The debate began on May 10th , when the RDA newsletter focused on the topic of abandoned, orphan and unplugged or improperly plugged gas wells.
RDA published Mr. Henderson's response to that newsletter on May 13th.
We now offer further comment from three among our members and friends. Thank you to Laurie Barr, Deron Gabriel and Vic Ciuccio for your remarks.
Dear RDA,
Thank you for helping to raise awareness and for writing about the lost, abandoned and unplugged wells in your newsletter.
We appreciate Mr. Henderson's response to the newsletter and the issues surrounding the lost and abandoned wells.
Many health, safety, environmental, and economic risks are associated with these wells and these are risks Pennsylvanians are being asked to accept.
These issues have garnered much less attention than we believe they deserve.
In Mr. Henderson's response to the newsletter he brought up details of regulations that have allowed these risks. Risks that are very real, but are treated as inconsequential.
Mr. Henderson wrote: "There is no current requirement that an operator must plug specific wells for which they have no legal or other responsibility for; that is, they did not drill, have ownership or lease of, participate in the construction of or derive any economic benefit from these particular wells."
Mr Henderson is correct, but that is one of the problems. Because there is no requirement to plug nearby/unplugged wells, when new drilling occurs nearby, these unplugged wells are at an increased risk of allowing methane, radon and fluids to migrate between formations, nearby aquifers and the surface.
Read :
http://www.portal.state.pa.us/portal/server.pt/community/newsroom/14287?id=8901&typeid=1
The DEP is responsible to pay the costs to plug approximately 8, 600 wells, currently on their abandoned well list.
Tens of thousands of wells are lost and if/when they are found, a large number may be eligible to be added to the DEP's abandoned well list.
Mr. Henderson is right about the money collected through surcharges and permit fees but these fees are provably inadequate based upon many sources, including the DEP's own records and the study published by Carnegie Mellon University.
If this is how the DEP plans to plug the lost and abandoned wells, they are going to be plugging wells into the next millennium.
Mr Henderson wrote: "The focus on the bonding amounts in the article too easily simplifies the issue, presenting the issue as if the amounts of the bonds are the maximum financial exposure of a company to plug a well."
It is simple. The disparity between the required bond and actual cost to plug leaves Pennsylvania exposed to a significant financial hazard. Act 13 does not prevent an entity/ operator from going bankrupt. Just one of Pennsylvania's problematic wells cost 3 million dollars to plug according to a Warren DEP official.
This is not rocket science.
One solution may be to hold these operators accountable by requiring operators to put funds equal to the estimated cost to plug their wells into an escrow account. This would not eliminate the financial risk but would minimize the risk.
These well bores are permanent holes in need of plugging and re-plugging; maintenance will be required for the life of the planet and we are kicking the can down the road leaving the unplugged wells as our legacy for future generations to deal with.
From Deron Gabriel, South Fayette Township Supervisor
It is a joke for Mr. Henderson to argue that $50 or $100 fees towards plugging wells is sufficient when it costs many thousands of dollars to properly plug each leaking, abandoned shallow well.
From Vic Ciuccio, Williamsport native now retired in Maryland
Someone has thin skin. I would jump on his statement that, " I am hard pressed to think of another business which is required to pay the costs of another's responsibilities."
I would draw a direct parallel to the health care industry. Each health insured person PAYS FOR the cost of another's uninsured illnesses and injuries.
From RDA
As shale-gas well drilling permits in Pennsylvania top the 10,000 mark, legislative protection that insures the public our gas production will be second to none is not yet complete, far from it.
