Prof. Ingraffea’s 9-Point Letter from the Marcellus Shale Industry
If the Marcellus gas industry did everything it should to make sure natural
gas development is "done right," that still would not be good enough for
Cornell Professor Dr. Anthony Ingraffea.
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The Letter I Wish Had Been Written
July 1, 2007
To: The Citizens of States Over the Marcellus
From: The Natural Gas Industry
We are writing to ask your permission to develop shale gas in your states
using high-volume, slickwater, hydraulic fracturing from long horizontal
well legs (HVSHF).
Although you have allowed us to produce oil and gas from thousands of wells
over many years, we recognize that we are now asking you to allow us to do
much more intense development than ever before, using a technology never
before used in your area. We acknowledge our development plan for your
states might eventually involve over 400,000 Marcellus wells alone, with
thousands more in other shales, and be valued in the trillions of dollars, over
decades to come.
We have seen how such intense development with this technology has caused
problems where we are using it already in gas shales. We have listened
closely to your concerns about these problems, and others on the horizon, so we
are writing you now to make a compact with you. We understand that you are
granting us a privilege, that, collectively, all of you have to give us the
right to develop your gas, because, quite honestly, our plans will
significantly affect all of you, not just landowners with whom we might have a
business relationship.
Therefore, if you give us the permission we seek, here are our promises to
you:
1. Since we will not be developing in your area for another 2-3 years, we
have time to help you prepare for our arrival:
* We will immediately fund appropriate training programs in your
community colleges to produce homegrown workers for our industry. We will
subsidize tuition for the students who commit to work in our industry. Those
workers will get right-of-first-refusal on our job openings.
* We will immediately fund appropriate training programs for your
emergency response teams--fire, police, medical, and spill hazards--and we
will equip them at our expense.
* We recognize that our heavy equipment will damage many of your
roads and bridges. We will start now to pay to upgrade these so that they all
remain usable not just by our equipment, but by you, too, throughout the
development process. This will be a "stimulus" to help your unemployment
situation now. When development is complete in an area, we will pay for final
repairs necessary to leave all impacted roads and bridges in state-of-the-art
condition. This will be a legacy gift to you from our industry.
* We will fund the construction or upgrading of regional industrial
waste treatment and disposal facilities with adequate capacity to process
safely all of the solid and liquid wastes we produce. We will not truck your
wastes to other states.
2. We will be transparent about our entire plan for development:
* We will tell you as soon as practicable, but no later than 1 year
before start of activity, where and when we will drill, and what pipelines
and compressor stations will be needed where and by when.
* We will publish gas and waste production figures from every well,
accurately, and on-time.
* We will tell you where your gas is going to market. We will not
sell your gas to a foreign market.
* We will disclose, completely, all chemicals and other substances we
use.
3. We will accept, without debate, all new regulations that might be
proposed by your regulatory agencies: your existing regulations are inadequate to
cover the new technologies and cumulative impact of HVSHF. We will offer
your agencies suggestions for continuous evolution of the regulations as a
result of lessons we are learning.
4. With respect to your natural environment legacy:
* For every tree we uproot, we will plant at least 1 replacement. We
will reforest all access roads as quickly as we can, and minimize the width
of all forest cuts.
* We will pay a fair price for the water we extract from your lakes
and rivers, which will average several million gallons per gas well.
* Whatever we break, despoil, or pollute, we will repair, replace, or
remediate, at our expense.
5. We will safely dispose of all liquid and solid wastes from our
development:
* We will never store any flowback fluids or produced water in open
pits. All such fluids will be recycled to the highest extent possible by
existing technologies, regardless of increase in cost to us.
* All liquid and solid wastes remaining from recycling will be
treated at the above-mentioned industrial waste treatment plants. We will provide
radiation monitoring equipment on every well pad: any materials, including
drill cuttings, leaving a well pad that trigger an alarm will be sent to a
licensed radioactive waste disposal facility.
6. We will not cause an increase in any tax levy on your citizens.
* We will agree to a substantial increase in permit fees to reflect
the expected 4-fold increase in person-time we expect you to spend on review
of permits for HVSHF.
* We will agree to a state severance tax, the level of which will be
floating, according to an accurate accounting of all costs to the state and
municipalities.
7. We will practice what we preach about clean fuels and emissions:
* Every truck, every generator, every pump, every compressor will run
on natural gas--no diesel, no gasoline engines.
* We will not allow uncaptured gaseous emissions from any of our
processes: no evaporation from open pits, no pressure releases from compressor
stations or condensate tanks.
8. We will be sensitive to noise and light pollution, even if a community
does not have zoning restrictions in place to regulate such:
* All of our pads and compressor stations will have sound/light
suppression measures in place before startup.
* Site drill pads, compressor stations, and pipelines in
collaboration with the community.
9. We will not unduly stress any of your communities:
* We will never experiment with drilling many wells in a small area
over a brief period of time.
* We will abide by all area and time restrictions on permitting.
* We will never contest loss of well water use by any citizen. If a
well is lost, we will replace it with whatever type of supply is requested
by its owner at our expense.
* We will never require a citizen harmed by our development to
promise silence in return for remediation.
* Finally, and humbly, we note that even our best plans and efforts
will come up short, sometime, someplace, somehow. Therefore, in addition to
all the contributions noted above, we also pledge to establish an escrow
account which will receive 1% of the value of all gas produced from shale gas
wells using HVSHF each year. This account will be administered by an
independent 3rd party, advised by an independent panel you select, and will be
used as an emergency fund to compensate those financially or physically
harmed by our development in your state.
Thank you for your attention to our request.
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The Letter I Hope Will Be Written
July 1, 2011
To: The Natural Gas Industry
From: The Citizens of States Over the Marcellus
We have observed, calculated, thought, done the science, and we have
concluded that even “doing it right” is wrong.
No thanks.
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Presented at the 2010 Rachel Carson Legacy Conference in Pittsburgh, PA on
September 24, 2010
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