Saturday, March 27, 2010

House Bill 2235 - Moratorium for Leasing State Forest Land

Personally - I consider the mineral and gas rights owned by the State via State Forest and other land the same as a Royality Owner. A royality owner has the right to lease or not to lease property. I am a little concern about the 5 year time line and it was not clear in the regulations what is going to be done to fund this evaluation. To be honest, the State Forest and other leasing programs are significantly better than the Oil and Gas Law and permitting process used by the State. These programs have better provisions for control, siting, and bonding.

The primary weakness in the HB 2235 is that is does not appear to provide funding for the assessment and the assesment does not look at critical management options. These options, provisions, or considerations would include evaluating the leasing process to develop a lease that protects the environment and the states assests, feasibility analysis to determine if it may be better to allow the State to directly hirer a contractor to develop the Gas Resource rather than leasing out the resource ((This way that State in the gas business - why should we give away 80 % of this value),  PA should maintain ownership and control of the pore space and does not address issues related to how monies for leasing could be allocated and utilized to benefit the community.

Funds from leasing should be used in ways that helps us to get off fossil fuels - even the best estimates are there are only 100 years of gas available.  The money should not go to pay current salaries, but used to fund environmental education, alternative energy projects (such as grants to citizens to improve efficiency,  install solar, wind, or ground source systems - i.e., decrease energy demand and consumption and install systems at the point of us), sustainable infrastructure, improve water and wastewater treatment plants, purchase forested land for other drilling  (carbon capture) and other programs that create economic value and reduce energy and water consumption.

This bill only seems to cover conducting some type of environmental inventory, but provides nothing related to the interpretation of the data to make recommendations on areas that could be accessed via the vertical leg of the well.    Yes our forested lands are critical habitate, but we need to manage the resource.   Also - this assessment should include an easement of the geology for the area.   If the report only identifies the surface features, the recommendations may not make sense from a geological or energy stand point.

This bill only covers a portion of the work that is needed to evaluate the option to lease State Owned Land or not.  The HB should include an evaluation of Best Practices that should be utilizied in these areas. A partial listing of best practices may include the following:

a. Using partially degraded water or treated wastewater or stormwater for frac fluid and using recirculation systems;

b. Selecting Frac Chemicals that are as environmentally benign as possible and commercially available;

c. Prohibit the on-site disposal of cuttings and the use of lined ponds for storing water that had been used for fracking;

d. Require the implementation of a monitoring program that includes on-site monitoring wells and pre and post monitoring for streams, wetlands, and surfacewater;

e. Require a multiple casement approach that properly seals the unconsolidated and shallow consolidated aquifer and protects water with a TDS of < 10,000 mg/L;

f. The leasing process should not include provisions for deep well injection or carbon sequestration - these rights should be retained by PA (pore space should be owned by the state) and;

f. Require third party inspectors hirer by the State or the State should hire a gas company as a consultant and pay their fees, but PA maintain the full royality rights.
Just my thoughts


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