Recently, the Pennsylvania Department of Environmental Protection (DEP) started to offer additional data resources with the introduction of the Open Data Portal. This development, along with the continued evolution of the ArcGIS Online mapping platform that we utilize has enabled some recent enhancements in our mapping of Pennsylvania oil and gas infrastructure. We’ve made changes to the existing Pennsylvania Shale Viewer for unconventional wells, and created a Conventional and Historical Wells in Pennsylvania map.
Unconventional Wells
Rather than defining the newer, industrial-scaled oil and gas wells by specific geological formations, configuration of the well, or the amount of fluid injected into the ground during the hydraulic fracturing process, Pennsylvania’s primary classification is based on whether or not they are considered to be unconventional.
Unconventional Wells – An unconventional gas well is a bore hole drilled or being drilled for the purpose of or to be used for the production of natural gas from an unconventional formation. An unconventional formation is defined as a geologic shale formation below the base of the Elk Sandstone or its geologic equivalent where natural gas generally cannot be produced except by horizontal or vertical well bores stimulated by hydraulic fracturing.
The previous structure of the PA Shale Viewer had separate layers for permits, drilled wells, and violations. This version replaces the first two layers with a single layer of unconventional locations, which we have called “Unconventional Wells and Permits” for the sake of clarity. The violations layer appears in the same format as before. When users are zoomed out, they will see generalized layers showing the overall location of O&G infrastructure and violations in the state, which were formed by creating a one mile buffer around these features. As users zoom in, the generalized layers are then replaced with point data showing the specific wells and violations. At this point, users can click on individual points and learn more about the features they see on the map.
Figure 1. PA Shale Viewer zoomed in to see individual wells by status
O&G locations are displayed by their well status, as of the time that FracTracker processed the data, including: Abandoned, Active, Operator Reported Not Drilled, Plugged OG Well, Proposed but Never Materialized, and Regulatory Inactive Status. Note that just because a well is classified as Active does not mean that it has been drilled, or even necessarily permitted. These milestones, along with whether or not it has been plugged, can be determined by looking for entries in the permit issue date, spud date, and plug date entries in the well’s popup box.
Conventional and Historical Wells
The map below shows known conventional wells in Pennsylvania along with additional well locations that were digitized from historical mining maps.
Although there are over 19,000 unconventional oil and gas locations in Pennsylvania, this figure amounts to just 11% of the total number of wells in the state that the DEP has location data for, the rest being classified as conventional wells. Furthermore, in a state that has been drilling for oil and gas since before the Civil War, there could be up to 750,000 abandoned wells statewide.
The DEP has been able to find the location of over 30,000 of these historical wells by digitizing records from old paper mining maps. This layer has records for 16 different counties, but well over half of these wells are in just three counties – Allegheny, Butler, and Washington. It looks like it would take a lot more work to digitize these historical wells throughout the rest of the state, but even when that happens, we will probably still not know where the majority of the old oil and gas wells in the state are located.
An Ohio family took joy in raising their kids and cattle at their farmhouse, built in 1853 with crooked walls and no indoor bathrooms. When they leased land to fracking activity, however, the “beep, beep, beep” of heavy truck traffic kept them up all night, and a cow died after drinking a strange fluid flowing on the land during the cold of winter. They dedicated their retirement savings to moving and building a new home, only to soon after receive a compressor station as their neighbor – close enough to hear the engines at all hours and loud enough to make them dread even walking out to their mailbox.
During the upswing of a boom-and-bust cycle of the gas industry in Greene County, the influx of outside workers and the high demand on rental housing resulted in one particular family being unable to secure an apartment. Without adequate housing, their children were temporarily taken from their custody.
In Huntingdon, a young woman resisted a pipeline being forced through her property by stationing herself in a tree, while workers with chainsaws felled those around her. Eminent domain enabled the gas company to claim this privately-owned land under a weak guise of “public good.”
These unsettling but true stories hint at the countless ways fracking plays out in individual households. A healthy home environment – with clean air, potable drinking water, and safety from outside elements – is essential to human life and functioning. Yet, the industrial processes involved in unconventional oil and gas development (UOGD), often summed up with the term “fracking,” may interfere with or even take away the ability to maintain a healthy home.
This article aims to put these household impacts, and the right to a healthy home, at the center of the fracking debate.
Framing the issue
The way we understand just about anything depends on our frame of reference. A frame, like the frame around a picture, brings its contents into focus. At the same time, it excludes the information outside its borders. A frame declares that what’s inside is what matters. When it comes to the human effects of fracking, various conflicting frames exist, each dictating their own picture of what fracking actually does and means.
The frame we use to look at the fracking debate is so important, because it dictates how we talk about and think about the problem. Likewise, if we can identify the frame others are using when they talk about fracking, we can see more clearly what they have prioritized and what they are leaving out of the conversation.
Two researchers who conducted surveys, interviews, and focus groups in five Pennsylvania counties in 2014 and 2015 argue for the need for a new frame.1 Some of the common ways of talking about fracking not only favor shale gas development for reasons like those included in the frame on the left above, they also work against those trying to make a stand against the negative effects fracking. These researchers suggest that, rather than arguing within the existing, dominant frames, activists should consider proactively “reframing the debate around other core values.” The right to a healthy home is a widely-shared value. I propose we adopt a frame that puts that right at the center of the picture.
What is a “healthy home”?
The term healthy home isn’t new. The federal agencies Housing and Urban Development (HUD) and the Centers for Disease Control (CDC) both use this phrase in defining the importance of a home environment free from hazards and contaminants, like lead and radon. Simply put, a healthy home is one that supports health.
Why Now?
We sit poised at a unique moment to take on the task of reframing fracking. While new drilling in some places appears to be on the decline, countless large-scale petrochemical projects, like a growing crop of plastic-producing ethane crackers in the northeast US, are ramping up. These facilities will demand massive supplies of natural gas and byproducts, perpetuating and likely increasing drilling.
Engagement is urgent and timely,2 and the entire country has a role to play. This moment in our energy history is a chance for all of us – those affected by, in favor of, concerned about, eager to welcome, or otherwise learning about UOGD – to get clear on our frame of understanding fracking.
A pipeline right-of-way, about 200 yards behind this house and children’s swingset, shows how close fracking infrastructure comes to homes. Photo credit: Leann Leiter
Why a “Healthy Homes” Frame?
Proponents of frames that endorse fracking often live at a considerable distance from the processes involved,3 buffering them and their families from its impacts. According to researchers4 who listened to the testimonies of residents at a community hearing, the distance they lived from the industrial activities shows up in how they talk about fracking. Those in favor tend to use a depersonalized, “birds-eye view” in describing the impacts. People for whom the negative impacts are or will be a part of their lives rely on more descriptive, specific, and place-based language.
Similarly, a frame that focuses on household impacts emphasizes the on-the-ground, lived experience of living near fracking infrastructure. This frame approaches the debate on fracking by continually asking, what is this like for the people who live with the process? What are the impacts to their home environment? Such a frame does not ignore large-scale issues of jobs and energy supply, but grounds these bigger questions with the real and urgent consequences to the people who are suffering.
Household impacts
Despite rulings that define UOGD as an industrial process, drilling companies locate all manner of infrastructure – wells, pipelines, compressor stations, among others – in areas formerly residential or agricultural. Rules dictating distances from UOGD facilities to structures like houses vary by municipality and state. Yet, these new and often imposing facilities repeatedly occupy the immediate view of homes, or are within close proximity that defy medical and safety warnings.
Video: Glaring light of burning flares and noises both droning and sudden, along with major truck traffic and other changes to the immediate landscape around the household, produce high levels of stress, leading to its own health problems, creating an environment where water may become unsafe to drink and breathing the air becomes a hazard.
The Oil & Gas Threat Map (by Earthworks and FracTracker) shows the populations within a half-mile “threat radius” of infrastructure that includes fracking – close enough for residents to be exposed to contaminated air emissions, and possibly smell disturbing odors, hear loud sounds and feel vibrations, and see bright lights and the fire of emergency flares. As confirmed by the EPA, in some cases, UOGD results in contamination of drinking water, as well.
Researchers at The Environmental Health Project (EHP) offer individual health assessments to residents living in the shadow of fracking operations. In a physician’s thorough review of over 61 assessments, they identified the following symptoms to be temporally related to gas activity:
Table 1. Symptoms temporally related to UOGD
SYMPTOM CATEGORY
n
%
Symptom
n
%
UPPER RESPIRATORY SYMPTOMS
39
64%
Nose or throat irritation
25
41%
Sinus pain or infections
17
28%
Nose bleeds
8
13%
CONSTITUTIONAL SYMPTOMS
33
54%
Sleep disruption
26
43%
Fatigue
13
21%
Weak or Drowsy
9
15%
NEUROLOGICAL SYMPTOMS
32
52%
Headache
25
41%
Dizziness
11
18%
Numbness
9
15%
Memory loss
8
13%
PSYCHOLOGICAL SYMPTOMS
32
52%
Stress or anxiety
23
38%
Irritable or moody
12
20%
Worry
6
10%
LOWER RESPIRATORY SYMPTOMS
30
49%
Cough
21
34%
Shortness of breath
19
31%
Weezing
14
23%
GASTRO-INTESTINAL SYMPTOMS
27
44%
Nausea
13
21%
Abdominal pain
12
20%
EYE SYMPTOMS
23
38%
Itchy eyes
11
18%
Painful or dry
10
16%
DERMATOLOGICAL SYMPTOMS
19
31%
Rash
10
16%
Itching
7
11%
Lesions or blisters
6
10%
CARDIAC SYMPTOMS
17
28%
Palpitations
9
15%
Chest pain
6
10%
Other cardiac symptoms
6
10%
HEARING CHANGES OR TINNITUS
10
16%
Hearing loss
3
5%
Tinnitus (ringing in the ear)
10
16%
MUSCULOSKELETAL
10
16%
Painful joints
9
15%
Aches
7
11%
ENDOCRINE
7
11%
Hair loss
7
11%
n = Number of patients reporting symptom, out of 61 patients assessed
% = Percentage of patients reporting symptom, out of 61 patients assessed
Mental and emotional stress can exacerbate and create physical health symptoms. For households close to fracking, the fear of a disaster, like a well pad fire, or concern for the long term health effects of exposures through air and water can create serious stress. These developments change communities, sometimes in divisive, negative ways, potentially adding to the stress.
Fracking, a disruptive, landscape-altering process can also produce what’s called solastalgia, whereby negatively-perceived changes to the land alter a person’s sense of belonging. In the case of fracking in residential areas, people may lose not only their relationship to the land, but their homes as they once knew them.5 Solastalgia, considered by some researchers to be a new psycho-social condition, is “the lived experience of the physical desolation of home.”6
When Home is Unsafe, Where to Get Help
Click to expand and explore the tri-fold. Click here to access and print this free resource, and many others by EHP.
EHP offers a new resource for protecting your health at a household level, called: “Protecting Your Health from Unconventional Oil and Gas Development.” We created this free informational resource in collaboration with residents and health care providers in four different shale gas counties.
The final product is the direct result of input and knowledge from 15 focus groups and project meetings in these affected communities with over 100 participants, including residents and healthcare providers. EHP has packed this resource with practical steps for households amid shale gas development to limit their exposure to air and water contamination that may be associated with fracking.
For follow-up questions, or for free personalized health services for those experiencing fracking-related exposures, you can contact EHP directly at 724-260-5504 or by email at info@environmentalhealthproject.org.
Re-Centering Home in the Fracking Debate
Putting affected households at the center of the fracking debate better reflects the experiences of people on the front lines. This powerful frame could help counter the power of those who speak positively about fracking, but lack direct experience of the process.
For those at the frontlines of fracking, the intent is that these resources and tools will help you protect your health and your homes.
For those not yet directly affected by fracking, you can lend a hand. Show support for health protective measures by signing up at EHP for updates on events, education, and opportunities to make your voice heard. And, whenever and wherever you can weigh in on the debate, put a frame around fracking that puts impacted households at the center.
References
Cooley, R., & Casagrande, D. (2017). Marcellus Shale as Golden Goose. ExtrACTION: Impacts, Engagements, and Alternative Futures.
Short, D., Elliot, J., Norder, K., Lloyd-Davies, E., & Morley, J. (2015). Extreme energy, ‘fracking’ and human rights: a new field for human rights impact assessments?, The International Journal of Human Rights, 19:6, 697-736, DOI:10.1080/13642987.2015.1019219
Cooley, R., & Casagrande, D. (2017). Marcellus Shale as Golden Goose. ExtrACTION: Impacts, Engagements, and Alternative Futures.
Mando, J. (2016). Constructing the vicarious experience of proximity in a Marcellus Shale public hearing. Environmental Communication, 10(3), 352-364.
Resick, L. K. (2016). Gender, protest, and the health impacts of unconventional natural gas development. In Y. Beebeejaum (Ed.), The participatory city (pp. 167-175). Berlin: Jovis Verlag GmgH.
Albrecht et al (2007). Solastalgia: the distress caused by environmental change, Australasian Psychiatry . Vol 15 Supplement.
By Leann Leiter, Environmental Health Fellow for the SW-PA Environmental Health Project and FracTracker Alliance
Feature photograph: A compressor station sits above a beautiful farm in Washington County, Pennsylvania. Photo credit: Leann Leiter
In this forest fragmentation analysis, FracTracker looked at existing vegetation height in the northern portion of Pennsylvania’s Susquehanna River Basin. The vegetation height data is available from LANDFIRE, a resource used by multiple federal agencies to assess wildfire potential by categorizing the vegetation growth in 30 by 30 meter pixels into different categories. In the portion of Pennsylvania’s Susquehanna Basin where we looked, there were 29 total categories based on vegetation height. For ease of analysis, we have consolidated those into eight categories, including roads, developed land, forest, herbs, shrubs, crops, mines and quarries, and open water.
Methods
We compared the ratio of the total number of each pixel type to the type that was found at vertical and horizontal wells in the region. In this experiment, we hypothesized that we would see evidence of deforestation in the areas where oil and gas development is present. Per our correspondence with LANDFIRE staff, the vegetation height data represents a timeframe of about 2014, so in this analysis, we focused on active wells that were drilled prior to that date. We found that the pixels on which the horizontal wells were located had a significantly different profile type than the overall pixel distribution, whereas conventional wells had a more modest departure from the general characteristics of the region.
Figure 1 – Vegetation profile of the northern portion of Pennsylvania’s Susquehanna River Basin. The area is highly impacted by O&G development, a trend that is likely to continue in the coming years.
In Figure 1, we see that the land cover profile where vertical wells (n=6,198) are present is largely similar to the overall distribution of pixels for the entire study area (n=40,897,818). While these wells are more than six times more likely to be on areas classified as mines, quarries, or barren, it is surprising that the impact is not even more pronounced. In terms of forested land, there is essentially no change from the background, with both at about 73%. However, the profile for horizontal wells (n=3,787) is only 51% forested, as well as being four times more likely than the background to be categorized as herbs, which are defined in this dataset as having a vegetation height of around one meter.
Why Aren’t the Impacts Even More Pronounced?
While the impacts are significant, particularly for horizontal wells, it is a bit surprising that evidence of deforestation isn’t even more striking. We know, for example, that unconventional wells are usually drilled in multi-well pads that frequently exceed five acres of cleared land, so why aren’t these always classified as mines, quarries, and barren land, for example? There are several factors that can help to explain this discrepancy.
First, it must be noted that at 900 square meters, each pixel represents almost a quarter of acre, so the extent of these pixels will not always match with the area of disturbance. And in many cases, the infrastructure for older vertical wells is completely covered by the forest canopy, so that neither well pad nor access road is visible from satellite imagery.
The map above shows horizontal and vertical wells in a portion of Centre County, Pennsylvania, an area within our study region. Note that many of the vertical wells, represented by purple dots, appear to be in areas that are heavily forested, whereas all of the horizontal wells (yellow dots) are on a defined well pad in the lower right part of the frame. Panning around to other portions of Centre County, we find that vertical wells are often in a visible clearing, but are frequently near the edge, so that the chances of the 30 by 30 meter pixel that they fall into is much more likely to be whatever it would have been if the well pad were not there.
We must also consider that this dataset has some limitations. First of all, it was built to be a tool for wildfire management, not as a means to measure deforestation. Secondly, there are often impacts that are captured by the tool that were not exactly on the well site. For this reason, it would make sense to evaluate the area around the well pad in future versions of the analysis.
Figure 2 – A close up of a group of wells in the study area. Note that the disturbed land (light grey) does not always correspond exactly with the well locations.
In Figure 2, we see a number of light grey areas –representing quarries, strip mines, and gravel pits –with an O&G well just off to the side. Such wells did not get classified as being on deforested land in this analysis.
And finally, after clarifying the LANDFIRE metadata with US Forest Service personnel involved in the project, we learned that while the map does represent vegetation cover circa 2014, it is actually build on satellite data collected in 2001, which has subsequently been updated with a detailed algorithm. However, the project is just beginning a reboot of the project, using imagery from 2015 and 2016. This should lead to much more accurate analyses in the future.
Why Forest Fragmentation Matters
The clearing of forests for well pads, pipelines, access roads, and other O&G infrastructure that has happened to date in the Susquehanna Basin is only a small fraction of the planned development. The industry operates at full capacity, there could be tens of thousands of new unconventional wells drilled on thousands of well pads in the region through 2030, according to estimates by the Nature Conservancy. They have also calculated an average of 1.65 miles of gathering lines from the well pad to existing midstream infrastructure. With a typical right-of-way being 100 feet wide, these gathering lines would require clearing 20 acres. It isn’t unusual for the total disturbance for a single well pad and the associated access road to exceed ten acres, making the total disturbance about 30 acres per well pad. Based on the vegetation distribution of the region, we can expect that 22 of these acres, on average, are currently forested land. Taking all of these factors into consideration, a total disturbance of 100,000 to 200,000 acres in Pennsylvania’s Susquehanna River Basin due to oil and gas extraction, processing, and transmission may well be a conservative estimate, depending on energy choices we make in the coming years.
This forest fragmentation has a number of deleterious effects on the environment. First, many invasive plant species, such as bush honeysuckle and Japanese knotweed, tend to thrive in recently disturbed open areas, where competing native plants have been removed. The practice also threatens numerous animal species that thrive far from the forest’s edge, including a variety of native song birds. The disturbed lands create significant runoff into nearby rivers and streams, which can have an impact on aquatic life. And the cumulative release of carbon into the atmosphere is staggering – consider that the average acre of forest in the United States contains 158,000 pounds of organic carbon per acre. As the area is 73% forested, the total cumulative impact could result in taking 5.8 to 11.6 million tons of organic carbon out of forested storage. Much of this carbon will find its way into the atmosphere, along with the hydrocarbons that are purposefully being extracted from drilling operations.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/06/Forest-Fragmentation-Feature.jpg400900Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2017-06-06 10:09:452021-04-15 15:03:01Forest Fragmentation and O&G Development in PA’s Susquehanna Basin
How fragmented approvals and infrastructure favor petrochemical development
By Leann Leiter and Lisa Graves-Marcucci
Let’s think back to 2009, when oil and gas companies like Range Resources began drilling the northeast shale plays in earnest. Picture the various stages involved in drilling – such as leasing of land, clearing of trees, boring of wells, siting of compressor stations, and construction of pipelines to gather the gas. Envision the geographic scope of the gas infrastructure, with thousands of wells in Pennsylvania alone, and thousands of miles of pipelines stretching as far as Louisiana.
Figure 1. A pipeline right-of-way snakes behind a residential property in Washington County, PA. Photo credit: Leann Leiter
Now, picture the present, where a homeowner looks out over her yard and wonders how a lease she signed with Shell several years prior made it possible for the company to run an ethane pipeline across her property and between her house and her garage.
Think forward in time, to 2022, the year when a world-scale ethane cracker is set to go online in Beaver County, Pennsylvania, to begin churning through natural gas liquids from wells in PA and others, producing a variety of disposable plastic products.
At each of these moments in gas development, which of the many stakeholders – industry leaders, local governments, state regulatory agencies, or landowners and residents – were granted a view of the full picture?
The proposed Shell ethane cracker in Beaver County is an illustration of the fragmented nature of gas development. From the extensive web of drilling infrastructure required to supply this massive facility, to several years of construction, this project is a case-study in piecemeal permitting. Such fragmentation creates a serious barrier to transparency and to the informed decision-making that relies upon it.
In the first two articles in this series on the petrochemical development in Beaver County, we focused on ethane cracker emergency scenarios and how the area might prepare. In this article, we draw the lens back to take in the larger picture of this region-altering project and highlight the effects of limited transparency.
The “Piecemeal” Nature of Gas Development
All across the Pennsylvania, proposed industrial development – even coal operations – have historically provided to the public, elected officials, and regulatory agencies the extent or footprint of their planned operations. Nonetheless, the oil and gas industry has in several instances undertaken a practice of developing its extensive infrastructure piece-by-piece. Operators of these facilities first acquire a GP-5 General Permit, which is only available to certain oil and gas operations with “minor” emissions and which allows them to avoid having the permit undergo public notice or comment. These operators then add emissions sources and increases through a series of minor amendments. While they are required to obtain a “major” source permit once their modifications result in major emissions, they avoid the scrutiny required for a major source by this fragmented process.
Unlike most other industrial permitting, the gas industry has enjoyed a much less transparent process. Instead of presenting their entire planned operation at the time of initial permit application, gas operators having been seeking – and receiving – incremental permits in a piecemeal fashion. This process puts local decision makers and the women, men, and children who live, work, and go to school near gas development at a severe disadvantage in the following ways:
Without full disclosure of the entirety of the planned project, neither regulatory bodies nor the public can conduct a full and factual assessment of land use impacts;
Incremental approvals allow for ever-expanding operations, including issuance of permits without additional public notification and participation;
Piecemeal approvals allow operations to continuously alter a community and its landscape;
The fragmented approval process prevents consideration of cumulative impacts; and
Without full transparency of key components of the proposed operations, emergency planning is hampered or non-existent.
From the Well to the Ethane Cracker
In the fragmented approval process of gas development, the proposed ethane cracker in Beaver County represents a pertinent example. Developers of this massive, multi-year, and many-stage project have only revealed the size and scope in a piecemeal fashion, quietly making inroads on the project (like securing land leases along the route of the pipeline required for the cracker, years in advance of permit approvals for the facility itself). By rolling out each piece over several years, the entirety of the petrochemical project only becomes clear in retrospect.
A World-Scale Petrochemical Hub
While Shell is still pursuing key approval from the PA Department of Environmental Protection, industry leaders treat the ethane cracker as a foregone conclusion, promising that this facility is but one step in turning the area into a “petrochemical hub.”
The cracker facility, alone, will push existing air pollution levels further beyond their already health-threatening state. Abundant vacant parcels around Shell’s cracker site are attractive sites for additional spin-off petrochemical facilities in the coming “new industry cluster.” These facilities would add their own risks to the equation, including yet-unknown chemical outputs emitted into the air and their resulting cumulative impacts. Likewise, disaster risks associated with the ethane cracker remain unclear, because in the piecemeal permitting process, the industry is not required to submit Preparedness, Prevention, and Contingency (PPC) Plans until after receiving approval to build.
Figure 2. A portion of the extensive US natural gas interstate pipeline system stretching from the petrochemical hubs in the bayous of the Gulf Coast Basin to Pittsburgh’s Appalachian Basin. However, petrochemical development in the northeast may reverse or otherwise change that flow. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 “Annual Report of Natural Gas and Supplemental Gas Supply and Disposition,” 2007.
92.3 Miles of Explosive Pipeline
More than just a major local expansion, communities downriver and downwind will be susceptible to the impacts, including major land disturbance, emissions, and the potential for “incidents,” including explosion. The pipeline required to feed the cracker with highly flammable, explosive ethane would tie the tri-state region into the equation, expanding the zone of risk into Ohio and crossing through West Virginia.
Figure 3. The Falcon Pipeline, which would be used to transport ethane to the cracker in Beaver County. At 92.3 miles long, it consists of two “legs,” starting from Scio and Cadiz, Ohio and Houston, PA, respectively, and extending up to the site of Shell’s ethane cracker. Credit: Shell Pipeline Company LP
Renewed Demand at the Wellhead
No one piece of the gas infrastructure stands alone; all work in tandem. According to the Energy Information Administration (EIA), the new US ethane crackers will drive consumption of ethane up by a 26% by the end of 2018. Gas wells in the northeast already supply ethane; new ethane crackers in the region introduce a way to profit from this by-product of harvesting methane without piping it to the Gulf Coast. How this renewed demand for ethane will play out at fracked wells will be the result of complex variables, but it will undoubtedly continue to drive demand at Pennsylvania’s 10,000 existing unconventional oil and gas wells and those of other states, and may promote bringing new ones online.
Figure 4. Excerpt from Executive Summary of IHS Markit Report, “Prospects to Enhance Pennsylvania’s Opportunities in Petrochemical Manufacturing.”
Along with drilling comes a growing network of gathering and transmission lines, which add to the existing 88,000 miles of natural gas pipeline in Pennsylvania alone, fragment wildlife habitat, and put people at risk from leaks and explosions. Facilities along the supply stream that add their own pollution and risks include pump stations along the route and the three cryogenic facilities at the starting points of the Falcon Pipeline (see Fig. 6).
Figure 5. Several yards of the 88,000 miles of gas pipelines cutting through Pennsylvania. Finleyville, PA. Credit: Leann Leiter
The infrastructure investment required for ethane crackers in this region could reach $3.7 billion in processing facilities, pipelines for transmitting natural gas liquids including ethane, and storage facilities. A report commissioned by Team Pennsylvania and the PA Department of Community and Economic Development asserts that “the significant feedstock and transportation infrastructure required” will “exceed what is typically required for a similar facility” in the Gulf Coast petrochemical hub, indicating a scale of petrochemical development that rivals that of the southern states. This begs the question of how the health impacts in Pennsylvania will compare to those in the Gulf Coast’s “Cancer Alley.”
Figure 6. Houston, PA Cryogenic and Fractionation Plant, one of three such facilities supplying feedstock to the proposed Shell ethane cracker. Credit: Garth Lenz, iLCP
Water Impacts, from the Ohio River to the Arctic Ocean
Shell’s facility is only one of the ethane crackers proposed for the region that, once operational, would be permitted to discharge waste into the already-beleaguered Ohio River. This waterway, which traverses six separate states, supplies the drinking water for over 3 million people. Extending the potential water impact even further, the primary product of the Shell facility is plastics, whose inevitable disposal would unnecessarily add to the glut of plastic waste entering our oceans. Plastic is accumulating at the alarming rate of 3,500 pieces a day on one island in the South Pacific and as far away as the waters of the Arctic.
Figure 7. View of the Ohio River, downriver from the site of Shell’s proposed ethane cracker. Existing sources of industrial pollution to the river include the American Electric power plants, coal loading docks, barges, coal ash lagoons, and dry coal ash beds shown in this picture, and at least two fracking operations within the coal plant areas. Credit: Vivian Stockman/ohvec.org; flyover courtesy SouthWings.org.
How does fragmentation favor industry?
The gas and petrochemical industry would likely defend the logistical flexibility the piecemeal process affords them, allowing them to tackle projects, make investments, and involve new players as needed overtime. But in what other ways do the incredibly fragmented approval processes, and the limited requirements on transparency, favor companies like Shell and their region-changing petrochemical projects? And what effect does the absence of full transparency have on local communities like those in Beaver County? We conclude that it:
“Divides and conquers” the region. The piecemeal approach to gas development, and major projects like the Shell ethane cracker, deny any sense of solidarity between the people along the pipeline route resisting these potentially explosive channels cutting through their yards, and residents of Beaver County who fear the cracker’s emissions that will surround their homes.
Makes the project seem a foregone conclusion, putting pressure on others to approve. For example, before Shell formally announced its intention to build the facility in Potter Township, it rerouted a state-owned road to facilitate construction and increased traffic flow. Likewise, though a key permit is still outstanding with the PA DEP, first responders, including local volunteer firefighters, have already begun dedicating their uncompensated time to training with Shell. While this is a positive step from a preparedness standpoint, it is one of many displays of confidence by Shell that the cracker is a done deal.
Puts major decisions in the hands of those with limited resources to carry them out and who do not represent the region to be affected. In the case of the Shell ethane cracker, three township supervisors in Potter Township granted approvals for the project. The impacts, however, extend well beyond Potter or even Beaver county and include major air impacts for Allegheny County and the Pittsburgh area. Effects will also be felt by landowners and residents in numerous counties and two states along the pipeline route, those near cryogenic facilities in Ohio and Pennsylvania, plus those living on the Marcellus and Utica shale plays who will see gas well production continue and potentially increase.
Figures 8a and 8b. Potter Township Supervisors give the go-ahead to draft approval of Shell’s proposed ethane cracker at a January meeting, while confronted with public concern about deficiencies in Shell’s permit applications. Photos courtesy of the Air Quality Collaborative.
The piecemeal, incremental, and fragmented approval processes for the ethane cracker – and other gas-related facilities in the making – create one major problem. They make it nearly impossible for locals, elected officials, and regulatory agencies to see the whole picture as they make decisions. The bit-by-bit approach to gas development amounts to far-reaching development with irreversible impacts to environmental and human health.
We ask readers, as they contemplate the impacts closest to them – be it a fracked well, a hazardous cryogenic facility, the heavily polluted Ohio River, a swath of land taken up for the pipeline’s right-of-way, or Shell’s ethane cracker itself – to insist that they, their elected officials, and regulators have access to the whole picture before approvals are granted. It’s hard to do with a project so enormous and far-reaching, but essential because the picture includes so many of us.
Sincere Appreciation
To The International League of Conservation Photographers, The Ohio Environmental Council, and The Air Quality Collaborative for sharing photographs.
To Sophie Riedel for sharing her visualizations of natural gas interstate pipelines.
To Lisa Hallowell at the Environmental Integrity Project, and Samantha Rubright and Kirk Jalbert at FracTracker, for their review of and and invaluable contributions to this series.
Feature image: Map of US counties and natural gas interstate pipeline system describes the wide-diameter (20-42 inch), high capacity trunklines that carry most of the natural gas that is transported throughout the nation. Visualization created by Sophie Riedel, Carnegie Mellon University, School of Architecture. Data on interstate natural gas supply sourced from Energy Information Administration, Form EIA176 “Annual Report of Natural Gas and Supplemental Gas Supply and Disposition,” 2007.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/05/Pipelines-US-Graphic-Riedel-Feature.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2017-05-31 09:12:492021-04-15 15:03:01Piecing Together an Ethane Cracker
By Leann Leiter and Lisa Graves Marcucci Maps and data analysis by Kirk Jalbert
Highly industrialized operations like petrochemical plants inherently carry risks, including the possibility of large-scale disasters. In an effort to prepare, it is incumbent upon all stakeholders to fully understand the risk potential. Yet, the planned Shell ethane cracker and additional petrochemical operations being proposed for Western Pennsylvania are the first of their kind in our region. This means that residents and elected officials are without a frame of reference as they consider approving these operations. Officials find themselves tasked with reviewing and approving highly complicated permit applications, and the public remains uncertain of what questions to ask and scenarios to consider. Often overlooked in the decision-making process is valuable expertise from local first responders like police, fire and emergency crew members, HAZMAT teams, and those who protect vulnerable populations, like emergency room personnel, nursing home staff, and school officials.
Example of cracker producing ethylene, located at BASF’s Ludwigshafen site. Photo credit: BASF
In the first article in this series , we tried to identify the known hazards associated with ethane crackers. In this article, we look more closely at how that risk could play out in Beaver County, PA and strive to initiate an important dialogue that invites valuable, local expertise.
In keeping with the first article in this series, we use the terms vulnerability and capacity. Vulnerability refers to the conditions and factors that increase the disaster impact that a community might experience, and capacity consists of the strengths that mitigate those impacts. Importantly, vulnerability and capacity frequently intertwine and overlap. We might, for example, consider a fire station to be a site of “capacity,” but if it lies within an Emergency Planning Zone (discussed more below), an explosion at the plant could render it a vulnerability. Likewise, “vulnerable” populations such as the elderly may have special skills and local knowledge, making them a source of capacity.
Emergency Planning: Learning from Louisiana
FracTracker got in touch with the Emergency Operations Center (EOC) in St. Charles Parish, Louisiana, to learn how a community already living with Shell-owned and other petrochemical facilities manages risk and disclosure. The Emergency Manager we spoke with explained that they designate a two- and a five-mile area around each new facility in their jurisdiction, like ethane crackers, during their emergency planning process. They call these areas “ emergency planning zones ” or EPZs, and they maintain records of the vulnerabilities and sites of capacity within each zone. In case of a fire, explosion, or other unplanned event at any facility, having the EPZs designated in advance allows them to mobilize first responders, and notify and evacuate everyone living, working, and attending school within the zone. Whether they activate a two- or a five-mile EPZ depends on the type of incident, and factors like wind speed and direction.
Based on those procedures, the map below shows similar likely zones for the proposed plant in Beaver County, along with sites of vulnerability and capacity.
The map helps us visualize the vulnerability and capacity of this area, relative to the proposed ethane cracker. It includes three main elements: the Shell site and parcels likely to be targeted for buildout of related facilities, two Emergency Planning Zones (EPZs) around the Shell facility, and infrastructure and facilities of the area that represent vulnerability and capacity.
Vacant parcels near the site
It is important to note that the proposed ethane cracker in Beaver County is merely the first of an influx of petrochemical spin-off facilities promised for the area, potentially occupying the various empty parcels indicated on the map above as “vacant properties” and presented in light gray in the screenshot left.
Each new facility would add its own risks and cumulative impacts to the equation. It would be impossible to project these additional risks without knowing what facilities will be built here, so in this article, we stick to what we do know – the risks already articulated by Shell, lessons learned from other communities hosting petrochemical industry in other parts of the country, and past disasters at similar facilities.
Vulnerability and Capacity in Beaver County
Red, blue, and green points on the map above and in the screenshot below stand in for hospitals like Heritage Valley Beaver; fire and emergency medical services like Vanport Volunteer Fire Company; police stations like the Beaver County Sheriff’s office; and daycares and schools like Center Grange Primary School.
Transportation routes, if impacted, could challenge evacuation. Potter Township Fire Chief Vicki Carlton pointed out that evacuations due to an event at this facility could also be complicated by the need to stay upwind, when evacuations would likely move in a downwind direction. This map lacks drinking water intakes and other essential features upon which lives depend, but which nonetheless also sit within this zone of vulnerability.
Points within EPZS
Vulnerability/capacity within 2-mile zone:
1 hospital
5 police stations
10 fire/EMS stations
23 schools/daycare facilities
47,717 residents*
When expanded to 5-mile zone:
2 hospitals
9 police stations
23 fire/EMS stations
40 schools/daycare facilities
120,849 residents*
*Note: For census tracts that are partly within a zone, a ratio is determined based on the percentage of land area in the tract within the zone. This ratio is then used to estimate the fraction of the population likely within the zone.
Stakeholders’ Right to Know
No person or community should be subjected to risk without the opportunity to be fully informed and to give meaningful input. Likewise, no group of people should have to bear a disproportionate share of environmental risks, particularly stakeholders who are already frequently disenfranchised in environmental decision-making. “Environmental justice” (EJ) refers to those simple principles, and DEP designates environmental justice areas based on communities of color and poverty indicators.
Presented as blue fields on the map and shown in the screenshot below, several state-designated EJ areas fall partially or entirely within the 2- and 5-mile EPZs (a portion of two EJ areas home to 2,851 people, and when expanded to five miles, two entire EJ areas and a portion of seven more, home to 18,679 people, respectively).
EJ Areas and Emergency Planning Zones around the Site
The basic ideas behind environmental justice have major bearing in emergency scenarios. For example, those living below the poverty line tend to have less access to information and news sources, meaning they might not learn of dangerous unexpected emissions plumes coming their way. They also may not have access to a personal vehicle, rendering them dependent upon a functioning public transportation system to evacuate in an emergency. Living below poverty level may also mean fewer resources at home for sheltering-in-place during a disaster, and having less financial resources, like personal savings, may lead to more difficult post-disaster recovery.
Local expertise
FracTracker recently consulted with the Emergency Management Director for Beaver County, Eric Brewer, and with Potter Township Fire Chief Vicki Carlton. Both indicated that their staff have already begun training exercises with Shell -including a live drill on site that simulated a fire in a work trailer. But when asked, neither reported that they had been consulted in the permit approval process. Neither had been informed of the chemicals to be held on site, and both referred to emergency planning considerations as something to come in the future, after the plant was built.
Unfortunately, the lack of input from public safety professionals during the permit approval stage isn’t unique to Beaver County. Our emergency management contact in Louisiana pointed to the same disturbing reality: Those who best understand the disaster implications of these dangerous developments and who would be mobilized to respond in the case of a disaster are not given a say in their approval or denial. This valuable local expertise – in Louisiana and in Beaver County – is being overlooked.
All Beaver County first responders who spoke with FracTracker clearly showed their willingness to perform their duties in any way that Shell’s new facility might demand, hopefulness about its safety, and a generally positive relationship with the company so far. Chief Carlton believes that the ethane cracker will be an improvement over the previous facility on the same site, the Horsehead zinc smelter, though a regional air pollution report characterizes this as a trade off of one type of dangerous pollution for another. Director Brewer pointed to the existing emergency plans for the county’s nuclear facility as giving Beaver County an important leg-up on preparedness.
But the conversations also raised concern about what the future relationship between the community and the industry will look like. Will funds be allocated to these first responders for the additional burdens brought on by new, unprecedented facilities, in what amount, and for how long into the future? Chief Carlton pointed out that until Shell’s on-site fire brigade is in place two or three years from now, her all-volunteer department would be the first line of defense in case of a fire or other incident. In the meantime, her fire company has ordered a much-needed equipment upgrade to replace a 30-year old, outdated tanker at a cost of $400,000. They are formally requesting all corporate businesses in the township, including Shell, to share the cost. Hopefully, the fire company will see this cost covered by their corporate neighbors who use their services. But further down the road? Once all is said and done, and Shell has what they need to operate unfettered, Chief Carlton wonders, “where do we stand with them?”
Waiting for disclosure of the risks
Emergency preparedness and planning should be a process characterized by transparency and inclusion of all stakeholders. However, when it comes to the Shell ethane cracker, those who will share a fence line with such operations have not yet been granted access to the full picture. Currently, the DEP allows industrial operations like the proposed ethane cracker to wait until immediately before operations begin to disclose emergency planning information, in the form of Preparedness, Prevention, and Contingency (PPC) plans. In other words, when permits are up for approval or denial prior to construction, permit applicants are not currently required to provide PPC plans, and the public and emergency managers cannot weigh the risks or provide crucial input.
Shell’s Acknowledged Risks According to public informationprovided by Shell
Sampling of Shell’s Disastrous
Petrochemical Precedents
According to Shell, possible risks of the proposed Beaver County petrochemical facility include fire, explosion, leaks, and equipment failures. More than mere potentialities, examples of each are already on the books. The above table presents a sampling. Shell also points out the increased risk of traffic accidents, not explored in this chart. It is worth noting, however, that the proposed facility, and likely spin-off facilities, would greatly increase vehicular and rail traffic.
The ethane cracker in Beaver County plant has not yet been constructed. However, Shell operates similar operations with documented risks and their own histories of emergency events. Going forward, the various governmental agencies tasked with reviewing permit applications should require industrial operations like Shell, to make this information public as part of the review and planning process. Currently they can relegate safety information to a few vague references and get a free pass to mark it as “confidential” in permit applications. Strengthening risk disclosure requirements would be a logical and basic step toward ensuring that all stakeholders – including those with special emergency planning expertise – can have input on whether those risks are acceptable before permits are approved and site prep begins.
Until regulations are tightened, we invite Shell to fulfill its own stated objective of being a “good neighbor” by being forthcoming about what risks will be moving in next door. Shell can and should take the initiative to share information about its existing facilities, as well as lessons learned from past emergencies at those sites. Instead of waiting for the post-construction, or the “implementation” stage, all stakeholders deserve disclosure of Shell’s plans to prevent and respond to emergencies now.
In our next article, we will explore the infrastructure for the proposed Shell facility, which spans multiple states, and sort out the piecemeal approval processes of building an ethane cracker in Pennsylvania.
Sincere Appreciation
Emergency Managers and First Responders in St. Charles Parish, Louisiana and Potter Township and Center Township, PA.
Lisa Hallowell, Senior Attorney at the Environmental Integrity Project, for her review of this article series and contributions to our understanding of relevant regulations.
Kirk Jalbert, in addition to maps and analysis, for contributing key points of consideration for and expertise on environmental justice.
The International League of Conservation Photographers for sharing the feature image used in this article.
The image used on our homepage of the steam cracker at BASF’s Ludwigshafen site was taken by BASF.
By Leann Leiter, Environmental Health Fellow for FracTracker Alliance and the Southwest PA Environmental Health Project and Lisa Graves Marcucci, PA Coordinator, Community Outreach of Environmental Integrity Project
With maps and analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/05/Cracker-2-Feature-iLCP.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2017-05-03 13:56:332021-04-15 15:03:08Understanding in Order to Prepare: Ethane Cracker Risk and Disclosure
The Susquehanna River is a 444-mile long waterway extending from the area around Cooperstown, New York to the Chesapeake Bay. In Pennsylvania, the basin includes more than 37,000 miles of streams that feed into the river, which capture the precipitation of more than 20,000 square miles of land, and is home to over 3.3 million people.
The region has been heavily impacted by oil and natural gas extraction in recent years; more than 5,500 unconventional wells and roughly 13,500 conventional wells have been drilled in the PA segment of the basin since 2000. Unconventional wells, in particular, have brought industrial-scaled activity, pollution, and waste products to a wide area of the basin, with especially heavy development occurring in three counties along Pennsylvania’s northern tier – Bradford, Susquehanna, and Tioga.
Several governmental agencies are involved with monitoring impacts to this massive watershed. This article focuses on the Pennsylvania portion of the basin, and examines how capable agency-run monitoring efforts are in capturing oil and gas (O&G) related pollution events. The Pennsylvania Department of Environmental Protection (DEP), the US Geological Survey (USGS), and the Susquehanna River Basin Commission (SRBC) maintain a combined network of 274 monthly “grab sample” monitoring sites and 58 continuous data loggers in the Pennsylvania portion of the river basin. Meanwhile, between January 1, 2000 and February 7, 2017, the DEP logged 6,522 on the O&G violations compliance report within the same region. More than three out of every four of these violations have been assessed to unconventional wells, even though only one out of every four active wells in the basin is categorized as such.
Map of O&G Monitoring & Violations in PA’s Susquehanna River Basin
Grab samples obtained from official monitoring locations are the preferred method for regulatory purposes in understanding the long-term health of the river system. Researchers can test for any number of analytes from samples that are collected in-stream, but analyzed in certified laboratories. However, samples from these locations are collected periodically – usually once per month – and therefore are very likely to miss the effects of a significant spill or issue that may impact surface water chemistry for a number of hours or days before being diluted and washing downstream.
Continuous data loggers give regulators a near real-time assessment of what is happening in selected points in the basin, usually at 15-minute intervals. While there are numerous events that contribute to fluctuations in these measurements, these data loggers would be the most likely instruments available to register an event impacting the surface water within the basin. However, there are unique issues with data loggers. For instance, available data from these data loggers are much more limited in scope, as temperature, pH, and conductivity are typically the only available analytes. In addition, because the analysis occurs on site, the results carry less weight than laboratory results would. Finally, even though data loggers collect data at rapid intervals, only some are equipped to send data real-time to agency offices. Some data loggers must be manually collected on a periodic basis by program managers.
Perhaps the greatest challenge for monitoring in the Susquehanna River Basin is that it is simply not practical to monitor in all places likely to be impacted by oil and gas operations. Testing within the jurisdiction of the Susquehanna River Basin is actually fairly extensive when compared to other regions, such as the Ohio River Basin. The Ohio River Valley Water Sanitation Commission – the equivalent of the SRBC for the Ohio River Basin – only monitors basic analytes like total dissolved solids at 29 locations, all at or near the main stem of the river. However, none of the agencies monitoring water quality in the Susquehanna River Basin have capacity to test everywhere. On average, there is one testing location for every 111 miles of rivers and streams within the basin.
Case Studies
If agency-based monitoring is so limited, then the important question is: How well do these efforts capture oil and gas-related impacts? Some violations are more likely to impact surface water quality than others. This article takes a closer look at some of the bigger problem areas within the basin, including the Dimock region in Susquehanna County, Leroy Township in Bradford County, and Bell Township in Clearfield County.
Dimock
O&G violations and water monitoring near Dimock, PA. Note that multiple violations can occur at the same location. Click to expand map.
The highest concentration of oil and gas violations in the Susquehanna Basin is located in the townships of Dimock and Springville, in Susquehanna County, PA, with a total of 591 incidents reported on the compliance report. This makes the region the highest concentration of O&G violations in the entire state. Many of these violations are related to the systemic failure of well integrity, resulting in the contamination of numerous groundwater supplies. In terms of how these might affect surface water, 443 of the violations are in areas that drain into the Thomas Creek-Meshoppen Creek subwatershed by the southern edge of Springville Township, while most of the rest of the violations drain into the parallel West Branch of Meshoppen Creek.
The USGS operates a monthly monitoring location in the middle of the cluster of violations, at the confluence of Burdick and Meshoppen creeks, just north of the Dimock’s southern border. While this location might seem ideal at first, only 180 of the 443 violations in the subwatershed are upstream of the grab sample site. There is another water monitoring location that captures all of these violations in the Meshoppen subwatershed, but it is more than 15 miles downstream. (link to EJ article about Dimock)
Leroy Township
O&G Violations and monitoring near Leroy Township, PA. Click to expand map.
Compared to the huge amount of oil and gas violations throughout the Dimock area, Leroy Township in Bradford County looks relatively quiet. It also appears to be well covered by monitoring locations, including a data logger site near the western edge of the township, a centrally located monthly monitoring location, as well as another monthly grab sample site upstream on Towanda Creek, just beyond the eastern boundary in Franklin Township.
And yet, this area was hit hard in the early part of the decade by two significant spills. On April 19, 2011, Chesapeake Appalachia lost control of the Atlas 2H well, with thousands of gallons of flowback fluid spilling onto the countryside and into the nearby Towanda Creek.
A little over a year later on July 4, 2012, a second major spill in the township saw 4,700 gallons of hydrochloric acid hit the ground. According to the DEP compliance report, this did not make it into the waterways, despite the gas well being located only about 550 feet from Towanda Creek, and less than 300 feet from another unnamed tributary.
Both incidents were within a reasonable distance of downstream monitoring locations. However, as these are grab sample sites that collect data once per month, they can only offer a limited insight into how Towanda Creek and its tributaries were impacted by these notable O&G related spills.
Bell Township
O&G violations and monitoring near Bell Township, PA. Click to expand map.
Bell Township is a small community in Clearfield County along the banks of the West Branch Susquehanna River. The northwestern portion of the township ultimately drains to the Ohio River, but all of the violations in Bell Township are within the Susquehanna River Basin.
Two significant incidents occurred in the township in 2016. On February 18, 2016, Alliance Petroleum Corp lost control of the McGee 11 OG Well, located less than 250 feet from Deer Run. According to the oil and gas compliance report, control of the well was regained five days later, after releasing unspecified quantities of gas, produced fluid, and crude oil. On December 5th of the same year, Exco Resources was cited for allowing 30 barrels (1,260 gallons) of produced fluid to spill at the Clyde Muth M-631 Wellpad in Bell Township.
A United States Geological Survey monthly monitoring location along the West Branch Susquehanna in nearby Greenwood Township is upstream, and could capture the effects of spills throughout much of Bell Township. However, the incident at the Clyde Muth well pad occurred in the Curry Run subwatershed, which meets up with the West Branch Susquehanna downstream of the monitoring location, so any pollution events in that area will not be reflected by monitoring efforts.
Conclusions
In the case of Dimock and Springville townships, we see how official water monitoring efforts capture only a fraction of the notorious cluster of wells that have resulted in hundreds of violations over the past decade. There could scarcely be a better candidate for systematic observation, and yet only a single grab sample site covers the immediate vicinity. Leroy Township does not have the same quantity of impacts as Dimock, but it did see one the worst blowouts in the recent history of O&G operations in Pennsylvania. The area is relatively well covered by grab samples sites, but due to the monthly sampling schedule, these locations would still be unlikely to capture significant changes in water quality. In Bell Township, much of the area is upstream of a monthly grab sample site, but the nearest downstream monitoring location to a major spill of produced fluid that occurred here is more than 17 miles away from the incident as the crow flies.
It should be noted that there are a number of industries and activities that contribute to water pollution in Pennsylvania, and as a result, the monitoring efforts are not specifically designed to capture oil and gas impacts. However, the compliance record shows heavy impacts from oil and gas wells in the basin, particularly from modern unconventional wells.
While the network of government-operated manual monitoring locations and data logger sites are fairly extensive in Susquehanna River Basin, these efforts are not sufficient to capture the full extent of oil and gas impacts in the region. Finding evidence of a small to medium sized spill at a site with monthly testing is unlikely, as contaminated water doesn’t stay in place in a dynamic river system. Data loggers also have a limited capacity, but are a useful tool for identifying substantial changes in water chemistry, and could therefore be employed to identify the presence of substantial spills. As such, it might be beneficial for additional data loggers to be distributed throughout the basin, particularly in areas that are heavily affected by the oil and gas industry. Furthermore, given resource gaps and staff cuts within agencies tasked with protecting the river basin, agencies should strongly consider utilizing networks of volunteers to augment their limited monitoring networks.
By Matt Kelso, Manager of Data and Technology, FracTracker Alliance
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/05/Susquehanna-2-Feature-WP.jpg400900Matt Kelso, BAhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngMatt Kelso, BA2017-05-02 13:17:582021-04-15 15:03:08Violations and Monitoring in Pennsylvania’s Susquehanna River Basin
By Alison Grass, Senior Researcher at Food & Water Watch
Over the past decade, the natural gas industry has experienced a renaissance that has been a boon to energy company profits. But it has altered the quality of life for the rural communities where most new gas wells have been drilled. Now, fracking is fueling a gas-fired power plant boom in Pennsylvania, with 47 new facilities. Most have already been approved, with a handful in commercial operation (see map below).
New research by Pennsylvanians Against Fracking shows, in vivid detail, the scale of this buildout, and the impacts it will have on Pennsylvania communities.
Current & Potential PA Gas-Fired Power Plants & their Emissions
Approximately half of the new gas power plants are located in northeastern region of Pennsylvania, a part of the state already overburdened by the lingering environmental maladies of coal mining and the more recent dangers associated with fracking. These rural communities may see increased drilling, fracking and pipeline construction to support the power plants — and the siting could be strategic. In a StateImpact Pennsylvania article about the first Marcellus shale gas power plant, for example, a company representative admitted that the location was chosen specifically due to its convenient access to shale gas. “This plant was sited precisely where it is because of its access to the abundant, high-quality natural gas that’s found a mile to two miles beneath our feet.”
Drilling Trends
The first modern Marcellus well was drilled in Pennsylvania by Range Resources in 2003, and commercial production began in 2005. Although fracking expanded rapidly in several areas across the country, Pennsylvania has been ground zero of the fracking boom, with just over 10,000 shale gas wells drilled between 2005 and 2016. Since then, however, there has been a rapid downturn in new wells drilled. After the early and dramatic increase in drilling – from 9 shale wells in 2005 to 1,957 shale wells in 2011 – the number dropped to 504 in 2016.
According to Natural Gas Intelligence, natural gas from the Appalachian Basin “…hit a roadblock in 2016, as pipeline projects struggled to move forward and a storage glut slowed the region’s previously rapid production growth.” Thus, it appears that in order to maintain fracking’s profitability, the gas industry is relying on new gas-fired power plants to alleviate the storage glut, while potentially increasing demand for shale gas (which could propagate more drilling and fracking).
Gas-Fired Power Plant Siting
The siting of these power plants also enables companies to use Pennsylvanian fracked gas to generate power for larger regional markets. This is because northeastern Pennsylvania is close to dense populations, including New York City. In Luzerne County, for instance, the new Caithness Moxie Freedom Generating Station gas-fired power plant will supply electricity to not just Pennsylvania residents, but also to New Jersey and New York State. And in the more central region of the state in Snyder County, the Panda Hummel Station will send “much of its power to the New York City market.”
Siting gas-fired power plants in the northeast may also increase drilling and fracking in the region, where gas is predominantly “dry” and less profitable than the “wet” gas found in southwest PA. This trend is largely due to a resurgence in North American petrochemical markets and increased ethane exports that rely on wet gas. (Dry natural gas contains primarily methane and smaller amounts of other hydrocarbons, while wet natural gas has higher concentrations of natural gas liquids. Natural gas liquids — predominantly ethane but also propane, butane, isobutane and pentanes — are the raw materials for manufacturing petrochemicals.)
Well Integrity and Other Risks
However, increased drilling and fracking mean more pollution for the Marcellus shale region of Pennsylvania, where shale gas wells have proven to be more prone to well construction “impairments” and well integrity problems, compared to conventional wells. This risk is especially true in the northeastern part of the state, where over nine percent of shale gas wells have indications of compromised well integrity.
Overall, fracking causes many public health and environmental problems. Methane, fracking fluids, and wastewater can pollute water supplies and imperil the livelihoods of farmers, who rely on clean water. Increased truck traffic and drilling emissions reduce air quality, and methane leaks contribute to global warming. Meanwhile, the proliferation of natural gas derricks and associated infrastructure destroys pristine landscapes (and related tourism and recreation industries).
The last thing that Pennsylvanians need is another way for the oil and gas industry to capitalize on shale at the expense of residents’ health and well-being.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/03/Power-Plants-PA-Feature.jpg400900Guest Authorhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngGuest Author2017-04-21 13:34:192021-04-15 15:03:09Wanted: More Places to Burn Natural Gas
In March 2017, FracTracker Alliance conducted a review of the available Pennsylvania oil and gas fine data released publicly by the PA Department of Environmental Protection (DEP) to identify trends in industry-related fines over time and by particular operators. In total, the DEP has assessed nearly $36 million in fines to oil and gas extraction and pipeline operators since January 1, 2000. Such fines are associated with over 42,000 violations issued1 by DEP in that time frame, covering 204,000 known oil and gas locations,2 as well as 91,000 miles of pipelines3 within the Commonwealth.
Understanding the Data Structure
The amount of money that the Pennsylvania Department of Environmental Protection (DEP) fines oil and gas (O&G) operations is included in the DEP’s compliance report published on their website. Even though fines data are made available, they are not necessarily straight-forward, and caution must be taken not to over-estimate the total number of assessed fines.
Records of fines are associated with enforcement identification codes on the compliance report. A single fine is often applied to numerous violations, and the full amount of the fine is listed on every record in this subset. Therefore, the total dollar amount of fines assessed to O&G companies appears overstated. For example, if a $400,000 fine were assessed to settle a group of 10 violations, that figure will appear on the report 10 times, for an apparent aggregate of $4,000,000 in fines. To get an accurate representation of fines assessed, we need to isolate fines associated with particular enforcement ID numbers, which are used administratively to resolve the fines.
This process is further complicated by the fact that, on occasion, such enforcement ID numbers are associated with more than one operator. This issue could result from a change in the well’s operator (or a change of the operator’s name), a group of wells in close proximity that are run by different operators, or it might point to an energy extraction company and a midstream company sharing responsibility for an incident. Sometimes, the second operator listed under an enforcement ID is in fact “not assigned.” The result is that we cannot first summarize by operator and then aggregate those subtotals without overstating the total amount of the assessed fines. In all, 62 of the enforcement ID numbers apply to more than one operator, but this figure amounts to less than one percent of the nearly 15,000 distinct enforcement ID numbers issued by DEP.
Conventional & Unconventional Violations & Fines
Oil and gas wells in Pennsylvania are categorized as either conventional or unconventional, with the latter category intended to represent the modern, industrial-scaled operations that are commonly referred to as “fracking wells.” Contrastingly, conventional wells are supposed to be the more traditional O&G wells that have been present in Pennsylvania since 1859. The actual definition of these wells leaves some blurring of this distinction, however, as almost all O&G wells now drilled in Pennsylvania are stimulated with hydraulic fracturing to some degree, and some of the conventional wells are even drilled horizontally – just not into formations that are technically defined as unconventional. For the most part, however, unconventional remains a useful distinction indicating the significant scale of operations.
Table 1. Summary of oil and gas wells, violations, and fines in Pennsylvania
Category
Conventional
Unconventional
(blank)
Total
Wells
193,655
10,291
0
203,946
Violations
27,223
6,126
9,026
42,375
Fines
$7,000,203
$13,689,032
$21,563,722
$35,949,495*
Fines per Violation
257
2,235
2,389
848
Fines per Well
36
1330
–
176.27
Violations per Well
0.14
0.60
–
0.21
Wells per Violation
7.11
1.68
–
4.81
* The total fine amount issued is not a summary of the three preceding categories, as some of the fines appear in multiple categories
Ninety-five (95)% of the state’s 204,000 O&G wells are classified as conventional, so it should not be surprising to see that this category of wells accounts for a majority of violations issued by the department. However, fines associated with these violations are less frequent, and often less harsh; the $7 million in fines for this category accounts for only 19% of the total assessed penalties. In contrast, the total penalties that have been assessed to unconventional wells in the state are nearly twice that of conventional wells, despite accounting for just 5% of the state’s well inventory
On the 54,412 records on the compliance report, 10,518 (19%) do not indicate whether or not it is an unconventional well. The list of operators includes some well-known conventional and unconventional drilling operators, and hundreds of names of individuals or organizations where O&G drilling is not their primary mode of business (such as municipal authorities and funeral homes). This category also contains violations for midstream operations, such as pipelines and compressor stations. Altogether, 3,795 operators have entries that were not categorized as either conventional or unconventional on the compliance report, and 124 of these operators were issued fines. One additional complication is that some of the violations and fines that fall into this category are cross-referenced in the conventional and unconventional categories, as well.
The resulting impact of these factors is that the blank category obscures the trends for violations and fines in the other two categories. While tempting to reclassify well data in this category as either conventional or unconventional, this would be a tall task due to the sheer number of records involved, and would likely result in a significant amount of errors. Therefore, the FracTracker Alliance has decided to present the data as is, along with an understanding of the complexities involved.
Most Heavily Fined Operators
Despite the numerous caveats listed above, we can get a clear look at the aggregated fines issued to the various O&G operators in the state by constructing our queries carefully. Table 2 shows the top 12 recipients of O&G-related fines assessed by DEP since 2000. Ten of these companies are on the extraction side of the business, and the total number of well permits issued4 to these companies since 2000 are included on the table. By looking at the permits instead of the drilled wells, we discover the operator that was originally associated with the drilling location, whereas the report of drilled wells associates the current operator associated with the site, or most recent operator in the event that the location is plugged and abandoned.
Stonehenge Appalachia and Williams Field Services operate in the midstream sector. Combining the various business name iterations and subsidiaries would be an enormous task, which we did not undertake here, with the exception of those near the top of the list. This includes Vantage Energy Appalachia, which was combined with records from Vantage Energy Appalachia II, and the compliance history of Rice Energy is the sum of three subsidiaries, the drilling company Rice Drilling B, and two pipeline companies, Rice Midstream Holdings and Rice Poseidon Midstream.
Table 2. Top 12 operators that have been assessed oil and gas-related fines by DEP since 2000
Operator
Total Fines
Conventional Permits
Unconventional Permits
Violations
Fines / Violation
Fines / Permit
Range Resources Appalachia LLC
$5,717,994
2,104
2,206
819
$6,982
$1,327
Chesapeake Appalachia LLC
$3,120,123
18
3,072
754
$4,138
$1,010
Rice Energy*
$2,336,552
442
165
$14,161
$5,286
Alpha Shale Res LP
$1,681,725
3
62
31
$54,249
$25,873
Stonehenge Appalachia LLC
$1,500,000
–
–
294
$5,102
–
Cabot Oil & Gas Corp
$1,407,275
19
902
726
$1,938
$1,528
CNX Gas Co LLC
$1,274,330
1,613
677
387
$3,293
$556
WPX Energy Appalachia LLC
$1,232,500
347
159
$7,752
$3,552
Chevron Appalachia LLC
$1,077,553
2
604
113
$9,536
$1,778
Vantage Energy Appalachia LLC**
$1,059,766
3
300
35
$30,279
$3,498
Williams Field Services Co, LLC
$872,404
–
–
158
$5,522
–
XTO Energy Inc
$739,712
1,962
461
383
$1,931
305
* Fines for Rice Energy here represent the sum of three subsidiaries, the drilling company Rice Drilling B, and two pipeline companies, Rice Midstream Holdings and Rice Poseidon Midstream.
** Fines for Vantage Energy Appalachia were combined with records from Vantage Energy Appalachia II.
Predictably, many of the entries on this list are among the most active drillers in the state, including Range Resources and Chesapeake Appalachia. However, Alpha Shale Resources has the dubious distinction of leading the pack with the highest amount of fines per violation, as well as the highest amount of fines per permit. Fitting in with the theme, the story here is complicated by the fact that Alpha had a joint venture with Rice, before selling them their stake in a group of wells and midstream operations that were fined $3.5 million by DEP.5 On this compliance report, the fines from this incident are split between the two companies.
Fines Issued Over Time
It is worth taking a look at how O&G related fines have varied over time, as well (Figure 1, shown in millions of dollars). Numerous factors could contribute to changes in trends, such as the number of available DEP inspectors,6 the amount of attention being paid to the industry in the media, differing compliance strategies employed by various political administrations, or changes in practices in the field, which could in turn be impacted by significant fines issued in the past.
Figure 1. O&G Fines Issued by DEP, 2000 through 2016
The notable spike in fines issued from 2010 to 2012 corresponds with the peak of unconventional drilling in the state – 4,908 of these industrial scaled wells were drilled during those three years, amounting to 48% of all unconventional wells in PA. In contrast, only 504 unconventional wells were drilled in 2016, or around a quarter of the total for 2011. In this context, the reduction in fines since the early part of the decade seems reasonable.
The association with the number of unconventional wells falls apart a bit in the years 2013 to 2014, however. These two years saw an average of 1,293 unconventional wells drilled, but the fines issued amounted to only 35% of the 2011 total.
Considerable strides have been made in the public accessibility of oil and gas data available from the PA DEP since FracTracker started requesting and reviewing this information in 2009. Still, there are many gaps in the datasets, such as geolocation details for 10 of the 20 largest fines issued by the department. FracTracker hopes external analyses like this one will help to close such gaps and identify operators who, too, need to improve their compliance records.
The Pennsylvania Department of Environmental Protection (DEP) will be hosting a nine-stop “listening tour” to hear residents’ perspectives on environmental justice (EJ). These sessions begin in the western part of the state on April 12th and 13th. The complete list of dates and locations of these meetings can be found here. The DEP will also be accepting written comments, which can be either mailed or emailed to DEP-OEJ@pa.gov.
The EJ listening tour follows on the heels of events in May 2016, when environmental advocacy groups questioned the well pad siting practices of oil and gas drilling company Range Resources, causing the DEP to announce it would revisit its EJ policies. Such changes would include reassessing how EJ zones are designated and what kinds of development triggers additional scrutiny by the DEP’s Office of Environmental Justice. We wrote about this story, and detailed how present EJ rules fail to account for oil and gas development in June 2016.
The following guide is meant to provide helpful information to residents in preparing for the listening tour. We first offer a summary of PA’s present EJ policies, followed by a commentary on what gaps we believe exist in those policies, and conclude with some reflections on EJ policies in other U.S. states and what we might learn from them in reassessing our own state’s EJ laws.
Listening Sessions Format
Each environmental justice listening tour will include opening remarks from Acting Secretary McDonnell, followed by a brief presentation from the Office of Environmental Justice, and then will open to receive testimony from the public. Verbal testimony is limited to 3 minutes for each witness. Organizations are asked to designate one witness to present testimony on their behalf. Verbal comments will be recorded by a court stenographer, and transcripts will be made available to the public at a later date.
The DEP Office of Environmental Justice has offered a set of eight questions to guide comments in the listening tour sessions. They are as follows:
What environmental justice concerns are most pressing in your community?
Do you feel that the current definition of an environmental justice community (20% poverty and/or 30% minority) properly represents the needs of your community and the Commonwealth at large?
Do you feel the DEP is engaged with marginalized communities to ensure that they have a voice in the decision making process? How can the DEP be more engaged with these communities?
What tools have you used to find out information on DEP permitting/enforcement actions?
What ways can the DEP be more effective at sharing information with the public?
How can the DEP be more effective at receiving public input?
What resource(s) is your community lacking that the DEP can provide that would assist in efforts to ensure environmental equity?
What additional steps can be taken by the Department to effectively reach out to these vulnerable communities to ensure that their concerns are taken into consideration?
Summary of Existing EJ Policies
According to the U.S. Environmental Protection Agency, environmental justice is “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” This same definition is used by the DEP.
In 2004, the DEP codified this EJ definition in the Environmental Justice Public Participation Policy. EJ designations are defined by the DEP as any census tract where 20% or more of the population lives in poverty and/or 30% or more of the population identifies as a minority. Designations are based on the U.S. Census Bureau and by the federal poverty guidelines.
Below is a map of current EJ designated census tracts in PA that also shows the counties where listening tour sessions will be held. When zoomed in to regional scale, EJ areas can be clicked to see their current poverty and minority percentages. The locations of oil and gas wells and permits are also visible at the regional scale.
Map of current EJ areas (based on 2015 census data) shown in teal, with listening tour counties outlined in red
Of note in the 2004 policy are the kinds of permits that trigger a potential EJ review – specifically: industrial wastewater facilities, air permits for new major source of hazardous air pollution, waste permits for landfills and incinerators, coal mining permits and coal refuse facilities, and/or concentrated animal feeding operations. The policy also allows for review of “opt-in permits” the DEP believes warrant special consideration, but we have found no evidence to suggest that this option has been historically used.
When a project triggers EJ review, the DEP “strongly encourages” the applicant meets with community stakeholders prior to submitting their permit, with the idea that additional public outreach makes project details more apparent. The applicant is also encouraged to produce “plain language” information sheets, online and in print form, regarding the proposed activity.
Issues with Existing PA EJ Policies
A complete list of what may occur when a project triggers EJ review can be found here. The following table is a breakdown of where we see deficiencies in PA EJ policies that need to be addressed:
Existing Policy
Issue
Possible Solutions
EJ Definition EJ areas defined by 20% poverty/30% minority indicators.EJ ensures meaningful involvement of all people regardless of race, color, national origin, or income.
Many communities are just outside poverty/minority thresholds, or are spread across multiple census tracts experiencing concentrated industrial activities.
Disproportionate exist due to other factors besides poverty and race.
DEP should go beyond the census tracts, as well as account for other factors such as the “working poor”, homeownership rates, assisted school lunches rate, disability and elderly populations, and language barriers.
Reviews should factor in “cumulative impacts” of more developing relative to existing industrial burdens.
Regardless of “age and gender” should be added to EJ protection language.
Trigger Permits Limited kinds of “trigger” permit types are listed in the Public Participation Policy as eligible for EJ review.
Permits outside of these categories are also degrading the communities and being targeted to environmental justice communities. Oil and gas extractions, pipelines, and other infrastructure are not currently considered trigger permits but are impacting many environmental justice areas.
DEP should oil and gas permits to the trigger list. All permits, even of seemingly lesser severity, should trigger review to see if they contribute to cumulative impacts to already burdened community.
Permit Notifications DEP program staff must notify the Office of EJ when a permit “trigger” EJ review and report the details of the proposed activity.
Currently not all DEP program staff are alerting the EJ office of trigger permits, and many are not education on EJ policies.
More training and funding needs to be allocated to make sure that trigger permits are not overlooked or mishandled.
Public Education
Requiring the distribution of “plain language” information sheets regarding the proposed activity and permit conditions. Public notices are to be placed in widely read publications in print and online.
Does not always happen or the information produced is inadequately written or poorly distributed. Public notices are put in the legal sections of paper, often initial meetings are not even publicly noticed if the company is the only one organizing the meeting.
Enforce this requirement and include real infographics as much as possible. Consult with local community groups to determine what communication tools work best.
Publish additional notice outside of newspaper in widely read publications, flyers in local businesses, community centers, and church bulletins. Require applicants to do direct mailing.
Updated the “eFacts notification system to include more information and send email notices to interested parties when updates in non-technical language.
Applicant Public Meetings
DEP “strongly suggests” applicants meet with all stakeholders, before applying for permit, as well as throughout the permitting process.
Not all stakeholders are being brought into conversations and often DEP allows the applicant to decide who these people should be. Applicants are often not transparent about their plans. Meetings do not occur at all stages of the process.
It should not be up to the applicant to control the process and do outreach. DEP should ensure that all interested parties are engaged in the permitting process.
Meeting should be held during the entire permitting process. This should be required, not “strongly suggested.” A meeting should occur after a permit is administratively complete and again after technical review is done but before a decision is made. Many changes happened during technical review and this gives communities the opportunity to weigh in on the final project and understand its timeline.
DEP should always participate in these meetings and make themselves available to answer questions from the community.
DEP Public Meetings
DEP holds an informal public conference within 30 days of receiving the application to inform residents of EJ area designation and the nature of project.
These meetings frequently are not able to answer people questions and residents are told to wait for additional information. The format of these meetings do not allow for dialogue, which prevents the community from learning from each other.
The DEP needs to hold the informal public conferences in discussion formats so residents can ask questions together and receive answers in person, not just take notes and tell residents they will receive a written response. DEP staff responsible for reviewing the proposal must be present at the meetings to answer questions.
Public Comments
DEP accepts comments from EJ communities.
These comments are often not taken into consideration, or given very little weight during the permitting process. Instead, the comments are merely noted for the record.
Create a formal process for integrating comments from community experts who are often best able to provide information about how a project will impact their community.
DEP Availability
DEP will maintain presence and be availability to residents throughout permitting process.
DEP staff are available during public meetings but are otherwise unavailable until there is a permit decision.
Inadequate continuing public oversight of how EJ policies are administered across the state.
Actively provide updates on the permitting process and changes to the application. The burden should not be on an EJ community to stay up date on the permit, but should be the DEP and applicant’s responsibility.
DEP staff responsible for reviewing the proposal must be available to the community to answer questions. DEP should also prioritize filling its regional Environmental Advocate staff positions currently vacant in many of its districts.
Convert the DEP Citizen Environmental Justice Advisory Board (EJAB) to a full committee, with the power to oversee EJ permits under review and influence state EJ policies. Hold quarterly EJAB meetings in different DEP regions on a rotating basis.
Reflections on other states’ EJ policies
States that use poverty and race indicators differently:
Connecticut: Uses income below 200% of the federal poverty level (“working poor”).
Illinois: indicates low-income and/or minority population as being “greater than twice the statewide average.”
Massachusetts: Defines by census “block group” rather than census tract, which can identify pocket EJ areas that might be lost in larger census tracts.
Texas: For income indicator, uses census block group and income below 200% of the federal poverty level.
States that go beyond poverty and race indicators:
California: Considers existing disproportionate environmental burden. Also, demographics include “low levels of homeownership, high rent burden…or low levels of educational attainment.”
Connecticut: includes a “distressed community” indicator, defined as whether it is eligible for HUD grants, or experienced layoffs/tax loss due to a major plant closing.
Georgia: includes language for elderly and disabled populations “The Americans with Disabilities Act (ADA) encourages the involvement of people with disabilities in the development and improvement of transportation and paratransit plans and services.”
Massachusetts: Uses linguistic isolation, defined as “25% or more of households having no one over the age of 14 who speaks English only, or very well.”
New Jersey: Communities can file a petition to be recognized as a vulnerable.
Example of better public participation affordances:
New Jersey: When a community is designated EJ, a task force is formed to develop a unique “Action Plan” after consultation with residents, local, and county government, that will address environmental, social and economic factors affecting their health or environment. This task force monitors Action Plan implementation, and advises development projects to reduce impacts.
Conclusions
Environmental justice rules came into existence in order to deal with the burdens of large polluting facilities like landfills, incinerators, and coal mines. Race and poverty measures are, without question, two very important indicators that have provided for the fair treatment of people of all races, income, and cultures in these instances. However, if we are to properly assess how residents are disproportionately impacted across a range of environmental burdens in the state, other indicators of marginalization should be included. The Center for Coalfield Justice suggests a few in a report titled Community Indicators of Environmental Justice: A Baseline Report Focusing on Greene and Washington Counties, Pennsylvania.
Fair treatment in EJ communities should also mean offering mechanisms for meaningful input that allow residents to shape the ultimate direction of proposed projects, as well. Finally, current EJ policies are very limited in only addressing future projects, whereas issues such as how disadvantaged communities, struggling with legacy problems such water, air, and soil pollution, are left to other agencies to deal with.
We encourage residents of Pennsylvania to attend an environmental justice listening tour session to share their perspectives, and how the DEP can better fulfill its mandates to protect vulnerable communities.
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/04/EJ_tour_header.jpg400900FracTracker Alliancehttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngFracTracker Alliance2017-04-10 11:06:352021-04-15 15:03:12PA DEP Environmental Justice Listening Tour
https://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2017/04/Dead-of-Spring-Feature.jpg400900Guest Authorhttps://www.fractracker.org/a5ej20sjfwe/wp-content/uploads/2021/04/2021-FracTracker-logo-horizontal.pngGuest Author2017-04-06 11:30:422021-04-15 15:03:12Interview with Sherry Knowlton, Author of Dead of Spring
