Wednesday, July 11, 2012

Fwd: [NYGCG] Comparison of State Shale Gas Regulations

---------- Forwarded message ----------
From: James Northrup <>
Date: Tue, Jul 10, 2012 at 6:45 PM
Subject: [NYGCG] Comparison of State Shale Gas Regulations
To: NYGCG <>

Fairly comprehensive review of state shale gas regulations. 

IMO, they left off the key indicator - compulsory integration

Since CI indicates how the state minerals management agency relates to the citizenry (not the wells) 

And New York's CI is the worst - as applied by the DEC - in the US 

They address waste water containment (on site) and tracking, but not whether there was any requirement to dispose of the wastewater

In New York, though injection wells are allowed, and a few have been permitted, they are not a viable solution, given the seismic issues

So New York has literally no place to dispose of one gallon of fracking flowback. 

Kind of a problem. 

Underground Injection Wells for Flowback and Produced Water

The state's ability to regulate oil and gas regulations is a function of enforcement 

Which is New York is not good, because New York has no state severance tax to pay for enforcement

Pa. just adopted a state production fee - no shale in Vermont, Connecticut, etc. so irrelevant.

Not shown is Alaska = 15% + 

Severance Taxes

Note that New York's gas well setback from a house (100 feet) is the least of any state 

And in other states, municipalities or county establish setbacks more restrictive than the state setback

None of these local setbacks are as low as New York's - the typical municipal setback in Texas would be 1,000 feet

If a gas well is too close to a house or water well - all the other regulations are pretty much useless

New York combines well permitting with environmental regulations into one agency -  the DEC

This guarantees that the integrity of the environmental function will be comprised - and Chesapeake will write the regs. 

Most states have at least two regulatory agencies - a well permitting agency and a separate environmental agency

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