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From: James Northrup <northrup49@gmail.com>
Date: Tue, Jul 10, 2012 at 6:45 PM
Subject: [NYGCG] Comparison of State Shale Gas Regulations
To: NYGCG <nygcg---new-york-gas-coordination-group@googlegroups.com>
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From: James Northrup <northrup49@gmail.com>
Date: Tue, Jul 10, 2012 at 6:45 PM
Subject: [NYGCG] Comparison of State Shale Gas Regulations
To: NYGCG <nygcg---new-york-gas-coordination-group@googlegroups.com>
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.
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% +
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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May you, and all beings
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