February 16, 2009, PA Environment Digest: PA Trout Unlimited Issues White Paper On Marcellus Shale Natural Gas Drilling


Spotlight - PA Trout Unlimited Issues White Paper On Marcellus Shale Natural Gas Drilling


PA Council of Trout Unlimited, which represents 13,000 members in 53 local Chapters across the state, issued a white paper this week outlining its concerns about drilling for natural gas in theMarcellus Shale formation outlining several concerns about the need to make sure drilling is done in a way that does not damage natural resources.


The following is a summary of the white paper which is available online.


"We understand that natural gas drilling and other energy developments are important to the economy of the Commonwealth and the nation. However, we are adamant that this drilling be done in a manner that does not damage our natural resources. Deep gas well drilling is relatively new to Pennsylvania , and the environmental concerns have not been fully evaluated prior to numerous permits being issued. Adequate permit restrictions and oversight are necessary. We encourage our regulatory agencies to actively ensure that all protections be enforced to protect our water resources as afforded under the Clean Water Act and the Clean Streams Law."

PA Trout outlined several concerns:


-- The removal of millions of gallons of water from streams and aquifers to frack the Marcellus gas producing zones;


-- The potential environmental damage the fracking water will do; both on site and during its disposal;


-- Drilling activity in Special Protection Watersheds (High Quality and Exceptional Value streams) and Wilderness Trout Designated areas may permanently affect these areas;


-- Bonding is inadequate to deal with plugging/closing of wells and to deal with any long-term environmental implications of orphan/abandoned well sites;


-- Potential increase in sediment and stormwater from the well pad sites; and


-- Resource agencies may be inadequately staffed to deal with the increase in permit requests and on site enforcement.

In response to these concerns, the Council makes 13 recommendations:

1. Marcellus Shale drilling and production presents a new series of problems. Namely, the need for millions of gallons of water for fracking, and the need to properly treat and dispose of this water when it returns to the wellhead. Simply put, Pennsylvania must enact criteria and disposal methods not yet employed in the Commonwealth. As an organization concerned with coldwater fisheries and the water quality and quantity needed to support these fisheries, Pennsylvania Trout Unlimited (PATU) insists that PA DEP must meet this new challenge. For example, PA DEP should encourage the use of reverse osmosis units to remove salts and any associated heavy metals from production waters and reuse the resulting water for future fracking.


2. PATU strongly believes that Marcellus Shale development cannot be permitted within Exceptional Value (EV) watersheds. We do not see how the existing Best Management Practices (BMPs) for sediment and erosion control, given the significant earth disturbances associated with road and pad construction, can comply with the anti-degradation standards required under the Clean Streams Law.


3. PATU sees an urgent need for PA DEP to change its present bonding requirements for existing vertical wells, and to cover the likely higher plugging costs for Marcellus wells. PA DEP needs to take immediate steps to determine the anticipated costs of closing Marcellus wells. PA DEP needs to consult with surrounding states regarding their existing or proposed bonding rates for this class of wells. PA DEP also needs to work closely with the Interstate Oil and Gas Compact Commission (IOGCC) to assure that bonding rates meet the necessary closing costs for Marcellus wells. Without adequate bonding, Pennsylvania will inherit more abandoned wells that cannot be properly closed, and that risk the spewing of contaminants into our waterways, much as we presently see from pre-Act drilling, and where bonding was inadequate to close the wells.


4. PATU sees an urgent need for PA DEP to require a severance fee adequate to meet the Department’s costs for permitting, inspections and enforcement, including the logistical needs of the program.


5. In High Quality-Coldwater Fishery (HQ-CWF) watersheds, PA DEP should, at minimum, require individual permits for gas development. Individual permits assure that the public has an opportunity to review, object to, or request a public meeting on, the proposed drilling operation and its associated discharges prior to the issuance of the permit. These options are not available with the present practice of issuing general permits pursuant to Chapter 102. Appeal rights, under the general permit, are limited to a short window after issuance of the permit. We find this practice unacceptable.


6. Drilling projects have the potential to cause multiple impacts on our environment. Permit approvals should consider all of the impacts before issuing a permit, including water needs for drilling, treatment and discharge of backflows and brine, habitat destruction from drill site pads, and erosion from road construction and pipeline construction.


7. PATU urges state agencies to prohibit any oil and gas development in Exceptional Value (EV) watersheds, Wilderness Trout Stream watersheds, EV wetlands or areas containing threatened or endangered species. Increased oversight should be applied in High Quality-Coldwater Fishery (HQ-CWF) watersheds.


8. We insist that water withdrawal permitting by SRBC, DRBC and PA DEP be closely monitored. Namely, flows from the permitted watershed need to be documented at the time of withdrawal to assure that the stream uses are protected. This will require that flow monitoring devices are part of the permit, thus assuring that the Q-7/10* is not violated.


9. PA DEP is obligated to consider the cumulative impacts these drilling sites will pose in a watershed. In addition, resource agencies should evaluate the overall impacts to groundwater and surface flows and place a cap on permits to prevent Total Maximum Daily Loads (TMDLs) from being reached. While any one project may do minimal damage, the cumulative impacts from multiple projects could cause significant damage.


10. Surface landowners must consider the cumulative impacts of site development as it pertains to forest fragmentation and its potential impacts on our coldwater resources.


11. Roads built to and around well pad sites should be required to incorporate Environmentally Sensitive Maintenance principles as outlined by the Center for Dirt and Gravel Roads Program.


12. Fracking water must be treated at facilities built to meet NPDES permit requirements. Municipal sewage treatment plants are not capable of treating chlorides and toxins present in fracking water.


13. The public has the right to know what materials the industry is injecting for Marcellus Shale development. It also has the right to know the chemical analysis of the flowback water.

PA Trout recommends those sharing these concerns contact the Department of Environmental Protection, county conservation districts, the Game Commission and the Fish and Boat Commission in their local areas.

The full white paper is available online.

*Q-7/10 is defined as a consecutive 7- day low streamflow during a ten year drought. Water qualitymodeling is based on this low flow condition to assure that stream uses are maintained.

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