My Comment Regarding Project #2014-081
submitted to the SRBC August 6, 2015
Chief Oil and Gas Forksville 2M/gpd
Water Withdrawal Application
According to the Susquehanna River Basin Commission (SRBC), their
decision will be based on 1) the impact to the Loyalsock Creek, and 2) the
needs of the applicant.
I am not an aquatic specialist, so I will not comment directly on water
quality or aquatic life issues; however I will address the alleged “needs” of
Chief Oil and Gas for the taking of this water – our water.
In Pennsylvania, Chief Oil and Gas has acquired 468 drilling permits
and has to date, drilled 281 unconventional gas wells, 81 of which have been
found in violation, and have accumulated 292 statewide violations, according to
the PA/DEP.
*Sources: PA/DEP, Marcellusgas.org, the Sullivan, Bradford, Lycoming County Prothonatary Offices, and FracFocus)
Of these 281 drilled wells, water consumption has ranged from 2 million
to 9 million gallons of fresh water, averaging out to be approximately 5.5
million gallons of fresh water ‘consumed’ by each well.
Chief Oil and Gas, like many other unconventional shale drilling
operators, boasts about their “recycling of produced water” (as much as 80%)
now used to drill new wells.
Over the years, Chief’s operations have been diminishing for various
reasons: supply v. demand, low natural gas prices, and the lack of pipeline
infrastructure needed to move Marcellus gas to markets – many of which are
overseas markets.
Many of Chief’s earlier lease acquisitions have either expired, or been
sold-off to other operators, most notably EXCO
Resources.
Currently, in Sullivan, Bradford, and Lycoming Counties – the counties
where Chief claims they need this water to develop their outstanding units,
Chief presently has 105 outstanding permits for new wells.
Therefore, when you multiply the number of outstanding well permits by
5.5 million gallons (Chief’s average water consumption p/well) that indicates a
“need” for 577,500,000 gallons of water.
However, when you multiply the proposed 2 million/gpd, that Chief is
looking to extract from this watershed over a five year period, that totals
3,650,000,000 gallons of water.
That’s a difference of 3,072,500,000 gallons of water in excess of
their current “needs”, and if the SRBC takes into account Chief’s intent on
recycling, the discrepancy between their application request and their actual
“need” is staggering and does not justify 2 million/gpd requested on this
application.
That is, unless Chief is planning on “commodifying” this excess water –
our water, which they would not be paying for, and selling it to other
operators. (EXCO Resources, Anadarko Petroleum, and Southwestern Energy are
three operators that immediately come to mind.)
*Chief claims that they have not discussed the possibility of selling
water from the Loyalsock, however they have stopped short from ruling it out,
or denying the possibility.
Chief Oil and Gas needs to be transparent and forthright with their
intentions for the “taking” of our water, and if their actual and verifiable
“need” does not require this extreme volume of water, then it is the SRBC’s
responsibility and duty to deny this application and not issue this permit.
I would also
like to suggest that for all future water withdrawal applications, the SRBC
require all applicants to agree not to sell and/or "commodify" this life-sustaining
resource or allow it to be included as part of the sale, or selling off, of corporations
assets.
I hereby
would like to remind the SRBC that this resource is owned by the people of the
Commonwealth of Pennsylvania, and must be protected and preserved, as clearly
stated in the Pennsylvania Constitution – which the SRBC as a “trustee”
of these resources is bound to uphold.
Article 1, Section 27 of the Pennsylvania
Constitution:
"The
people have a right to clean air, pure water, and to the preservation of the
natural, scenic, historic, and esthetic values of the environment.
Pennsylvania's public natural resources are the common property of all of the
people, including generations yet to come. As trustee of these resources, the
Commonwealth shall conserve and maintain them for the benefit of all the
people."
John A. Trallo,
Sr.
Sonestown, PA 17758
Chief Oil and Gas Forksville 2M/gpd
Water Withdrawal Application
Project
#2014-081
Permits Wells Drilled Wells to be Determined Sites
Sullivan County (All) 87 50 20 39
Bradford County 160 92 68 59
Lycoming County 23 6 17 7
Totals: 270 148 105 105
Sullivan County Townships
Cherry 24 20
7
Colley 0 0 0
Davidson 0 0
0
Elkland 40 21
15
Forks 6 3 5
Forksville 7 2 6
Fox 21 24 6
Hillsgrove 0 0 0
Laporte 0 0
0
Shrewsbury 0 0 0
·
Average water
consumed for each well = 5,500,000
gallons
·
Estimated water
needed to drill 105 proposed wells = 557,500,000 gallons
·
Potential 5 year
withdrawal @2M/gpd = 3,650,000,000 gallons
·
That’s
3,072,500,000 excess gallons than is needed for all of Chief's operations in Sullivan,
Bradford, and Lycoming Counties.
Chief O&G PA statistics to date:
·
468 well permits issued
·
281 wells drilled
·
81 wells with violations
·
2010 inspections revealed 292
statewide violations.
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