Arctic Drilling: Not Ready for Prime Time

The USCG said Friday that it is coordinating a response with Royal Dutch Shell representatives after the company’s brand new $200 million tugboat experienced multiple engine failures while towing Shell’s arctic semisubmersible drilling rig, the Kulluk, approximately 50 miles south of Kodiak Island Friday, in 20-foot seas. Rough but not unusual conditions for the Arctic.  

The tugboat M/V Aiviq towing Shell’s Kulluk drill rig in better times. Photo courtesy gCaptain.

This is right on the heels of the Coast Guard discovering “several major safety and pollution prevention equipment” deficiencies on Shell’s other Arctic rig, the Noble Discoverer drillship.

And remember when the Discoverer went rogue and ran aground in Dutch Harbor back in July?

And Shell crushed their supposed oil spill containment device “like a beer can” during a field test this summer in water just 120 feet deep?

After having multiple delays getting their oil spill response vessel to meet Coast Guard standards?

This is a surprising – alarming? – series of missteps, mistakes and outright failures for a company of Shell’s size, talent, market cap and ambitions.  Especially considering how much time and money, and political capital, they’ve invested in this program.  But it’s not too late to take a prudent time out to allow a thorough, critical evaluation of whether we are really ready to drill safely in the Arctic, and respond effectively to oil spills in that tough environment.

Because if Shell isn’t ready after all this time and effort and investment, then who on earth is?

Fracking With Diesel Fuel

We here at SkyTruth are happy to see the our data being put to good use by our colleagues over at FracTracker. Using our fracking chemical database that we released last month, they have created an interactive map that visualizes where diesel fuel is being used in hydraulic fracturing. In October we posted that industry self-reported using diesel fuels at least 448 times, in spite of the fact these substances are the one family of chemicals not included in the abundantly generous “Halliburton Loophole.”

Check out FracTracker’s interactive map embedded below to see where this practice is used most. (Kerosene in Arkansas, New Mexico, Colorado, and N. Pennsylvania, and diesel fuel [sometimes called petroleum distillate] in Texas esp.)

To find out more about the practice, why it is dangerous, and how diesel fuels are defined, check out our original post on this issue:

What on Earth is a Waterdog?

This past summer SkyTruth and the Downstream Project went up to Northern Pennsylvania to document Marcellus Shale gas development in and around the Pine Creek Watershed, a watershed known to Pennsylvanians as the “Grand Canyon of the East.” Our trip was facilitated by LightHawk, a volunteer conservation pilot association who took us up in a single-engine aircraft to get an aerial perspective on unconventional shale gas wells popping up across the Northern Tier (Read more about our part of the story here). However, one of the most unique features we found was the waterdogs.

Eastern Hellbender: Image from Davidson College.

“Waterdog” is a nickname for a type of Hellbender, North America’s largest salamander. But because of local citizens’ concern for the habitat and health of these elusive creatures, and the amount of time volunteers spend in the streams they care about, these citizen-scientists have taken to calling themselves the “Pine Creek Waterdogs.” To learn more, check out:


Waterdogs from The Downstream Project on Vimeo.

Special thanks to The Downstream Project, Pine Creek Headwaters Protection Group, Trout Unlimited: God’s Country Chapter, Dickinson College’s Alliance for Aquatic Resource Monitoring (ALLARM), and LightHawk.

And the flaring continues off Nigeria…

Looks like flaring on offshore oil and gas platforms in Africa didn’t take a holiday this year. As you can see by this MODIS Aqua 7-2-1 image from  12/23/2012, there was lots and lots of flaring activity going on off the coast of Nigeria.

MODIS Aqua 7-2-1 taken on 12/23/2012 showing multiple flaring incidents off the Nigerian coast.

And not to be outdone, this area where we’ve seen flaring before is at it again:

MODIS Aqua 7-2-1 taken on 12/23/2012 shows an area of flaring that we’ve been following for awhile now.

You can read about that spot off the Niger Delta on our blog post of December 3.We still don’t know who is operating out there, so if anyone knows, fill us in!

SkyTruth Joins Petition Regarding Pacific NW Coal Exports

SkyTruth has joined WaterKeeper Alliance members from around the Pacific Rim and other NGO’s in petitioning the Army Corps of Engineers (ACoE) to  widen the scope of their environmental impact statement (EIS) for the Gateway Pacific Coal Terminal at Cherry Point in Whatcom County, WA. We endorse this petition because it supports our vision of “a world where all people can see and understand the environmental consequences of human activity everywhere on the earth.” 
Smog (grey clouds) over China as seen by NASA’s MODerate resolution Imaging Spectroradiometer (MODIS) in October 2010.  Increased exports through the Pacific Northwest are expected to find a major market in China and Southeast Asia.
Photo: NASA/MODIS
From our perspective of the earth through the lenses of satellites, aerial images, and spatial data, we have a unique perspective on the footprint of human activity and the far-reaching impacts of our development. In order for the ACoE to make a accurate judgement on the positive and negative elements of this project, all of the impacts have to be accounted for. This petition calls for a thorough environmental impact statement that:
  • Analyzes impacts to every community impacted by the mining, transport and burning of coal, including impacts in Montana, Idaho, Washington, India, China and Bangladesh.
  • Quantifies the air, land and water pollution from coal dust that will blow off rail cars, barges, transfer stations and loading areas contaminating communities, people, wildlife and waterways with heavy metals and particulates.
  • Thoroughly assesses the impacts of habitat alteration and pollutant impacts to natural resources, parks and wildlife including the rare, threatened and endangered species in the Columbia River Basin, the Puget Sound Basin and in the Cherry Point Aquatic Reserve where the terminal might be built, including impacts to threatened Puget Sound Chinook Salmon, steelhead trout and bull trout as well as endangered Southern Resident Orca Whales.
  • Calculates and reports the amount of mercury, fine particulates and other air pollutants that will blow back across the Pacific Ocean and pollute Pacific Northwest after the coal has been burned in power plants in India and China.
  • Analyzes the impacts to cultural and archaeological resources in tribal communities that are located in the path of the coal trains, barges and ships that will supply the Gateway Pacific Terminal.
  • Assesses the likely drop in property values due to air emissions, coal dust and traffic disruption along railroad path.
  • Fully assesses the increased risk of a marine accident that could result in a major oil spill in the already-crowded waters of Puget Sound and the Salish Sea, due to 900 or more container ship transits per year. This should include a major spill’s likely impact on the economy and on threatened and endangered species, including the endangered Southern Resident orca whale.
  • Quantifies the carbon emissions generated by the burning and transport of the coal, as well as its impact on global climate change and ocean acidification.
  • Includes a no-action alternative.
The comment period will remain open through January 21, 2013: to sign, visit: 

To: Bureau of Land Management RE: Fracking Disclosure Recommendations for Public Lands

The Bureau of Land Management (BLM) is currently considering regulations and guidelines for unconventional oil and gas development on millions of acres of public land, and SkyTruth believes that public disclosure must be an integral part of these new rules. The BLM has already indicated that they are strongly considering FracFocus.org as the platform for disclosure, however, there are a number of transparency issues which are not currently addressed by the industry-funded website.
 
The Jonah Field in Sublette County, WY is partly managed by the BLM and has seen heavy development in recent years, based on mineral leases from the 1970’s. Millions more acres are under consideration for development, requiring strong, effective management with accurate and accessible disclosure.

Photo Credit: Bruce Gordon, EcoFlight
 
 
The BLM is a federal agency responsible for over 750 million acres of subsurface mineral rights, including an estimated 57.2 million acres of split estate properties; that is, the surface is privately owned, but the minerals belong to someone else. In this case, the deed holder is the U.S. government, and the guidelines for fracking on these lands will have significant impact on thousands of citizens and will likely set the national standard for disclosure and transparency.
In November, we released a unique database containing over 27,000 fracking chemical reports from FracFocus, an action that would have been unnecessary in a truly transparent and accessible system. In the interest of transparency, public health, and legal protection of property and resources, we advise the BLM to include the following functions in any final ruling on disclosure:
 
▪   Make Bulk Raw Data Download Available
▪   Lift Intellectual Property Restrictions
▪   Require “Official” Reference Copy for Reports
▪   Require a Document Publish Date
▪   Require Document Change Management
 
Make Bulk Raw Data Download Available:
Issue:
In order to perform any aggregate analysis operation, currently a member of the public must go to great lengths to extract data from individual PDF files in order to compile them into a spreadsheet or database. We have demonstrated how this would be done with our Fracking Chemical Database, released last month.
This is necessary for tasks like the following:
The current publication mechanism presents a substantial up-front barrier to anyone seeking to use FracFocus data for research or regulatory purposes.
Recommendation:

 

  • Minimum – Publish the entire collection in a simple standard text format (like CSV) that can be imported directly into a spreadsheet or database. 
  • Better – Provide a way to bulk download all the disclosure data in a search result set (as raw data, not PDFs)
  • Best – Consider automatically re-publishing fracfocus.org disclosure content to data.gov or similar Open Data Initiative publication portal

 

 

Lift Intellectual Property Restrictions:

Issue: 

Intellectual Property (IP) /Copyright Statement on the FracFocus website is unreasonably restrictive
            
Recommendation: 
Remove the IP restriction entirely for all the disclosure data. Make an explicit statement that the data can be freely shared and used for any purpose.

Require “Official” Reference Copy for Reports:

Issue: 

There is no way to link directly to an individual disclosure document published on fracfocus.org. This is problematic for anyone reporting on the content of a disclosure because in order to reference the original document, they must re-publish a copy of it.
            
Recommendation: 
Add a mechanism to provide a permanent link to each disclosure document based on a unique document ID number. This becomes the official reference copy of the document in case there is any question about the accuracy of data re-published by a third party.

Require a Document Publish Date:

Issue:

Currently there is no way to tell when a disclosure was first published, so there is no way to verify after the fact whether the disclosure was made in the required time window.
 
Recommendation: 
Include a “published” date with each disclosure record

Require Document Change Management:

Issue:

We have observed documents that had their content altered after publication, so that the first edition of the document is no longer available and the new edition bears no indication that a previous edition was published.

            

Recommendation: 
Add a document change history and/or edit tracking to the document record, and assign a new unique document ID to the revised document so that the earlier revision is still accessible
Summary:
 
Millions of acres held in the common trust of the American people are under consideration for an extractive process with a very large footprint and potentially significant impacts on air, land, and water. It is critical to the oversight and regulation of this process that the Bureau of Land Management require a disclosure and transparency system that is complete, accessible to all, and enforceable. As we have written before, FracFocus does not provide this transparency and access in its current configuration. Decisions about disclosure should either incorporate changes to the FracFocus disclosure platform, or utilize another system that accommodates the aforementioned needs.

The West Virginia Hills: Flyover of Wetzel County Gas Drilling (Part 2)

Last week I posted Part I of our LightHawk flight over West Virginia’s most active unconventional gas field in Wetzel County. Part I highlighted what an actual hydraulic fracturing job looks like and illustrated a chronic issue in  rugged terrain – frequent “slips,” which are effectively small landslides. Today I will point out several more issues that were readily visible from an aerial perspective: infrastructure, habitat fragmentation, and proximity to homes.

Highlight #3: Infrastructure

While not discussed nearly as much as water contamination, buildout of natural gas infrastructure is a certain impact of unconventional  shale gas development. Gas separator units and condensate tanks remain on the wellpad for the productive life of the well, pipeline networks crisscross the fields and forests to connect all of the wells to market,  compressor stations will run as long as there is gas moving through the pipelines, and large petrochemical facilities set up shop in traditionally rural areas. These facilities have a big footprint on the land, and contribute to air, noise, and light pollution in largely rural areas.
One facility that stood out in particular is the new Mark West Compressor Station near Mobely, WV. Because of the lack of flat ground in these hills, with the exception of floodplains, any major installation is going to have a larger than usual footprint, and this one in particular appears to have completely rearranged the natural profile of the ridge top:
Our colleagues at the Wetzel County Action Group tell us this ridge has been lowered at least 100 feet. It is apparent that the terrain has been heavily modified.                                  
Photo: David Manthos, SkyTruth; Facilitated by LightHawk

Highlight #4: Habitat Fragmentation

Add miles of access roads and pipeline right-of-ways to the footprint of development and the total area impacted increases considerably. In mixed land-use areas this may not be a major issue, but in contiguous forests and state game lands fragmentation has serious ecological consequences. The USGS recently published a paper on habitat fragmentation in Washington and Bradford County, Pennsylvania, using aerial image analysis and GIS like we do here at SkyTruth. They concluded that change was occurring in the these counties, but was not yet very significant due to the high quantity of pre-existing fragmentation of those areas. The paper explains the concepts of fragmentation very well but we need to see similar studies conducted with a narrower focus (such as the Loyalsock State Forest in PA).
 

 

In the background of the Mark West Facility, two pipeline right-of-ways are visible in the center and to the right. These are just a couple examples of the miles of pipelines and service roads that will disect the forests of active gas fields for the lifetime of well-production.
Photo: David Manthos, SkyTruth; Facilitated by LightHawk
 
However, infrastructure, fragmentation, and air, noise, and light pollution may seem to be insignificant if human residents aren’t directly impacted by it. Biodiversity loss aside (a topic for a whole different post), in Wetzel County and across the nation, residents are experiencing a growing number of well pads, compressor stations, and other facilities moving in close to home, bringing us to the final point for this post.

Highlight #5: Residential Proximity

West Virginia law, House Bill 401 to be specific, has restrictions on how close drilling activity can be from occupied dwellings, streams, water wells, etc. According to the law,  “The center of well pads may not be located within six hundred twenty-five feet of an occupied dwelling structure.” There are several issues with the way this law is worded, but the main problem is that the distance restriction is on the center of the well pad, not the boundary. Therefore, the edge of an active industrial site could quite easily overreach the already limited buffer zone.
The proximity of houses and farms to industrial activity is an issue across the entire Marcellus Shale play. Here in SW Pennsylvania, several homes are immediately downhill of a large pad and the service road for two well pads goes through the bottom center of the image.
Photo: David Manthos, SkyTruth; Facilitated by LightHawk
In Wetzel County, WV, Stone Energy’s Weekly pad (orange tanks in the center of the image) is surrounded by private homes. The green structures on the pad are separators and condensate tanks which remove and store ethane, butane, propane, and other gas “liquids” from the natural gas produced by the well. These units run constantly and at times emit sickening fumes that cause headaches and respiratory irritation.
Photo: David Manthos, SkyTruth; Facilitated by LightHawk

Conclusion:

There are many more observations to make about hydraulic fracturing and unconventional shale gas development, and many more ways we want to look at it from the sky. These are just the most obvious issues illustrated by this round of images. Even developed as responsibly as possible, it is undeniable that unconventional shale gas extraction will change the landscape of West Virginia for decades to come.
Stone Energy’s Howell Pad: 16 acres of surface disturbance.
Photo: David Manthos, SkyTruth; Facilitated by LightHawk
 
Oh, the West Virginia hills! How unchang'd they seem to stand,
With their summits pointed skyward To the Great Almighty's Land! 
Many changes I can see, Which my heart with sadness fills; 
But no changes can be noticed In those West Virginia hills
 
-WV State Song: The West Virginia Hills (circa 1885)