After Review Wayne National Forest OK’s Shale Development
Last year the Wayne National Forest (WNF) found itself at the center of the ongoing debate over Utica Shale development. This occurred as leasing proposals were being offered and objections from environmental groups compelled the forest to review their 2006 Forest Plan before moving forward. Following that review, now officials have declared development can proceed in WNF without any additional regulations or changes to the Forest’s plan due to the safety of these operations and the strong regulations in place in Ohio.
As a result of these objections, in November WNF removed their minerals from being leased. At the time, WNF Supervisor Anne Carey stated “Based on new information and increased public interest on natural gas exploration, especially deep horizontal drilling, the Forest will soon assemble a team of natural resource specialists to do further analysis.”
When this news was released last year Energy In Depth Ohio examined the decision and found many issues worth addressing.
Since the original announcement, and our response, WNF performed a Review of New Information (RONI) which assisted officials in determining whether the 2006 Forest Plan needed to be amended or revised to support Utica Shale development. In a letter dated May 3, 2012, the BLM documented that they reviewed and the determined that 13 horizontal well sites (10 on the Marietta Unit and 3 on the Athens Unit) could occur on the WNF for the remainder of the first 10 years (2006-2016) of Forest Plan implementation.
On Monday, Wayne National Forest Supervisor Anne Carey signed a Finding for the Supplemental Information Report which determined there is no need to correct or amend the 2006 Land and Resource Management Plan to address the surface impacts of horizontal development in Wayne National Forrest as well as no need to supplement the Environmental Impact Statement that was prepared for the 2006 Land and Resource Management Plan.
“I have reviewed the new information contained in the Supplemental Information Report, and determined that further environmental analysis is not needed,” said Carey. “I believe that the existing Forest Plan direction is adequate to address the surface effects anticipated from the potential development of horizontal wells as projected by the Bureau of Land Management (BLM).”-Wayne National Forest Supervisor Anne Carey
In addition to the statement, WNF also released their Executive Summary for the “Supplemental Information Report Horizontal Drilling Using High Volume Hydraulic Fracturing” which made some key findings on some hot topics regarding shale development in Ohio and across the United States.
Casing and Regulations in Ohio:
- Cementing and casing of the well is regulated by the BLM through the Onshore Oil and Gas Order Number 2, and by Division of Oil and Gas Resources Management (DOGRM) through the Ohio Revised Code. When state regulations are more strict than federal regulations, the BLM defers to the state. In Ohio, the BLM defers to the DOGRM in many scenarios for the regulation of casing and cementing. (p. 4, Executive Summary, emphasis added)
- Ohio has extensive oil and gas laws, rules and regulations which are administered by the Ohio Department of Natural Resources Oil and Gas Program. (p. 4, Executive Summary)
Hydraulic Fracturing and Fluid Migration
- The migration of fluids from the hydraulically fractured zone upward into zones containing potential drinking water sources is considered to be low-risk because of the presence of a thick sequence of low permeability layers between the fractured zone and potable groundwater zones. Contamination of groundwater has never been definitively linked to migration from the hydraulically fractured zone outside the borehole at any of the tens of thousands of sites in Ohio that have undergone either low- or high-volume hydraulic fracturing. (p. 5, Executive Summary, emphasis added)
- It has been suggested that hydraulic fracturing could force hydraulic fracturing fluids or subsurface formation waters into permeable fault or fracture zones that connect the fractured zone with overlying underground sources of drinking water. However, no instance of this has been identified in Ohio. The potential for such pathways to exist allowing migration of fluids over the several thousand feet separating the Utica shale and the underground sources of drinking water is low, given that fault and fracture zones are frequently sealed by pressure and/or mineralized infilling materials; particularly with depth. (p. 5, Executive Summary, emphasis added)
Orphan Wells Acting As Conduit
- Orphan oil and gas wells that were drilled to or through the Marcellus or Utica could act as a conduit for the upward migration of hydraulic fracturing fluids if they are located within the fracturing zone of the proposed horizontal well. These types of wells are rare and are addressed by DOGRM during the permit application review process of a new Marcellus or Utica Shale application. (p. 5, Executive Summary, emphasis added)
- If a new application is in close proximity to an improperly plugged and abandoned or an improperly sealed production well that penetrates into or through the Marcellus or Utica proposed producing zone, then the operator of the new application will either need to propose a new location or re-open and replug the older oil and gas well. This prevents the potential for cross-communication during the hydraulic fracturing operations (Tomastik 2012a). (p. 5, Executive Summary)
- The incorporation of horizontal wells will reduce the number of development sites on the landscape when compared with vertical well development as described above, thus would be viewed as a beneficial impact with regards to fragmentation. (p. 10, Executive Summary)
- An Example Scenario: The development of thirteen horizontal well pads would correspond to roughly 71.5 acres of total site disturbance. Given that the total disturbance is constrained to 272 acres, the remaining acres of total disturbance would be 200.5 acres. Based on these remaining acres of development, approximately 172 vertical wells could be developed. This combination of horizontal and vertical well sites would thus reflect a reduction of approximately 62 (vertical) well sites, compared if all vertical wells were developed instead. A reduction in such a significant number of sites for oil and gas development would correspond to reduced fragmentation effects on the landscape, though the total affected area would be the same (272 acres). This scenario represents a reduction of 26 percent (number of sites). Also, a reduced number of sites would correspond with reduced noise and human disturbance, even though the duration of drilling several wells at a horizontal site would be longer. (p. 10, Executive Summary)
As the conversation continues, science and facts continue to come up on the side of oil and gas development. Even though Wayne National Forest was put under pressure by surrounding misinformed activists to put the screws to oil and gas development, they thoroughly reviewed the subject and determined that it would be viable to host Utica Shale development. Hopefully these results will resonate with those looking to have an honest debate on shale development.