George Jugovic, Jr. Chief Counsel, PennFuture

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22 Φεβ 2014 (πριν από 3 χρόνια και 3 μήνες)

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George Jugovic, Jr.

Chief Counsel,
PennFuture


Air Quality


Shallow Groundwater


Special Protection Watersheds


Public Lands


Transparency


Data Collection

Flaring



Study by Ceres group of investors using
figures from North Dakota Industrial
Commission indicates that 29% of gas
produced in May 2013 was flared, down
from high of 36% in September 2011. In
2012 equivalent of 1 billion gas burned
and GHG emissions of putting 1 million
cars on the road


NOx

Emissions


1 hour NAAQS
-

100 ppb short term
exposure to avoid adverse health effects
(Jan 2010)


Evidence of degraded air quality in other
gas fields across the country


DEP SWRO has permitted equivalent of two
coal fired power plants in the past eight
years


Lack of modeling because considered
minor source


Lack of monitoring in most active areas






Fracking



NETL study preliminary results being
evaluated


Single well in one geologic location


Pennsylvania geology variable across the
shale play


More studies needed to assure public


Pipeline Crossings



High Quality and Exceptional Value
streams


2 Million persons fish annually; 1.6 Billion
pumped into economy yearly (PAFBC)


Renewable resource


Anti
-
degredation

policy


Cumulative impacts

Methane Leakage



Estimated 300,000 abandoned wells


Complex geology complicated by
underground coal mines, abandoned
wells, and shallow gas


Lack of construction standards for
drinking water wells

On
-
site Disposal Practices



RCRA exemption for oil and gas wastes


PA Residual waste


No permit required for disposal


DEP authorized on
-
site disposal; 200 feet
from stream; 20 inches above
groundwater; remove liquid; wrap in
liner; no long
-
term monitoring


1895


Dr. Joseph
Rothrock

became the
first commissioner


1897


General Assembly passed law
authorizing the purchase of “unseated
lands for forest reservations”


1930s


Department of Forest and Waters
began purchasing what would become
the
Loyalsock

State Forest from
Pennsylvania Lumber Company





60% forested


Pennsylvania
state forests one of largest in
east
-

2.1
million acres.


About 2/3 or 1.5
million
sits
on the
Marcellus
shale


The state owns about 70% of mineral rights
beneath state forests; only 30% state parks


385,400 acres of state forest land has been
leased for drilling; DCNR informal policy
seeks to prevent drilling in State Parks



2010 DCNR Park Study


33.6 million people visited State Parks;
spent $738 million direct payments


$463 million sales


8,439 jobs


2006 Outdoor Wildlife Survey


87.5 million hunted, fished or recreated


$122.3 billion dollars



Forest fragmentation



Erosion and sedimentation



Loss of habitat




Case 1:
Loyalsock

State Forest


114,494 acres


Clarence Moore tracts consists of 25,000
that contains some of the most
ecologically sensitive areas in PA


Clarence Moore purchased the mineral
rights from Pennsylvania Lumber
Company


Anadarko
Petroleum own the rights






DCNR asserts it must allow access because
of implied right of easement


Conservationists assert an unusual
l
ease
provision terminated surface access on
18,000 acres


The remaining 7,000 not accessible without
an easement


DCNR budget already accounted for the
amount of money that Anadarko offered to
resolve surface access dispute


Anadarko submitted development plan in
March 2012


Still has not been released to public

for
comment


DCNR refused to hold any public hearings
for over one year


April 2013, DCNR offered a meeting to
hand
-
selected groups and individuals


May 22, 2013, DCNR finally agreed to an
open public meeting, held on June 4


No public planning process


No comprehensive environmental impact
statement (mini
-
NEPA)


No obligation to hold public hearings


No plain right to administrative hearing
from DCNR actions



Case 2: waste management records


Act 13 requires maintenance of detailed
records for waste management


No obligation to submit records to DEP
unless requested


Public has no access under RTKL unless
submitted to agency


Serious lack of data on important issues
affecting the environment


Public policy decisions should be based on
scientific facts


No long
-
term air monitoring plan in areas
with most drilling


No comprehensive shallow aquifer data


No reporting of methane releases


No data on
frack

fluid migration


NETL study on
frack

fluid migration


PSU study on forest fragmentation