Tag Archive for: Pennsylvania

Re-imagine Beaver County meeting - Photo by Sophie Riedel
FracTracker Alliance

Mapping a new vision in PA: Alternatives to petrochemical development

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At a Re-Imagine Beaver County gathering in Pennsylvania earlier this month, static maps became dynamic in the hands of those who live in and around the region depicted. Residents of this area in the greater Pittsburgh region gathered to depict a new vision for Beaver County, PA. This county is currently faced with the proposal of a massive Shell-owned petrochemical facility – also called a “cracker” – and further build-out that could render the area a northern version of Louisiana’s “Chemical Corridor.” Participants at this event, from Beaver County and beyond, were encouraged to collectively envision a future based on sustainable development. The picture they created was one that welcomes change – but requires it to be sustainable and for the benefit of the community that makes it happen.

Re-Imagine Beaver County Group Mapping - by Sophie Riedel

Figure 1: Participants study a map of Beaver County. Photo credit: Sophie Riedel.

Re-Imagine Beaver County Participants

Panelists from municipal government, organic agriculture, and leaders and entrepreneurs of sustainable initiatives started off the event, sponsored by the League of Women Voters of Pennsylvania and endorsed by the Beaver County Marcellus Awareness Committee. After an hour, the room of 60 or so participants dove into the lively de- and re-construction of large format maps of the area. They were invited to markup the maps, created by Carnegie Mellon University graduate student of the School of Architecture, Sophie Riedel. Each table worked from a different base map of the same area – centering on the confluence of the Ohio and Beaver rivers, including the already heavily-industrialized riverside and the site of Shell’s proposed petrochemical facility.

Massive shell processing plant under construction in Beaver County PA and across the Ohio River from the town of Beaver. This massive processing plant, near residential areas, schools and hospitals, will be a serious threat to the health of the those living in the region.

Figure 2: The site of the proposed petrochemical facility in Beaver County (on left) and the Ohio River that participants hope to see reinvented as a recreational waterway buttressed by public parks. Photo credit: Garth Lenz, iLCP.

Much more than a thought exercise, the gathering represented a timely response to a growing grassroots effort around the proposed petrochemical inundation. Changes are already underway at the site, and those who live in this region have the right to give input. This right is especially salient when considering the risks associated with the petrochemical industry – including detrimental health impacts on babies before they are even born, asthma exacerbation, and increased cancer rates.

Charting a new vision

The re-invented Beaver County would be one of increased connectivity and mobility, well-equipped to provide for local needs with local means.

Many ideas included on the maps reflected a longing for transportation options independent of personal vehicles – including better, safer, more connected bike trails and walking paths, use of existing rail lines for local travel, and even the inventive suggestion of a water taxi. These inherently lower-impact means of transport coincide with preferences of millennials, according to several of the panelists, who want more walkable, bikeable communities. Ushering in such sustainable suggestions would welcome more young families to an area with an aging population. More than just about moving people, transportation ideas also included ways to get locally grown foods to those who need it, such as the elderly.

sophie-riedel-visioning-map-close-up

Figure 3: Participants modify maps to reflect a new vision. Photo credit: Sophie Riedel.

The value of beauty was a subtheme in many of the ideas to connect and mobilize the population and goods, ideas which often held a dual aim of protecting open space, creating new parks, and offering recreation possibilities. Participants ambitiously reimagined their river, the Ohio, from its current status as a closed-off corridor for industrial usage and waste, to a recreational resource for kayaking and fishing walleye.

Participants marked up the maps to show the resources that help sustain this community, and voiced a strong desire for development that would enable additional self-reliance. These forward-thinking changes included increased agriculture and use of permaculture techniques, and community gardens for growing food near the people who currently lack access. Ideas for powering the region abounded, like harnessing wind power and putting solar panels on every new building.

Participants were firm on local sourcing for another key resource: the labor required for these efforts, they insisted, must come from the local populace. Educational programs designed to channel learners into workers for sustainability might include training to rebuild homes to “greener” standards, and programs aimed at bringing a new generation of farmers to the fields. Perhaps a nod to the world-wide plastic glut that a petrochemical facility would add to, suggestions even included local ways of dealing with waste, like starting a composting program and establishing more recycling centers.

Whose vision?

Who is a part of this vision, both in creating it and living it out? Inevitably, the selection of panelists and the interests of the audience members themselves influenced the vision this group crafted. The question of inclusion and representation found articulation among many participants, and the hosts of the event welcomed suggestions on reaching a broader audience moving forward. Looking around the room, one man asked, “Where are all the young people, and families with kids?” Indeed, only several members of this demographic were present. Though indicative of the racial makeup of Beaver County, the audience appeared to be primarily white, meaning that the racially diverse communities in the region where not represented. Others pointed out that going forward, the audience should also include those residents struggling with un- and underemployment, who have a major stake in whatever vision of Beaver County comes to fruition. Another said he would like to see more elected officials and leaders present. Notably, Potter Township Board of Supervisors Chairperson, Rebecca Matsco, who is a strong advocate for the proposed petrochemical project in her township, was present for the first half of the event.

Local means for meeting local needs

People who welcome petrochemical development in Beaver County might believe that those who voice concerns about the proposed Shell plant aren’t forward-thinking, or simply oppose change. Quite in contrast, participants at Re-Imagine Beaver County went to work reinventing their community with optimism and enthusiasm. They didn’t seem to be resisting change, but instead, wanting to participate in the process of change and to ultimately see benefits to their community. For example, discussion of solar power generated substantial excitement. According to panel speaker Hal Saville, however, the biggest challenge is making it affordable for everyone, which suggests that the estimated $1.6 billion in tax breaks going to Shell for the petrochemical plant could be better allocated.

A key narrative from supporters of the ethane cracker centers on the pressing need for jobs in this area, though some locals have expressed concern about how many of Shell’s promised jobs would go to residents. Whoever gets hired, these jobs come with serious dangers to workers. Participants at this event proposed alternative initiatives – both ambitious and small – for creating jobs within the community, like providing “sprout funds” to encourage new business start-ups, and launching a coordinated effort to rehab aging housing stock. These ideas suggest that the people of this region feel their energy and ingenuity would be best spent making Beaver County a better place to live and work, in contrast to producing disposable petrochemical products for export around the world. The fact that so many participants emphasized local means for meeting their needs in no way downplays the need for good jobs. Rather, it points to the fact that people want jobs that are good for them and for the future of their community.

Moving the vision forward

Where do we go from here? Can the momentum of this event draw in greater representation from the region to have a voice in this process? Will these visions become animated and guide the creation of a new reality? Broader and deeper planning is in order; participants and panelists alike pointed to tools like comprehensive community plans and cleaner, “greener” industrial policies. More than anything, the group articulated a need for more deliberation and participation. As panelist and farm co-owner Don Kretschmann put it, when it comes to change, we need to “think it through before we go ahead and do it.”

The maps themselves, bearing the inspirations scrawled out during the event, have not reached the end of the road. From here, these maps will accompany an upcoming exhibition of the artworks in Petrochemical America, which locals hope to bring to the greater Pittsburgh area in the coming months. League of Women Voters, for their part, continue to move the vision forward, inviting input from all on next steps, with an emphasis on pulling in a broader cross-section of the community.

To voice your vision, and to stay in the loop on future Re-Imagine Beaver County events, contact reimaginelwvpa@gmail.com.

Many thanks to Sophie Riedel for sharing photographs from the event, and to the International League of Conservation Photographers and the Environmental Integrity Project for sharing the aerial photograph of the Shell site from their joint project, “The Human Cost of Energy Production.”

By Leann Leiter, Environmental Health Fellow

 

Northern Access Project - pipeline map
Karen Edelstein

Northern Access Project: Exporting PA’s Marcellus Gas Northward

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In March 2015, the National Fuel Gas Supply Corporation and Empire Pipeline Company filed a joint application with the Federal Energy Resource Commission (FERC) to construct a new natural gas pipeline and related infrastructure, known collectively as the Northern Access Project (NAPL). The pricetag on the project is $455 million, and is funded through international, as well as local, financial institutions. The Public Accountability Initiative recently produced a report detailing the funding for this pipeline project, entitled “The Power Behind the Pipeline“.

The proposed Northern Access Project consists of a 97-mile-long, 24” pipe that would carry Marcellus Shale gas from Sergeant Township (McKean County), PA, to the Porterville Compressor Station in the Town of Elma (Erie County), NY. Nearly 69% of the proposed main pipeline will be co-located in existing pipeline and power line rights-of-way, according to FERC. The agency says this will streamline the project and reduce the need to rely on eminent domain to most efficiently route the project.

A $42 million, 15,400 horsepower Hinsdale Compressor Station along the proposed pipeline route was completed in 2015. In addition to the pipeline itself, the proposed project includes:

  • Additional 5,350 HP compression at the existing Porterville Compressor Station, a ten-fold increase of the capacity of that station
  • A new 22,214 HP compressor station in Pendleton (Niagara County), NY
  • Two miles of pipeline in Pendleton (Niagara County), NY
  • A new natural gas dehydration facility in Wheatfield (Niagara County), NY
  • An interconnection with the Tennessee Gas Pipeline in Wales (Erie County), NY, as well as tie-ins in McKean, Allegany, and Cattaraugus counties
  • A metering, regulation and delivery station in Erie County
  • Mainline block valves in McKean, Allegany, Cattaraugus and Erie counties; and
  • Access roads and contractor/staging yards in McKean, Allegany, Cattaraugus and Erie counties

Map of Proposed Northern Access Project


View map fullscreen | How FracTracker maps work

The above map shows the proposed pipeline (green) and related infrastructure (bright pink). The pale yellow and pink lines on the map are the existing pipelines that the Northern Access Project would tie into. Click here to explore the map fullscreen.

Project Purpose

National Fuel maintains that the goal of the proposed project would be to supply multiple markets in Western New York State and the Midwest. The project would also supply gas for export to Canada via the Empire Pipeline system, and New York and New England through the Tennessee Gas Pipeline 200 Line. The company anticipates that the project would be completed by late 2017 or early 2018. Proponents are hoping that NAPL will keep fuel prices low, raise tax revenues, and create jobs.

Push-back against this project has been widespread from citizens and environmental groups, including Sierra Club and RiverKeeper. This is despite an environmental assessment ruling in July 2016 that FERC saw no negative environmental impacts of the project. FERC granted a stamp of approval for the project on February 4, 2017.

Concerns about the Proposed Pipeline

The Bufffalo-Niagara Riverkeeper, asserts that the project presents multiple threats to environmental health of the Upper Lake Erie and Niagara River Watersheds. In their letter to FERC, they disagreed with the Commission’s negative declaration that the project would result in “no significant impact to the environment.” The pipeline construction will require crossings of 77 intermittent and 60 perennial streams, 19 of which are classified by the New York State Department of Environmental Conservation (NYS DEC) as protected trout streams. Twenty-eight of the intermittent streams impacted also flow into these protected streams. Resulting water quality deterioration associated with bank destabilization, increased turbidity, erosion, thermal destabilization of streams, and habitat loss is likely to impact sensitive native brook trout and salamanders. Riverkeeper found that National Fuel’s plan on how to minimize impacts to hundreds of wetlands surround the project area was insufficient. FERC’s Environmental Assessment of the project indicated that approximately 1,800 acres of vegetation would affected by the project.

Several groups have also taken issue with the proposed project’s plan to use the “dry crossing” method of traversing waterways. Only three crossings will be accomplished using horizontal directional drilling under the stream bed — a method that would largely protect the pipes from dynamic movement of the stream during floods. The rest will be “trenched” less than 5 feet below the stream bed. Opponents of the project point out that NYSDEC, federal guidelines, and even industry itself discourage pipe trenching, because during times of high stream flow, stream scour may expose the pipes to rocks, trees, and other objects. This may lead to the pipes leaking, or even rupturing, impacting both the natural environment, and, potentially, the drinking water supply.

A December 2016 editorial to The Buffalo News addressed the impacts that the proposed Northern Access Project could have to the Cattaraugus Creek Basin Aquifer, the sole source of drinking water for 20,000 residents in surrounding Cattaraugus, Erie, and Wyoming counties in New York. In particular, because the aquifer is shallow, and even at the surface in some locations, it is particularly vulnerable to contamination. The editorial took issue with the absence of measures in the Environmental Assessment that could have explored how to protect the aquifer.

Other concerns include light and noise pollution, in addition to well-documented impacts on climate change, created by fugitive methane leakage from pipelines and compressors.

NYSDEC has held three public hearings about the project already: February 7th at Saint Bonaventure University (Allegany, NY), February 8th at Iroquois High School (Elma, NY), February 9th at Niagara County Community College (Sanborn, NY). The hearing at Saint Bonaventure was attended by nearly 250 people.

While FERC approved the project on February 4, 2017, the project still requires approvals from NYSDEC – including a Section 401 Water Quality Certification. These decisions have recently been pushed back from March 1 to April 7.

Proponents for the project – particularly the pipefitting industry – have emphasized that it would create up to 1,700 jobs during the construction period, and suggested that because of the experience level of the construction workforce, there would be no negative impacts on the streams. Other speakers emphasized National Fuel’s commitment to safety and environmental compliance.

Seneca Nation President Todd Gates expressed his concerns about the gas pipeline’s impacts on Cattaraugus Creek, which flows through Seneca Nation land (Cattaraugus Indian Reservation), and is downstream from several tributaries traversed by the proposed pipeline. In addition, closer to the southern border of New York State, the proposed pipeline cuts across tributaries to the Allegheny River, which flows through the Allegany Indian Reservation. One of New York State’s primary aquifers lies beneath the reservation. The closest that the proposed pipeline itself would pass about 12 miles from Seneca Nation Territory, so National Fuel was not required contact the residents there.

Concerns about Wheatfield dehydration facility & Pendleton compressor station

According to The Buffalo News, National Fuel has purchased 20 acres of land from the Tonawanda Sportsmen’s Club. The company is building two compressors on this property, totaling 22,000 HP, to move gas through two miles of pipeline that are also part of the proposed project, but 23 miles north of the primary stretch of newly constructed pipeline. Less than six miles east of the Pendleton compressor stations, a dehydration facility is also proposed. The purpose of this facility is to remove water vapor from the natural gas, in accordance with Canadian low-moisture standards. According to some reports from a National Fuel representative, the dehydration facility would run only a few days a year, but this claim, has not been officially confirmed.

Residents of both Pendleton and Wheatfield have rallied to express their concerns about both components of the project, citing potential impacts on public health, safety, and the environment relating to air and water quality.

Northern Access Project Next Steps

The deadline for public comment submission is 5 pm on February 24, 2017 — less than two weeks away. To file a comment, you can either email NYS DEC directly To Michael Higgins at NFGNA2016Project@dec.ny.gov, or send comments by mail to NYS DEC, Attn. Michael Higgins, Project Manager, 625 Broadway, 4th Floor, Albany, NY 12233.

 

Note: this article originally stated that the Porterville Compressor Station would double its capacity as a result of the NAPL project. In fact, the capacity increase would be ten-fold, from 600 hp to about 6000 hp. We regret this error.

by Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance

Mariner East Technical Difficulties map
FracTracker Alliance

Remaining Questions on Mariner East Technical Deficiencies

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In the summer of 2015, Sunoco Logistics submitted applications to the Pennsylvania Department of Environmental Protection (DEP) to build its massive Mariner East 2 pipeline. The ME 2 pipeline would have the capacity to transport 275,000 barrels a day of propane, ethane, butane, and other hydrocarbons from the shale fields of Western Pennsylvania to the Marcus Hook export terminal, located on the Delaware River.

Sunoco’s applications were to satisfy the state’s Chapter 105 (water obstruction and encroachment) and Chapter 102 (erosion/sediment control and earth disturbance) permitting requirements. The DEP responded to Sunoco’s application, issuing 20 deficiency letters totaling more than 550 pages. Sunoco resubmitted their application in the summer of 2016 and the DEP again rejected many of its plans to disturb streams, ponds, and wetlands. In December, Sunoco resubmitted its revised application for a third time, hoping for final approval.

FracTracker Alliance first wrote about ME 2’s risks to watershed in August 2016, following Sunoco’s second application. Readers who want a general overview of the issues may find that article worth reading. In this new article, we dig deeper into the subject. Along with its December application, Sunoco also supplied the DEP with revised GIS files illustrating ME 2’s new route and documents summarizing its impacts to nearby water bodies. We have created a new map utilizing newly available data and provide contextual analysis valuable in determining how Sunoco responds to the DEP’s review of its prior rejected applications.

Detailed Mapping of Water Body Impacts

At the end of December, the DEP finally released Sunoco’s GIS files detailing water bodies that will be impacted by ME 2, as well as Sunoco’s data tables outlining alternative methods that might mitigate certain impacts. Our map (below) combines these new datasets to show the locations where ME 2’s route has changed since Sunoco’s initial application, presumably in response to the DEP’s technical deficiency letter.

Also on this map are water bodies: 1) implicated in ME 2’s environmental impact assessment, 2) determined by the DEP as likely impacted by construction, and 3) identified by Sunoco as having viable construction alternatives to mitigate impacts.

Mariner East 2 Technical Deficiencies Map


View map fullscreen | How FracTracker maps work

By viewing the map fullscreen and zooming in, one can click on a water feature to reveal its data tables (see below example). These tables contain information on the water body’s flow regime, the extent of permanent and temporary impacts, alternative crossing methods that could be used, and what benefits might come from those alternate methods. Also in the tables are a number of designations such as:

  • USGS Fish and Wildlife wetland classification (see guide). Most common are PEM (palustrine emergent wetland), PSS (palustrine scrub-shrub wetland), PFO (palustrine forested wetland), and PuB (palustrine unconsolidated bottom – i.e. ponds).
  • PA DEP stream designation (see guide). Most common are WWF (warm water fishes), CWF (cold water fishes), HQ (high quality), and EV (exceptional value).
  • PA Fish and Boat Commission classifications (see guide). Most common are ATW (approved trout water), STS (stocked trout stream), Class A (class A water), and WTS (wilderness trout stream).

An example water body data table that can be found on the map:
me2-zoom-screenshot2

Our analysis of this new data reveals the number of water crossings in question is significantly higher than what we estimated in August: now totaling 1,222 streams, 34 ponds, and 708 wetlands crossings. This increase is primarily due to Sunoco’s data also containing information on ephemeral and intermittent waters that are not typically accounted for in USGS data (all that was available at the time of our prior analysis).

Defining Impacts

The DEP’s Chapter 105 Joint Permit Application Instructions break down “impacts” into two broad categories: permanent and temporary. These are primarily used to assess environmental impact fees, but are also valuable in determining what parameters Sunoco will be held to during and after ME 2’s construction.

Permanent impacts: are “areas affected by a water obstruction or encroachment that consist of both direct and indirect impacts that result from the placement or construction of a water obstruction or encroachment and include areas necessary for the operation and maintenance of the water obstruction or encroachment located in, along or across, or projecting into a watercourse, floodway or body of water.”

Permanent impacts are calculated using the pipeline’s 50-foot permanent right-of-way. For streams, all bed and banks are to be restored to pre-construction conditions. For ponds and wetlands, permanent impacts are assumed to remain even if the area is considered restored.

Temporary impacts: are “areas affected during the construction of a water obstruction or encroachment that consists of both direct and indirect impacts located in, along or across, or projecting into a watercourse, floodway or body of water that are restored upon completion of construction.” Temporary impacts consist of areas such as temporary workspaces and access roads.

The below table lists the total impacted acres broken down by county. Of interest here is that more than 175 acres would be permanently impacted — equivalent to 134 football fields — with an additional 82 acres temporarily impacted.

Table 1. Impacted Acres by County

County Permanent Impacts (acres) Temporary Impacts (acre)
Allegheny 1.85 0.39
Berks 11.14 4.88
Blair 11.70 6.72
Cambria 20.21 8.48
Chester 10.30 3.92
Cumberland 24.06 7.61
Dauphin 8.12 6.55
Delaware 5.05 3.33
Huntingdon 18.75 8.04
Indiana 11.42 4.73
Juniata 5.25 3.02
Lancaster 4.65 1.66
Lebanon 6.48 2.53
Perry 5.58 2.63
Washington 9.37 2.94
Westmoreland 17.72 12.36
York 3.46 2.16
Total 175.12 81.93

Viable Options to Reduce Impacts

Example of an open cut wet crossing

An open cut wet crossing (image source)

Pipeline companies cross water bodies using a variety of methods depending on their classification. The DEP maintains three general categories for water crossings: minor (in streams less than or equal to 10 feet wide at the water’s edge at the time of construction), intermediate (perennial stream crossings greater than 10 feet wide but less than 100 feet wide at the water’s edge at the time of construction), and major (crossings of more than 100 feet at the water’s edge at the time of construction).

Minor and intermediate crossings often employ rudimentary trenching along “open cut” crossings where the water is either temporarily diverted (wet crossing) or allowed to flow during construction (wet crossing). After the cuts, the company attempts to repair damage done in the process of trenching.

In more sensitive places, such as in exceptional value streams, wetlands, and always in major crossings, a company uses conventional boring to tunnel under a water feature. When boring over long distances, such as under a lake or river, a company turns to Horizontal Directional Drilling (HDD), a more engineered form of boring. An example of HDD boring is seen below (image source):

hdd_crossing_example

We were surprised by the number of water crossings identified by Sunoco as having options to minimize impact. As the table below shows, more than 44% (869) of Sunoco’s crossings have an alternate method identified in the resubmitted applications. In most of these instances, the intended crossing method is either trenching through open cuts or dry crossings. The majority of identified alternatives would reduce impacts simply by altering the trenching route. 53 of the 869 were shown to have feasible conditions for conventional or HDD boring, but Sunoco categorized all of these as impracticable options despite their environmental benefits.

Table 2. Number of Crossings With and Without Viable Alternate Methods

Crossings Assessed but Unimpacted Impacted with No Alternative Impacted with Alternatives Total
Streams 313 925 297 1,535
Ponds 66 3 31 100
Wetlands 963 167 541 1,671
  1,342 1,095 869 3,306

Absorbing the Costs of Environmental Impacts

If executed, these alternative methods would decrease the length of crossings, limit right-of-way encroachments, prevent land fragmentation, and significantly reduce risks to larger water bodies. More likely, Sunoco will pay the impact fees associated with the less complicated crossing methods. We’ve summarized these fees (found in Sunoco’s resubmitted application) in the table below. In total, Sunoco would pay roughly $1.8 million in exchange for nearly 2,000 water body crossings – a fraction of the project’s $2.5 billion estimated cost:

Table 3. Impact Fees for Sunoco’s Preferred Crossings

County Permanent Impacts area (fees) Temporary Impact area (fees) Admin Fees Total Fees
Allegheny $15,200 $1,600 $1,750 $18,550
Berks $89,600 $19,600 $1,750 $110,950
Blair $94,400 $27,200 $1,750 $123,350
Cambria $162,400 $34,000 $1,750 $198,150
Chester $83,200 $16,000 $1,750 $100,950
Cumberland $192,800 $30,800 $1,750 $225,350
Dauphin $65,600 $26,400 $1,750 $93,750
Delaware $40,800 $13,600 $1,750 $56,150
Huntingdon $150,400 $32,400 $1,750 $184,550
Indiana $92,000 $19,200 $1,750 $112,950
Juniata $42,400 $12,400 $1,750 $56,550
Lancaster $37,600 $6,800 $1,750 $46,150
Lebanon $52,000 $10,400 $1,750 $64,150
Perry $44,800 $10,800 $1,750 $57,350
Washington $75,200 $12,000 $1,750 $88,950
Westmoreland $142,400 $50,000 $1,750 $194,150
York $28,000 $8,800 $1,750 $38,550
$1,408,800 $332,000 $29,750 $1,770,550

Conclusion

This week, acting DEP Secretary Patrick McDonnell met with residents who voiced frustration that the agency failed to provide an additional public comment period following Sunoco’s application resubmission. Nevertheless, the DEP is expected to greenlight Sunoco’s plans any day now, adding another to the list of recent pipeline approvals in the region. Sunoco needs its permits now in order to begin clearing trees prior to endangered species bat nesting season, which begins in April.

Meanwhile, communities along the pipeline’s path are preparing for the sudden wave of disruption that may ensue. Some have threatened lawsuits, arguing that the resubmitted application still contains many deficiencies including missing wetlands and private drinking wells that must be accounted for. Indeed, the map and data presented in this article confirms that there is still a lot that the general public does not know about ME 2 – in particular, the extent of water impacts the DEP seems willing to accept and the range of options at Sunoco’s disposal that might mitigate those impacts if it were forced to do so.

Finally, it is encouraging to see that the DEP is becoming more transparent in sharing datasets, compared to other pipeline projects. However, this data is complex and not easily understood without sufficient technical expertise. We are discouraged to think that it is unlikely the public will learn about additional changes to the construction plan until after permits are issued. In order for data to be useful, it must be made available throughout the process, not at the end stages of planning, and done so in a way that it becomes integrated into the agency’s public participation responsibilities.

by Kirk Jalbert, Manager of Community-Based Research & Engagement

Shell Ethane Cracker
FracTracker Alliance

A Formula for Disaster: Calculating Risk at the Ethane Cracker

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by Leann Leiter, Environmental Health Fellow
map & analysis by Kirk Jalbert, Manager of Community-Based Research & Engagement
in partnership with the Environmental Integrity Project

On January 18, 2016, Potter Township Supervisors approved conditional use permits for Shell Chemical Appalachia’s proposed ethane cracker facility in Beaver County, PA. A type of petrochemical facility, an ethane cracker uses energy and the by-products of so-called natural gas to make ethylene, a building block of plastics. FracTracker Alliance has produced informative articles on the jobs numbers touted by the industry, and the considerable negative air impacts of the proposed facility. In the first in a series of new articles, we look at the potential hazards of ethane cracker plants in order to begin calculating the risk of a disaster in Beaver County.

As those who stand to be affected by — or make crucial decisions on — the ethane cracker contemplate the potential risks and promised rewards of this massive project, they should also carefully consider what could go wrong. In addition to the serious environmental and human health effects, which might only reveal themselves over time, what acute events, emergencies, and disasters could potentially occur? What is the disaster risk, the potential for “losses, in lives, health status, livelihoods, assets and services,” of this massive petrochemical facility?

Known Ethane Cracker Risks

A well-accepted formula in disaster studies for determining risk, cited by, among others, the United Nations International Strategy for Disaster Reduction (UNISDR), is Disaster Risk = (Hazard x Vulnerability)/Capacity, as defined in the diagram below. In this article, we consider the first of these factors: hazard. Future articles will examine the remaining factors of vulnerability and capacity that are specific to this location and its population.

disaster-risk-infographic-websize

Applied to Shell’s self-described “world-scale petrochemical project,” it is challenging to quantify the first of these inputs, hazard. Not only would a facility of this size be unprecedented in this region, but Shell has closely controlled the “public” information on the proposed facility. What compounds the uncertainty much further is the fact that the proposed massive cracker plant is a welcome mat for further development in the area—for a complex network of pipelines and infrastructure to support the plant and its related facilities, and for a long-term commitment to continued gas extraction in the Marcellus and Utica shale plays.

williams-geismar-explosion-websize

U.S. Chemical Safety and Hazard Investigation Board, Williams Geismar Case Study, No. 2013-03-I-LA, October 2016.

We can use what we do know about the hazards presented by ethane crackers and nearby existing vulnerabilities to establish some lower limit of risk. Large petrochemical facilities of this type are known to produce sizable unplanned releases of carcinogenic benzene and other toxic pollutants during “plant upsets,” a term that refers to a “shut down because of a mechanical problem, power outage or some other unplanned event.” A sampling of actual emergency events at other ethane crackers also includes fires and explosions, evacuations, injuries, and deaths.

For instance, a ruptured boiler at the Williams Company ethane cracker plant in Geismar, Louisiana, led to an explosion and fire in 2013. The event resulted in the unplanned and unpermitted release of at least 30,000 lbs. of flammable hydrocarbons into the air, including ethylene, propylene, benzene, 1-3 butadiene, and other volatile organic chemicals, as well as the release of pollutants through the discharge of untreated fire waters, according to the Louisiana Department of Environmental Quality. According to the Times-Picayune, “workers scrambl(ed) over gates to get out of the plant.” The event required the evacuation of 300 workers, injured 167, and resulted in two deaths.

The community’s emergency response involved deployment of hundreds of personnel and extensive resources, including 20 ambulances, four rescue helicopters, and buses to move the injured to multiple area hospitals. The U.S. Chemical Safety and Hazard Investigation Board chalked up the incident to poor “process safety culture” at the plant and “gaps in a key industry standard by the American Petroleum Institute (API).” The accident shut the plant down for a year and a half.

Potential Risks & Shell’s Mixed Messages

Shell has done little to define the potential for emergencies at the proposed Beaver County ethane cracker plant, at least in materials made available to the public. Shell has revealed that general hazards include “fire, explosion, traffic accidents, leaks and equipment failures.”

However, we located numerous versions of Shell’s handout and found one notable difference among them—the brochure distributed to community members at a December 2016 public hearing held by the Pennsylvania Department of Environmental Protection (PA DEP) excluded the word “explosion” from the list of “potential safety concerns.” The difference is seen in comparing the two documents.

Figure #1 below: Excerpt of online version of a handout for Beaver County, dated May 2015, with “explosion” included in list of “potential safety concerns.” (Other Shell-produced safety documents, like the one included as an exhibit in the conditional use permit application on file with the township, and Shell’s webpage for the project, also include “explosion” in the list of hazards.)

Figure #2 below: Excerpt of handout, dated November 2016 and provided to the community at December 15, 2016 meeting, with the word “explosion” no longer included.

 

Additional hints about risks are peppered throughout the voluminous permit applications submitted by Shell to the PA DEP and Potter Township, such as references to mitigating acts of terror against the plant, strategies for reducing water contamination, and the possibility of unplanned upsets. But the sheer volume of these documents, coupled with their limited accessibility challenge the public’s ability to digest this information. The conditional use permit application submitted by Shell indicates the existence of an Emergency Response Plan for the construction phase, but the submission is marked as confidential.

Per Pennsylvania law, and as set forth in PA DEP guidelines, Shell must submit a Preparedness, Prevention, and Contingency Plan (PPC Plan) at an unspecified point prior to operation. But at that likely too-late stage, who would hear objections to the identified hazards, when construction of the plant is already a done deal? Even then, can we trust that the plan outlined by that document is a solid and executable one?

Shell’s defense of the Beaver County plant is quick to point out differences between other plants and the one to come, making the case that technical advances will result in safety improvements. But it is noteworthy that the U.S. Chemical Safety and Hazard Investigation Board attributes failures at the Williams Geismar plant, in part, to “the ineffective implementation of…process safety management programs… as well as weaknesses in Williams’ written programs themselves.” The Geismar explosion demonstrates some of the tangible hazards that communities experience in living near ethane cracker plants. It is worth noting that the proposed Beaver County facility will have about 2½ times more ethylene processing capacity than the Geismar plant had at the time of the 2013 explosion.

Opening the Floodgates

In an effort to expand our understanding of risk associated with the proposed Beaver County ethane cracker and the extent of related developments promised by industry leaders, FracTracker Alliance has constructed the below map. It shows the site of the Shell facility and nearby land marked by Beaver County as “abandoned” or “unused.” These land parcels are potential targets for future build-out of associated facilities. Two “emergency planning zones” are indicated—a radius of 2 miles and a radius of 5 miles from the perimeter of Shell’s site. These projections are based upon FracTracker’s discussions with officials at the Saint Charles Parish Department of Homeland Security and Emergency Preparedness, who are responsible for emergency planning procedures in Norco, Louisiana, the site of another Shell ethane cracker facility. The emergency zones are also noted in the 2015 Saint Charles Hazard Mitigation Plan.

Also shown on the map is an estimated route of the Falcon pipeline system Shell intends to build, which will bring ethane from the shale gas fields of Ohio and Pennsylvania. Note that this is an estimated route based on images shown in Shell’s announcement of the project. Finally, our map includes resources and sites of vulnerability, including schools, fire stations, and hospitals. The importance of these sites will be discussed in the next article of this series.

Ethane Cracker Hazards Map


View map fullscreen | How FracTracker maps work

While the site of the Shell cracker is worth attending to, it would be a mistake to limit assessments of disaster risk to the site of the facility alone. Shell’s proposed plant is but one component in a larger plan to expand ethane-based processing and use in the region, with the potential to rival the Gulf Coast as a major U.S. petrochemical hub. An upcoming conference on petrochemical construction in the region, scheduled for June 2017 in Pittsburgh, shows the industry’s commitment to further development. These associated facilities (from plants producing fertilizers to plastics) would utilize their own mix of chemicals, and their potential interactions would produce additional, unforeseen hazards. Ultimately, a cumulative impact assessment is needed, and should take into account these promised facilities as well as existing resources and vulnerabilities. The below Google Earth window gives a sense of what this regional build-out might look like.

What might an ethane cracker and related petrochemical facilities look like in Beaver County? For an idea of the potential build-out, take a tour of Norco, Louisiana, which includes Shell-owned petrochemical facilities.

Final Calculations

As discussed in the introduction, “hazard,” “vulnerability,” and “capacity” are the elements of the formula that, in turn, exacerbate or mitigate disaster risk. While much of this article has focused on drastic “hazards,” such as disastrous explosions or unplanned chemical releases, these should not overshadow the more commonplace public health threats associated with petrochemical facilities, such as detrimental impact on air quality and the psychological harm of living under the looming threat of something going wrong.

The second and third articles in this series will dig deeper into “vulnerability” and “capacity.” These terms remind us of the needs and strengths of the community in question, but also that there is a community in question.

Formulas, terminology, and calculations should not obscure the fact that people’s lives are in the balance. The public should not be satisfied with preliminary and incomplete risk assessments when major documents that should detail the disaster implications of the ethane cracker are not yet available, as well as when the full scale of future build-out in the area remains an unknown.

Much gratitude to Lisa Graves-Marcucci and Lisa Hallowell of the Environmental Integrity Project for their expertise and feedback on this article.

The Environmental Integrity Project is a nonpartisan, nonprofit watchdog organization that advocates for effective enforcement of environmental laws. 

For the Susquehanna River Basin Impacts Project
FracTracker Alliance

An Introduction to the Susquehanna River Basin Impacts Project

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By the FracTracker Alliance
In partnership with the Pennsylvania Chapter of the Sierra Club
and Clean Water Action 

Looking at a map of Pennsylvania, three major rivers span the Commonwealth — the Ohio River in the West, the Susquehanna River in the middle of PA, and the Delaware River in the East. The Delaware River Watershed benefits from the active oversight and management of the Delaware River Basin Commission (DRBC) and the Ohio is managed by Ohio River Valley Water Sanitation Commission (ORSANCO). The multi-state effort to protect the Susquehanna River is known as the Susquehanna River Basin Commission (SRBC).

These agencies differ greatly in how they oversee protections of their respective watersheds, particularly in the context of oil and gas development. For instance, the DRBC engages in a range of activities related to water quantity protection (like water supply allocation and water conservation), water quality, regulatory review and permitting, watershed-wide planning, flood mitigation and drought management, and recreational activities. Meanwhile, ORSANCO and the SRBC interpret their responsibilities very narrowly, primarily focusing on managing issues related to discharge standards in the case of ORSANCO, and water quantity in the case of the SRBC.

Major watershed boundaries in PA, with the Susquehanna River Basin shown in pale green. Source: DCNR

In this new series of articles, FracTracker Alliance, in partnership with the Sierra Club Pennsylvania Chapter and Clean Water Action, takes a closer look at the Susquehanna River Watershed and its many challenges related to industrial development, including deforestation and sedimentation issues, nutrient loading from poor agricultural practices, sewer and stormwater runoff. A significant component of Susquehanna River Basin impacts can be attributed to expanding oil and gas development. How will the Susquehanna River Watershed withstand future impacts from the oil and gas industry given the SRBC’s limited oversight? A first step in understanding the problem is to look at the state of the watershed today.

Oil & Gas in the Susquehanna River Watershed

As part of the ongoing Marcellus Shale oil and gas boom, nearly 5,500 unconventional wells on roughly 2,000 well pads have been drilled in the Susquehanna River Watershed since 2007. According to the Nature Conservancy, shale gas companies could drill 27,600 additional wells in the Susquehanna River basin by 2030, which would result in approximately 6,900 well pads (assuming four wells per pad, a relatively conservative number given recent trends where up to a dozen wells are being drilled on a single pad). These additional 4,900 well pads represent 31,850 acres of disturbed lands for the pads and access roads alone. Overall, the Nature Conservancy believes that up to 110,000 acres of forested land could be cleared in the Susquehanna River Watershed by 2030. In addition to well pads and access roads, one must also account for the impacts of associated pipelines. Estimates suggest that 12-15 acres of gathering line are installed per acre of well pad.

This explosive growth of the shale drilling industry, combined with declining resources for regulatory oversight, would complicate regional watershed management strategies. A growing body of evidence suggests that watersheds near hydraulic fracturing operations can be impacted by improper waste disposal, trucking accidents, migration of drilling fluids, as well as problems related to land disturbance such as pipeline and access road stream crossings, sedimentation and runoff (needs a reference). And while there are two major water monitoring programs operating in the Susquehanna River, one run by the Pennsylvania Department of Environmental Protection (PA DEP) and the other operated by the SRBC, significant questions remain about their ability to assess the Susquehanna River’s water quality. These concerns primarily stem from the infrequent and patchwork-like coverage of their sampling regimes, as well as inconsistencies in indicators measured at different sites.

Existing Water Monitoring Efforts

Watershed testing is key to understanding how industrial development affects water quality. It also significantly informs mitigation strategies. In this first map of the series (below), we have put together several layers to help illustrate the state of water testing in the Susquehanna River Basin. This map can be used to obtain summary information about unconventional oil and gas activity and monitoring efforts at the watershed level by clicking on individual features.

Note that there are two separate layers on this map depicting summary data — one outlined in dark green and one in light green, both at HUC-08 level. The dark green outlines are in PA only and contain oil and gas summaries of wells and violations. The light green outlines show agency-based monitoring activity, and are not restricted to PA boundaries. The reason for the two layers is that states classify oil and gas wells differently and so cannot be combined easily.

View map fullscreen | How FracTracker maps work

The Susquehanna River Basin has over 49,000 miles of waterways, according to the SRBC. While it may not be possible to fully document the impacts that the oil and gas industry has on the basin, there are some efforts underway to chronicle changes to the river system. In this map, we look at the efforts of governmental and quasi-governmental agencies to test the waters throughout the region, which range from periodic grab samples to automated data loggers that constantly evaluate several measures of water quality. There are advantages to both methods, as data loggers can capture short term spikes in conductivity, for example, that monthly sampling would likely miss altogether. However, grab sampling allows for a more in-depth analysis of the water in a laboratory than what the data loggers can provide.

While oil and gas is the focus of the map, it is not the only concern of the SRBC. Thus, considerable testing occurs in areas that are not seeing drilling activity. The drilling regions are shown on the map as a great orange arc, extending from Indiana County in the west-central part of Pennsylvania all the way to Susquehanna county in the Northern Tier. If you zoom in on this region, data for individual unconventional wells will become visible, along with permits for wells that have yet to be been drilled, and violations that have been issued by DEP.

Clusters of Development and Oversight

In some regions of the Susquehanna basin, there are significant clusters of oil and gas activity without a corresponding governmental monitoring regimen. Other areas have significant monitoring coverage. In many cases, periodic grab samples are taken from the same sites as data loggers – and may therefore appear twice on our map – to capture both aspects of monitoring activity. Our map can be used to find quick summary data for a given watershed.  For example, the Upper Susquehanna-Tunkhannock watershed is being monitored with 53 testing sites and nine data loggers. The same region has 2,178 wells, and 2,347 violations associated with these wells.

We can also use the map to focus on concerns at different scales. The cluster of drilling activity in Ulysses Township, seen below, resulted in a number of violations (shown in yellow). Due to historical impact of the oil and gas industry in this sub-watershed, additional monitoring locations might be called for.

While we think that it is important to protect all the Susquehanna’s waters, certain areas are more fragile than others. For instance, headwater streams that are designated as high quality (HQ) or exceptional value (EV) are vital to the overall health of the river system and their protection is required by Pennsylvania law. However, many headwaters streams have no monitoring despite heavy oil and gas drilling, as can be seen in the below map. We have included HQ/EV designated streams on the map, although due to the large amount of data these streams are not displayed by default. They can be seen by activating the layer.

Broader Implications

The Susquehanna River provides drinking water to 4.1 million people, including residents in New York, Pennsylvania, and Maryland. In addition, through water that is diverted to areas outside the watershed, it is estimated that the Susquehanna also serves as a drinking water supply for 2 million people in more populated areas such as Baltimore, MD and Chester County, PA. With clean drinking water hanging in the balance, and the potential build-out of thousands more natural gas well pads in the watershed, it is more important than ever to understand how oil and gas activity could affect the watershed.

The Pennsylvania Constitution reminds us of our right to clean air, pure water, and the preservation of the environment. Prior to the adoption of the Environmental Rights Amendment — 80 years ago this year — and long before the federal Clean Water Act, the Pennsylvania legislature passed the state level Clean Streams Law in recognition of the need to protect the integrity of our valuable aquatic resources. In the spirit of this tradition to lead on clean water issues, the SRBC, Pennsylvania, and surrounding states must commit to putting the protection and preservation of the Susquehanna River watershed at the forefront of decision-making within the basin.

In future installments of this series, we seek to reveal gaps in watershed and land management plans in order to evaluate what these risks mean for the people and environments of the Susquehanna River Basin. The mapping and analysis provided in this series will be used to frame a series of conversations throughout the Basin with the goal of encouraging concerned residents to become more involved in public discussions about watershed management planning. Further, this project will result in recommendations for tangible solutions to filling oversight and management gaps and communicate these findings to relevant agencies. Only with adequate information can the public ensure strong protections for this life-sustaining waterway. Recognizing the important work that the SRBC has done in recent years, we also hope to identify areas where the Commission can direct additional resources to analyzing the cumulative impacts of shale gas development and expand their oversight strategies.

Project Info

Read more about the Susquehanna River Basin Impacts Project

Top: fair use image by Nicholas A. Tonelli

Map of PA drilling complaints - collaboration with Public Herald
FracTracker Alliance

PA Fracking Complaints are Increasing, Systemic

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The Pennsylvania Department of Environmental Protection (DEP) logs incoming complaints from residents about drilling activity in the Commonwealth, and Public Herald has spent a great deal of time aggregating and making that information public. A recent investigation by Public Herald into that data, with help from FracTracker, has highlighted a number of concerning issues related to fracking in Pennsylvania unfortunately.

Concerning Complaints

Firstly, the data they reviewed indicate that complaints from residents about unconventional drilling (how most fracked wells are designated) are more common than those about traditional wells. Secondly, it seems that complaints about fracked wells are increasing over time, even though the number of new wells has decreased.

There may be several reasons for such trends, and Public Herald discusses some of them in their new report. Are fracking wells more likely to fail, resulting in a higher proportion of complaints from nearby residents? Or has tracking simply improved in recent years? What these trends undoubtably indicate, however, is that the impacts from drilling have been systemic, according to Drs. Ingraffea and Stolz, who also reviewed the data.

Probably the most troubling finding unearthed in this investigation is that the PA DEP was not transparent about complaint data. The information they released to Public Herald differed wildly from the spreadsheets previously obtained by other requestors. Learn more about this and other issues in Public Herald’s Hidden Data Report.

Read Public Herald Report

Digging into the Data

Below we have included a map showing where those complaints originated, as well as a table that parses out the data by county.

Pennsylvania Oil & Gas Complaint Map


View map fullscreen | How FracTracker maps work

The above map by Public Herald and FracTracker Alliance shows the density of citizen complaints reported to the Department of Environmental Protection from 2004 – 2016. It includes conventional and unconventional well complaints. Clicking on a township reveals a database of complaints where viewers can download files.

In addition to the report issued by Public Herald, you can explore the data mapped above in the table below. It fleshes out how many complaints have been issued by residents, where these complaints originated, and how many are specific to water issues.

Table 1. PA Unconventional Well Complaint Statistics Logged by the PA DEP

DEP Office County Total Complaints (#) Water Complaints (#) Municipalities w/Complaints (#) Drilled Unconventional Wells, Jan 2004 – Nov 29 2016
TOTALS
PENNSYLVANIA 47 9442 4108 893 10027
SWRO 3653 1427 328 3587
NWRO 3197 1159 284 1027
NCRO (ERO) 2592 1522 281 5413
BY COUNTY
SWRO Washington 1066 460 51 1478
ERO Susquehanna 648 393 32 1326
ERO Bradford 647 468 43 1371
SWRO Greene 576 156 26 1082
NWRO McKean 550 121 21 134
SWRO Westmoreland 538 219 43 270
NWRO Warren 443 106 26 3
NWRO Butler 419 186 35 497
SWRO Armstrong 388 208 38 223
SWRO Indiana 367 153 32 48
ERO Tioga 349 212 30 907
SWRO Fayette 335 121 28 291
NWRO Mercer 276 153 31 61
NWRO Venango 273 108 25 6
NWRO Crawford 258 141 35 3
NWRO Jefferson 244 113 29 56
ERO Lycoming 242 110 32 927
SWRO Allegheny 228 30 53 100
NWRO Clarion 186 89 23 28
NWRO Forest 177 56 8 22
ERO Clearfield 175 70 34 150
ERO Wyoming 167 92 19 258
NWRO Erie 164 17 30 0
NWRO Elk 143 37 9 146
ERO Potter 108 60 25 91
ERO Sullivan 86 47 8 127
SWRO Beaver 67 44 25 62
NWRO Lawrence 64 32 12 71
SWRO Somerset 44 16 18 26
SWRO Cambria 43 20 13 7
ERO Clinton 40 16 8 107
ERO Bedford 36 25 7 1
ERO Centre 33 10 9 65
ERO Luzerne 19 1 10 2
ERO Wayne 14 4 7 5
ERO Lackawanna 6 3 3 2
ERO Columbia 5 1 2 3
ERO Blair 4 3 2 6
ERO Cameron 4 2 2 64
ERO Huntingdon 2 2 1 1

SWRO = Southwest Regional Office; NWRO = Northwest Regional Office; NCRO (ERO) = North Central/Eastern Regional Office. Find your office here.

Read Public Herald Report
Stay Tuned

Public Herald will be releasing Part 2 of their Hidden Data report soon!

FracTracker Alliance

Revolving Doors & the PA Natural Gas Industry

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By Susan Volz, FracTracker Alliance Intern

The result of this year’s presidential election has sent shock waves through all levels of government. Many are now wondering what the next four years will look like in terms of funding and policy decisions. Just a few days after the inauguration, the next administration’s cabinet choices have many worried. For example, the person President-Elect Trump has selected to lead the transition at the Environmental Protection Agency (EPA), Myron Ebell, has connections to the fossil fuel industry, suggesting national energy policy may embrace fossil fuel development. Of equal concern are the industry connections of former ExxonMobil CEO Rex Tillerson as Secretary of State and former Texas governor Rick Perry as Secretary of Energy.

While these transformations are happening at the federal level, Pennsylvania has its own long history of revolving doors between government and industry that deserve attention. Examination of data collected by citizen advocate, Dorina Hippauf, as well as my own independent research, shows a state government with extensive ties to the oil and gas industry. This relationship is a concern given that state responses to national energy policy and climate change will become particularly important in coming years.

The Governor’s Office

Former Governor Ed Rendell, who served from 2003-2011, has multiple ties to the natural gas industry and was governor during the initial stages of the shale gas boom in PA. During this time, Governor Rendell leased 130,000 acres of state land to gas extraction companies (he later imposed a ban on leasing state lands). After leaving office, Rendell joined Element Partners, an equity firm with investments in the gas industry. Currently, Rendell is Co-chair of Building America’s Future, a bipartisan coalition of elected officials advocating for investment in the nation’s infrastructure. As recently as August 2016, Rendell has said he makes no apologies and remains a “strong advocate” of unconventional gas extraction, also stating that weaknesses in regulation were “cured” in 2010.

Pennsylvania’s shale gas industry saw its beginnings under Governor Rendell, but the industry truly boomed under Governor Tom Corbett. Corbett, a Republican, served a single term from 2011 to 2015. One of Corbett’s first acts as governor was to sign Act 13, which revised oil and gas laws and implemented the controversial impact fee in lieu of a severance tax. Corbett overturned Rendell’s ban on leasing public lands to gas companies. Corbett accepted $1.8 million in campaign contributions from gas companies. These contributions came not only from the companies themselves but also individual contributions from industry executives. Many of the companies that donated to Corbett’s campaign also found themselves appointed to the Marcellus Shale Advisory Commission.

Pennsylvania’s current Governor, Democrat Tom Wolf, campaigned on a platform of tougher restrictions on natural gas companies, as well as a 5% severance tax. However, the severance tax has failed to be implemented due to contentious budget negotiations with the Republican-held General Assembly. There were also concerns during Wolf’s campaign when it was revealed he had received $273,000 in donations from members of the gas industry. Many environmental advocates called on Wolf to return the funds.

Another important point to consider in these transitions is that, as elected officials move through various offices, their staffers often move with them or are appointed to influential positions. For example, K. Scott Roy served as Rendell’s chief of staff while in Harrisburg. After leaving politics, Roy joined Range Resources, one of the largest gas extraction companies in Pennsylvania. In the past he has also served as Treasurer for the Marcellus Shale Coalition.

The DEP: Regulating in the Public Interest?

The Department of Environmental Protection (DEP) is the state agency responsible for enforcing and regulating the natural gas industry in PA. However, research shows a consistent thread of secretaries with ties to the oil and gas industry dating as far back as secretaries James Seif (1995-2001) and David Hess (2001-2003). Both joined lobbying firms after leaving government. Seif joined Ridge Global, LLC, a lobbying firm founded by former governor Tom Ridge, which has had contracts with the Marcellus Shale Coalition, and where Seif currently serves as Principal of Energy and Environment. Hess joined Crisci, a lobbying firm with many gas companies as clients, where he is currently the Director of Policy and Communication at Crisci.

Katie McGinty was appointed by Governor Rendell and served from 2003 to 2008. Since leaving the agency she has worked for a number of energy-related companies including NRG Energy (operator of natural gas plants),  Element Partners (the same firm Ed Rendell joined), and has been senior vice-president at Westen Solutions (a consulting firm with several natural gas companies as clients). During her Senate campaign, McGinty faced criticism for the significant campaign donations she received from the natural gas industry, as well as her employment past. McGinty was succeeded by John Hanger, who served from 2008 to 2011. Hanger left the DEP to join the law and lobbying firm Eckert Seamans Cherin and Mellott, LLC, which is a member of the Marcellus Shale Coalition. One of their clients is the Pennsylvania Independent Oil and Gas Association (PIOGA).

Perhaps the most infamous DEP secretary was Michael Krancer (2011-2013), who once notoriously said, “At the end of the day, my job is to get gas done.” Prior to joining the DEP, Krancer worked for Blank Rome, a law and lobbying firm that represents gas companies and is also a member of the Marcellus Shale Coalition, where he now currently works once again. Krancer also served as a member of the Marcellus Shale Advisory Commission, the panel that advised Governor Corbett on unconventional gas drilling regulations. Krancer’s father, Ronald, was also a significant contributor to Corbett’s 2010 gubernatorial campaign. After Krancer left the DEP, Corbett appointed Christopher Abruzzo, who served for about a year, followed by Dana Ankust, who also served a single year.

When Tom Wolf took office in 2015, he appointed John Quigley to head the DEP. Due to his past working with environmental advocacy group PennFuture, there was optimism that Quigley’s appointment would take the DEP in a different direction. Quigley had also previously served as secretary of the Department of Conservation and Natural Resources. In 2014, the Pennsylvania Environmental Defense Council sued the Commonwealth to try and stop the leasing of state lands to gas companies. Quigley testified that he had felt pressure to allow the lease of public land. Quigley dramatically resigned as secretary of the DEP in May, 2016, as a result of a leaked email voicing frustration with environmental advocacy groups and gridlock in the General Assembly. Quigley is an interesting counterpoint to the trend of DEP secretaries being influenced by the shale gas industry — an environmental advocate entering a political arena hostile to the DEP’s mission.

If one looks deeper at the DEP, there is further evidence of the revolving door between the oil and gas industry and the agency. For example, Barbara Sexton served as executive deputy secretary before leaving to join Chesapeake Energy, where she is currently Director of Government Relations. Another former deputy secretary, John Hines, left the agency to work for Shell. Michael Arch, who was an inspection supervisor, left to work for PIOGA. And finally, L. Richard Adams was formerly the DEP watershed manager before joining Chief Oil and Gas.

Conclusion

These findings suggest that multiple aspects of the Pennsylvania state government have historical and presently revolving-door relationships with the oil and gas industry. In a sense, this situation is not entirely surprising. PA is one of the largest natural gas producing states in the country, and the rhetoric of energy policy sells natural gas as a cleaner, cheaper, domestically-produced alternative to coal or oil. Historically, states have acted as “laboratories of policy,” as the federal government has been slow to pass legislation addressing energy and climate change. The incoming Trump administration has shown itself to be enthusiastic about expanding the fossil fuel market. However, it’s impossible to predict what changes will happen to the EPA and federal regulations. Such unpredictability makes states all the more important in shaping environmental protection policy in the next few years. We need to be aware of these revolving doors so we can be prepared for what’s coming in the future.

Matt Kelso, BA

Hypothetical Impacts of Unconventional Drilling In Allegheny County

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

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

Click to Enter the Hypothetical Impacts Interactive Story Map

hypothetical impacts map

By Matt Kelso, Manager of Data & Technology

You Are Here feature image
Karen Edelstein

You Are Here!

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Read more
Karen Edelstein

“Taking” Wildlife in PA, OH, WV

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By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance

 

In an apparent move to step around compliance with comprehensive regulations outlined in the Endangered Species Act (ESA), a coalition of nine oil and gas corporations has filed a draft plan entitled the Oil & Gas Coalition Multi-State Habitat Conservation Plan (O&G HCP). The proposed plan, which would relax regulations on five species of bats, is unprecedented in scope in the eastern United States, both temporally and spatially. If approved, it would be in effect for 50 years, and cover oil and gas operations throughout the states of Ohio, Pennsylvania, and West Virginia—covering over 110,000 square miles. The oil and gas companies see the plan as a means of “streamlining” the permit processes associated with oil and gas exploration, production, and maintenance activities. Others outside of industry may wonder whether the requested permit is a broad over-reach of an existing loophole in the ESA.

Habitat fragmentation, air, and noise pollution that comes with oil and gas extraction and fossil fuel delivery activities have the potential to incidentally injure or kill bat species in the three-State plan area that are currently protected by the Endangered Species Act (ESA) of 1973. In essence, the requested “incidental take permit”, or ITP, would acknowledge that these companies would not be held to the same comprehensive regulations that are designed to safeguard the environment, particularly the flora and fauna at most risk to extirpation. Rather, they would simply be asked to insure that their impacts are “minimized and mitigated to the maximum extent practicable.”

Section 10(a)(2)(B) of the ESA contains provisions for issuing an ITP to a non-Federal entity for the take of endangered and threatened species, provided the following criteria are met:

  • The taking will be incidental
  • The applicant will, to the maximum extent practicable, minimize and mitigate the impact of such taking
  • The applicant will develop an HCP and ensure that adequate funding for the plan will be provided
  • The taking will not appreciably reduce the likelihood of survival and recovery of the species in the wild
  • The applicant will carry out any other measures that the Secretary may require as being necessary or appropriate for the purposes of the HCP

What activities would be involved?

n_long-eared_bat

The Northern Long-eared Bat is a federally-listed threatened species, also included in the ITP

The proposed plan, which would seek to exempt both upstream development activities (oil & gas wells) and midstream development activities (pipelines). Upstream activities include the creation of access roads, staging areas, seismic operations, land clearing, explosives; the development and construction of well fields, including drilling, well pad construction, disposal wells, water impoundments, communication towers; and other operations, including gas flaring and soil disturbance; and decommissioning and reclamation activities, including more land moving and excavation.

Midstream activities include the construction of gathering, transmission, and distribution pipeline, including land grading and stream construction, construction of compressor stations, meter stations, electric substations, storage facilities, and processing plants, and installation of roads, culverts, and ditches, to name just a few.

Companies involved in the proposed “Conservation Plan” represent the major players in fossil fuel extraction, refinement, and delivery in the region, and include:

  • Antero Resources Corporation
  • Ascent Resources, LLC
  • Chesapeake Energy Corporation
  • EnLink Midstream L.P.
  • EQT Corporation
  • MarkWest Energy Partners, L.P., MPLX L.P., and Marathon Petroleum Corporation (all part of same corporate enterprise)
  • Rice Energy, Inc.
  • Southwestern Energy Company
  • The Williams Companies, Inc.

Focal species of the request

Populations of federally endangered Indiana Bats could be impacted by the proposed Incidental Take Permit (ITP)

Populations of federally-endangered Indiana Bats could be impacted by the proposed Incidental Take Permit (ITP)

The five species listed in the ITP include the Indiana Bat (a federally-listed endangered species) and Northern Long-eared Bat (a federally-listed threatened species), the Eastern Small-footed Bat (a threatened species protected under Pennsylvania’s Game and Wildlife Code), as well as the Little Brown Bat and Tri-colored Bat. Populations of all five species are already under dire threats due to white-nose syndrome, a devastating disease that, since 2008, has killed an estimated 5.7 million bats in North America. In some cases, entire local populations have succumbed to this deadly disease. Because bats already have a naturally low birthrate, bat populations that do survive this epidemic will be slow to rebound. Only recently, wildlife biologists have begun to see hope for a treatment in a beneficial bacterium that may save affected bats. However, production and deployment details of this treatment are still under development. Best summarized in a recent article in the Pittsburgh Post-Gazette:

This [ITP] would be a huge deal because we are dealing with species in a precipitous decline,” said Jared Margolis, an attorney with the Center for Biological Diversity, a national nonprofit conservation organization headquartered in Tucson, Ariz. “I don’t see how it could be biologically defensible. Even without the drilling and energy development we don’t know if these species will survive.

In 2012, Bat Conservation International produced a report for Delaware Riverkeeper, entitled Impacts of Shale Gas Development on Bat Populations in the Northeastern United States. The report focuses on landscape scale impacts that range from water quality threats, to disruption of winter hibernacula, the locations where bats hibernate during the winter, en masse. In addition, because bats have strong site fidelity to roosting trees or groups of trees, forest clearing for pipelines, well pads or other facilities may disproportionately impact local populations.

The below map, developed by FracTracker Alliance, shows the population ranges of all five bat species, as well as the current areas impacted by existing development by the oil and gas industry through well sites, pipelines, and other facilities.

View map fullscreen | How FracTracker maps work

 

To learn more details about the extensive oil and gas development in each of the impacted states, follow these links:

  • Oil and gas threat map for Pennsylvania. Currently, there are ~104,000 oil and gas wells, compressors, and other related facilities here.
  •  Oil and gas threat map for Ohio. Currently, there are ~90,000 oil and gas wells, compressors, and other related facilities here.
  • Oil and gas threat map for West Virginia. Currently, there are ~16,000 oil and gas wells, compressors, and other related facilities here.

Public input options

The U.S. Fish and Wildlife Service (USFWS) announced in the Federal Register in late November 2016 its intent to prepare an environmental impact statement (EIS) and hold five public scoping sessions about the permit, as well as an informational webinar.  In keeping with the parameters of an environmental impact statement, USFWS is particularly interested in input and information about:

  • Aspects of the human environment that warrant examination such as baseline information that could inform the analyses.
  • Information concerning the range, distribution, population size, and population trends concerning the covered species in the plan area.
  • Additional biological information concerning the covered species or other federally listed species that occur in the plan area.
  • Direct, indirect, and/or cumulative impacts that implementation of the proposed action (i.e., covered activities) will have on the covered species or other federally listed species.
  • Information about measures that can be implemented to avoid, minimize, and mitigate impacts to the covered species.
  • Other possible alternatives to the proposed action that the Service should consider.
  • Whether there are connected, similar, or reasonably foreseeable cumulative actions (i.e., current or planned activities) and their potential impacts on covered species or other federally listed species in the plan area.
  • The presence of archaeological sites, buildings and structures, historic events, sacred and traditional areas, and other historic preservation concerns within the plan area that are required to be considered in project planning by the National Historic Preservation Act.
  • Any other environmental issues that should be considered with regard to the proposed HCP and potential permit issuance.

The public comment period ends on December 27, 2016. Links to more information about locations of the public hearings, as well as instructions about how to sign up for the December 20, 2016 informational webinar can be found at this website. In addition, you can electronically submit comments about the “conservation plan” by following this link.