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Sandhill Crane

Giving Voice to the Sandhill Cranes: Place-based Arguments against Keystone XL

By Wrexie Bardaglio, guest commentator

When we hear his call, we hear no mere bird. We hear the trumpet in the orchestra of evolution. He is the symbol of our untamable past, of that incredible sweep of millennia which underlies and conditions the daily affairs of birds and men…” ~ Aldo Leopold, on the Sandhill Crane, in “Marshland Elegy”

Dilbit – or diluted bitumen – is refined from the naturally-occurring tar sands deposits in Alberta, Canada. In March 2017, I applied to the Nebraska Public Service Commission for standing as an intervenor in the Commission’s consideration of TransCanada’s request for a permit to construct a pipeline transporting dilbit – a project referred to as the Keystone XL pipeline. Below are my reflections on the battle against the permitting process, and how FracTracker’s maps ensured the Sandhill Crane’s voice made it into public record.

A Pipeline’s History

The Keystone 1 pipeline carries the dilbit from Alberta, to Steele City, Nebraska, and ultimately to Port Arthur, Texas and export refineries along the Gulf Coast. The state of Montana had already approved the Keystone XL project, as had the state of South Dakota. The decision of the South Dakota Public Utilities Commission was appealed, however, and has now worked its way to the South Dakota Supreme Court, where it is pending.

Resistance to TransCanada’s oil and gas infrastructure projects is not new. Beginning in 2010, some Nebraska farmers and ranchers joined forces with tribal nations in the Dakotas, who were also fighting TransCanada’s lack of proper tribal consultation regarding access through traditional treaty territory. The indigenous nations held certain retained rights as agreed in the 1868 Fort Laramie Treaty between the United States government and the nine tribes of the Great Sioux Nation. The tribes were also protesting TransCanada’s flaunting of the National Historic Preservation Act’s protections of Native American sacred sites and burial grounds. Further, although TransCanada was largely successful in securing the easements needed in Nebraska to construct the pipeline, there were local holdouts refusing to negotiate with the company. TransCanada’s subsequent attempts to exercise eminent domain resulted in a number of lawsuits.

In January of 2015, then-President Barack Obama denied the international permit TransCanada needed. While that denial was celebrated by many, everyone also understood that a new president could well restore the international permit. Indeed, as one of his first actions in January 2017, the new Republican president signed an executive order granting the permit, and the struggle in Nebraska was reignited.

“What Waters Run Through My Veins…”

While I am a long-time resident of New York, I grew up in the Platte River Valley of South Central Nebraska, in a town where my family had and continues to have roots – even before Nebraska became a state. There was never a question in my mind that in this particular permitting process I would request status as an intervenor; for me, the matter of the Keystone XL Pipeline went far beyond the legal and political and energy policy questions that were raised and were about to be considered. It was about who I am, how I was raised, what I was taught, what waters run through my veins as surely as blood, and who my own spirit animals are, the Sandhill Cranes.

wrexie_3yrs

Bardaglio (age 3) and her father, along the banks of the Platte River

When we were growing up, our father told us over and over and over about why Nebraska was so green. The Ogallala Aquifer, he said, was deep and vast, and while eight states partially sat atop this ancient natural cistern, nearly all of Nebraska floated on this body. Nebraska was green, its fields stretching to the horizon, because, as our father explained, the snow runoff from the Rockies that flowed into our state and was used eleven times over was cleansed in water-bearing sand and gravel on its way to the Missouri on our eastern boundary, thence to the Mississippi, and finally to the Gulf.

I grew up understanding that the Ogallala Aquifer was a unique treasure, the largest freshwater aquifer in the world, the lifeblood for Nebraska’s agriculture and U.S. agriculture generally, and worthy of protection. I thought about the peril to the aquifer because of TransCanada’s plans, should there be a spill, and the additional threats an accident would potentially pose to Nebraska’s rivers, waterways and private wells.

2000px-ogallala_saturated_thickness_1997-sattk97-v2-svg

The Ogallala Aquifer

Knowing that climate change is real, terrifying, and accelerating, I recognized that a warming world would increasingly depend on this aquifer in the nation’s midsection for life itself.

Migration of the Sandhill Cranes

As I thought about how I would fight the KXL, another narrative took shape rising out of my concern for the aquifer. Growing up in the South Central Platte River Valley, I – and I daresay most everyone who lives there – have been captivated by the annual migration of the Sandhill Cranes, plying the skies known as the Central Flyway. As sure as early spring comes, so do the birds. It may still be bitterly cold, but these birds know that it is time to fly. And so they do – the forward scouts appearing in winter grey skies, soon followed by some 500,000 – 600,000 thousand of them, darkening the skies, their cries deafening and their gorgeous archaeopteryx silhouettes coming in wave after wave like flying Roman Legions.

branch-bird-sky-sunrise-sunset-morning-dawn-flock-dusk-birds-cranes-water-bird-bird-migration-migratory-birds-atmospheric-phenomenon-animal-migration-crane-like-bird-529634

To this day, no matter where I am, the first thing in my sinews and bones when winter begins to give way is the certainty that the birds are coming, I feel them; they are back. They are roosting on the sandbars in the braided river that is the Platte and gleaning in the stubbled fields abutting it… they are home.

According to The Nature Conservancy:

Scientists estimate that at least one-third of the entire North American population of Sandhill Cranes breed in the boreal forest of Canada and Alaska…

Scientists estimate that approximately 80 percent of all Sandhill Cranes in North America use a 75-mile stretch of Nebraska’s Platte River during spring migration. From March to April, more than 500,000 birds spend time in the area preparing for the long journey north to their breeding grounds in Canada and Alaska. During migration, the birds may fly as much as 400 miles in one day.

Sandhill Cranes rely on open freshwater wetlands for most of their lifecycle. Degradation of these kinds of wetland habitats is among the most pressing threats to the survival of Sandhill Cranes. (Emphasis added)

Giving Sandhill Cranes a Voice

But how could I make the point about the threat TransCanada posed to the migratory habitat of the Sandhill Cranes (and endangered Whooping Cranes, pelicans, and hummingbirds among the other thermal riders who also migrate with them)? Books, scientific papers, lectures – all the words in the world – cannot describe this ancient rite, this mysterious primal navigation of the unique pathway focusing on this slim stretch of river, when viewed from a global perspective a fragile skein in a fragile web in a biosphere in peril.

In my head I called it a river of birds in the grassland of sky. And I am so grateful to my friend, Karen Edelstein at FracTracker Alliance, for her willingness to help map and illustrate the magnificence of the migration flyway in the context of the three proposed options for the KXL pipeline.

flyway_map

Karen prepared two maps for me, but my favorite is the one above.

It shows an ancient, near-primordial, near-mystical event. Guided by rudders and instinct we can barely comprehend, in concert with earth’s intrinsic and exquisitely-designed balance, and as certain as a sunrise, a sunset or a moon rise, these oldest of crane species find their ways through the heavens. They hew to certainties that eclipse the greed of multinational corporations like TransCanada, who barely even pay lip service to the integrity of anything over which they can’t exert dominion. To say they don’t respect the inherent rights of species other than our own, or to ecological communities that don’t directly include us, is an understatement, and a damning comment on their values.

I was prepared for pushback on these maps from TransCanada. And in truth, the company was successful in an in limine motion to have certain exhibits and parts of my testimony stricken from the official record of the proceedings.

But not the maps.

In fact, too many other intervenors to count, as well as several of the lawyers involved in the proceedings commented to me on the beauty and accuracy of the maps. And not only are they now a part of the permanent record of the Nebraska Public Service Commission, should there be an appeal (which all of us expect), on both sides of the issue, there is a very good possibility they will be incorporated into the formal testimonies by the lawyers as the matter moves through the appeals process.

Taking Action, Speaking Out

Ordinary citizens must figure out how to confront the near-impenetrable stranglehold of multi-national corporations whose wealth is predicated on the continuance of fossil fuels as the primary sources of energy. We have had to become more educated, more activist, and more determined to fight the destruction that is now assured if we fail to slow down the impacts of climate change and shift the aggregate will of nations towards renewable energy.

Many activists do not realize that they can formally intervene at the state level in pipeline and infrastructure permitting processes. In doing so, the voice of the educated citizen is amplified and becomes a threat to these corporations whose business models didn’t account for systematic and informed resistance in public agencies’ heretofore pro forma proceedings. The publicly-available documents and filings from corporations can be important tools for “speaking truth to power” when paired with the creative tools born of necessity by the environmental movement.

Technology is value-neutral, but as I learned – as did many others in the Keystone XL Pipeline fight – in skilled hands it becomes a weapon in the struggle for the greater good.

I will be forever grateful for FracTracker, and will be interested to see how others use this tool in the fights that are sure to come.

EXCELSIOR!

For more background on the natural history of Sandhill Cranes, please view this video produced by The Crane Trust.


Wrexie Bardaglio is a Nebraska native living in Covert, New York. She worked for ten years for a member of Congress as a legislative assistant with a focus on Indian affairs and for a DC law firm as legislative specialist in Indian affairs. She left politics to open a bookstore in suburban Baltimore. She has been active in the Keystone XL fights in Nebraska and South Dakota and in fracking and gas infrastructure fights in New York.

This article’s feature image of a Sandhill Crane is the work of a U.S. Fish and Wildlife Service employee, taken or made as part of that person’s official duties. As a work of the U.S. federal government, the image is in the public domain.

FracTracker Alliance makes hundreds of maps, analyses, and photos available for free to frontline communities, grassroots groups, NGO’s, and many other organizations concerned about the industry to use in their oil and gas campaigns. To address an issue, you need to be able to see it.

However, we rely on funders and donations – and couldn’t do all of this without your help!

Susquehanna River Basin map article #2

Violations and Monitoring in Pennsylvania’s Susquehanna River Basin

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


View Map Fullscreen | How FracTracker Maps Work

Limitations of Monitoring Efforts

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

Map of O&G violations and water monitoring near Dimock, PA

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

Map of O&G Violations and monitoring near Leroy Township, PA

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

Map of O&G violations and monitoring near Bell Township, PA. Susquehanna River Basin project

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

Mariner East Technical Difficulties map

Remaining Questions on Mariner East Technical Deficiencies

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 fullscreenHow 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

For the Susquehanna River Basin Impacts Project

An Introduction to the Susquehanna River Basin Impacts Project

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.

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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.

Top: fair use image by Nicholas A. Tonelli

Mariner East 2 Pipeline Route

Mariner East 2 and Watershed Risks

Mariner East 2 (ME 2) is a $2.5 billion, 350 mile-long pipeline that, if built, would be one of the largest pipeline construction projects in Pennsylvania’s history—carving a fifty-foot wide path through 17 counties. A project of Sunoco Logistics, ME 2 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 and neighboring states to an international export terminal in Marcus Hook, located on the Delaware River.

ME 2 has sparked a range of responses from residents in Pennsylvania, however, including concerns about recent pipeline accidents, the ethics of taking land by eminent domain, and the unknown risks to sensitive ecosystems. Below we explore the watersheds that could be impacted by this proposed pipeline.

Watershed Impacts

While some components of Sunoco’s ME 2 proposal are approved, the project requires more permits from the Pennsylvania Department of Environmental Protection (DEP) before construction can begin. Among those are permits to build through and under stream and wetlands. Many of the waters threatened by ME 2 are designated by the Commonwealth as “exceptional value” (EV) or “high quality” (HQ) and are supposed to be given greater protections from harm. Water Obstruction and Encroachment Permits, also known as “Chapter 105” permits, are required for any building activities that would disrupt any body of water, including wetlands and streams. Sunoco applied for these so-called “Chapter 105” permits in the summer of 2015, but its applications were rejected as incomplete several times.

The below map shows the ME 2 route as of May 2016 relative to the watersheds and streams it will cross. Zoom into the map to see additional layers. Note that this is the most accurate representations of ME 2’s route we have seen to date. MWA provided the shapefiles for ME 2’s route to FracTracker Alliance and continues its investigations into potential watershed impacts.

Proposed ME 2 Route

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In total, ME 2’s path will include 1,227 stream crossings, 570 wetland crossings, and 11 pond crossings. Of the 1,227 stream crossings, 19 are EV and 318 are HQ, meaning that 337 crossings will disturb what DEP refers to as “special protection” waters. In addition, there are 129 exceptional value wetlands being crossed. These numbers were compiled by Mountain Watershed Association (MWA) from Sunoco’s permitting applications. MWA also identified 2 HQ streams in Washington County, and 3 HQ streams in Blair County, that are proposed to be crossed that are not acknowledged as being HQ in Sunoco’s permits.

Public Comment Period Open

People living along the proposed route are sometimes in the best position to see what the route looks like from the ground, where wetlands and streams are, and what kinds of wetlands and streams they are. The DEP is accepting public comments on Sunoco’s ME 2 Ch. 105 permit application through Wednesday, August 24. Each DEP regional office receives separate Ch. 105 applications depending on where the pipeline routes through different counties. Those wishing to comment on the project can do so through the DEP regional office websites: DEP Southwest RegionDEP South-central Region, DEP Southeast Region. For guidance on how to write comments on permits, see MWA’s Pipeline Project Information & Talking Points.


We wish to thank Mountain Watershed Association and the Clean Air Council for helping us compile data and analysis for this article.

Written by Kirk Jalbert, PhD, MFA – Manager of Community-Based Research & Engagement, FracTracker Alliance

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