Today, the Department of Energy’s Shale Gas Subcommittee issued a draft of its second of two ninety-day reports [PDF] on steps that can be taken to reduce the environmental impact of shale gas production. The first report made twenty recommendations on needed improvements. This second report prioritizes those recommendations, and makes suggestions on how each might be implemented. The subcommittee continued to stress the need for “collaborative efforts” and “continuous improvement” by companies involved in shale gas production (including service companies), and focused again on the need for public involvement and transparency. While sanguine about the potential of “arguably the country’s most important domestic energy resource,” the subcommittee noted that “the progress to date is less than the Subcommittee hoped and it is not clear how to catalyze action at a time when everyone’s attention is focused on economic issues, the press of daily business, and an upcoming election.”
Several of the notable recommendations include:
- Additional federal funding for two non-profit organizations—the State Review of Oil and Natural Gas Environmental Regulations (STRONGER) and the Ground Water Protection Council (GWPC), to include grants to states that volunteer to have their regulations and practices reviewed by STRONGER (for a recent example, see STRONGER’s review of Colorado’s regulations [PDF]).
- Finalization of EPA’s proposed New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants (NSPS/NESHAPs) for the oil and gas sector. The subcommittee noted its disappointment in the proposed rule’s failure to “directly” control methane emissions.
- Implementation by the Department of Interior of a full disclosure policy for all chemicals, not just those that would appear on a Material Safety Data Sheet (MSDS). This recommendation states “the bar for trade secret protection should be high.”
- Taking background water measurements at wells surrounding production sites to establish a pre-drilling/fracking baseline.
- Encouraging state and local governments to take the lead in developing cumulative and community models to address all impacts (wildlife, noise, traffic, dust, water etc.).
- Imploring industry to make a more visible commitment (including a stakeholder process) to developing quantitative best practice metrics for the entire range of shale gas operations (well design and siting, completion casing and cementing, fracking, surface operations, well abandonment and sealing etc.).
Regarding water quality issues, the Subcommittee noted that the recently announced ELG rulemaking, and the broader EPA water-life-cycle study will not be completed for several years, during which time “a tremendous amount of activity” will occur in the field. The subcommittee “urge[d] EPA to take action as appropriate during the course of [these processes].” It is unclear what this means, but could be interpreted as a recommendation for EPA to focus interim enforcement efforts on water issues.
Taken together, the DOE reports highlight for the industry the critical importance of transparency, stakeholder involvement, and public awareness. It is becoming increasingly clear that the successful development of this major domestic resource will hinge as much on credible public relations as it will on technological advancements and economic forces. As the Subcommittee concludes “some concerted and sustained action is needed to avoid excessive environmental impacts . . . and the consequent risk of public opposition to its continuation and expansion.”