Last week the Pennsylvania Environmental Council (PEC) and Environmental Defense Fund (EDF) submitted joint comments [PDF] in support of draft technical guidance [PDF] by the Department of Environmental Protection (DEP). The guidance concerns what’s commonly referred to as “Area of Review” – where operators, before they start drilling or hydraulically fracturing a well, identify subsurface features to protect against migration of fluids, chemicals, or methane. The most common threats are abandoned wells and geologic faults.
Area of Review has been a priority issue for PEC since before passage of Act 13 in 2012, going all the way back to our first report [PDF] on unconventional well development in 2010.
This preventative measure is extremely important in Pennsylvania. Our state has hundreds of thousands of abandoned wells, many of which are unidentified and not marked on any map. Operators already perform pre-drilling analysis to optimize well production. Conducting preventative review at the same time helps prevent communication with existing conduits that could bring gas or fluids to groundwater aquifers or the surface.
Area of Review is recognized as a leading practice by collaborative efforts including the State Review of Oil and Natural Gas Environmental Regulations (STRONGER) and the Center for Responsible Shale Development (CRSD). Other states have already successfully implemented Area of Review rules or regulatory programs; it is essential that Pennsylvania follow suit, particularly given the prevalence of abandoned wells across the Commonwealth.
DEP’s draft guidance was developed in consultation with industry and environmental interests, and will help guide new regulations finalized in October of this year. The guidance should become final in 2017.