Performance Standards of the Center for Sustainable Shale Development (CSSD)

“Voluntary Shale Standards”

“Voluntary Shale  Standards” for Marcellus Shale Development”

From the Article by Casey Junkins, Wheeling Intelligencer, April 14, 2013

Some environmental groups are concerned about the Center for Sustainable Shale Development. So are some industry groups. For Andrew Place, that means the center must be doing something right.

Place, interim director of the Pittsburgh-based Center for Sustainable Shale Development, said the center’s mission is to “support continuous improvement and innovative practices through performance standards” for drilling in the Marcellus and Utica shale formations. The organization formed last month.

To date, industry representatives are CONSOL, Chevron, EQT Corp. and Royal Dutch Shell. Chesapeake Energy and Range Resources are two companies that have not signed. He also noted a number of environmental groups – the Group Against Smog and Pollution, the Environmental Defense Fund and the Heinz Endowments – are signed on as partners.

Membership and Purpose

Place said the center’s work and standards would cover West Virginia, Ohio and Pennsylvania – areas with burgeoning drilling and fracking activity – as well as New York and other states that have placed a moratorium on fracking.

Chevron Corp., which has drilling operations in Marshall County and maintains some acreage in Ohio County, is one of the founding members of the center, as is CONSOL, which also has active drilling operations in Marshall County in collaboration with Noble Energy.

“The group’s standards will certainly make an impact in the areas where these founding companies are operating,” Place said. “I have a farm in southwestern Pennsylvania. Wearing my landowner hat, if I know that a company abides by these standards, I will think better of them.”

Other founding members of the center include the Heinz Endowments, GASP, the Environmental Defense Fund, the Center are the Clean Air Task Force, EQT Corp., Citizens for Pennsylvania’s Future, the Pennsylvania Environmental Council, Royal Dutch Shell, and the William Penn Foundation. The new standards established by the voluntary organization include: – limitations on the flaring of excess methane, which is identified by the U.S. Environmental Protection Agency as a potent greenhouse gas, and other hydrocarbons;  – reduced engine emissions from drilling rigs, compressor motors and trucks; – vapor controls on condensate tanks; – groundwater monitoring and protection; – improved well designs; – stricter wastewater disposal methods; – the use of less toxic fracking fluids; – the elimination of diesel fuel for fracking; – seismic monitoring before drilling begins.

Questions and Concerns

“We appreciate this diverse group’s support for our member companies’ development of natural gas and engaging in a process to embrace its clear environmental and public health benefits,” said Kathryn Klaber, chief executive officer of the coalition. She added her association’s members are “vigorously committed to compliance with this stringent framework.”

Environmental groups also have expressed concern over the center. According to the Associated Press, the Sierra Club opposes its work, and the group No Frack Ohio said the plan “simply puts green lipstick on a pig.”

Place said the center’s goals do not include seeking to change federal or state laws, noting he believes these performance standards are no substitute for regulation. “This was always seen as version 1.0,” he said. “We have weekly meetings now. Environmentalists and industry representatives are in the same room, thinking of how we can work together.”

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Comments from the Group Against Smog and Pollution on April 18^th:

When we decided to participate in CSSD, we knew we’d take some criticism from others who are concerned about fracking. However, if CSSD is successful, it will result in meaningful reductions in the impacts of shale gas development on communities, human health, and the environment. I think a lot of the skeptics will view CSSD more positively in a couple years when CSSD has achieved some tangible results.

One common misconception I’d like to address: while the standards are voluntary and are no substitute for regulations, some have taken the term “voluntary” to mean compliance with the standards is based entirely on the honor system. However, the CSSD certification process will include ongoing measures to ensure companies are meeting these performance standards (e.g., third-party inspections, recordkeeping and reporting requirements, etc.)

Also, these standards are a work in progress, they don’t address every negative impact posed by shale gas production, but additional standards will be added over time and existing standards will be updated to ensure they remain more rigorous than the status quo.

Some specifics regarding the CSSD standards:

Standards 5 and 6 require companies to conduct geological studies prior to drilling a well and meet ongoing water monitoring requirements. These are similar to underground injection control requirements of the Safe Drinking Water Act that would apply nationwide if not for the Halliburton Loophole.

Standard 10 is similar to a recent EPA rulemaking requiring green completions (as opposed to wasteful well completion flaring). However, the CSSD standard requires companies to meet this standard 1 year earlier than the federal regulation. During the federal rulemaking the American Petroleum Institute argued it would not be feasible for industry to meet the reduced emission completion standard by this deadline.

Standards 11, 12, and 15 will significantly reduce emissions from trucks, frack pumps, drill rigs, and stationary compressor engines.

Joe Osborne, Legal Director, Group Against Smog and Pollution
Office: 412.924.0604, Cell: 617.909.8365, www.gasp-pgh.org