toward improving the effectiveness and reach of our work. Our California operations will be based at the HUB in Berkeley. The HUB is an innovative shared workspace with maximum opportunity to connect to other people, organizations, and ideas. And if that work environment wasn’t inspiring enough, the HUB in Berkeley is located at the David Brower Center, a very green (LEED Platinum!) building and home to numerous conservation organizations.
Adding additional wisdom to our Pacific coast presence, FracTracker welcomes Brian Segee as the newest member of our board of directors. Brian is a Staff Attorney at the Environmental Defense Center in Santa Barbara, a group with a legacy of addressing oil issues and other topics of importance to FracTracker.
To Kyle, Brian, and the 11th Hour project, a great big thanks for your commitment to us and what we do. Together may we cast a helpful light in the golden state!
structure for unconventional resource extraction (hydraulic fracturing, acidizing, and other stimulation techniques) for the state. As a feature of the current version of the regulations, oil and gas drilling/development operators are required to notify the California Department of Conservation’s Division of Oil Gas and Geothermal Resources (DOGGR), as well as neighboring property owners, 30 days prior to stimulating an oil or gas well. In addition to property owners having the right to request baseline water sampling within the the following 20 days, DOGGR posts the well stimulation notices to their website.
