Proposed Policy on Unconventional Natural Gas
Natural Gas Fracturing Task Force: Proposed Policy Language
The Natural Gas Fracturing Task Force has revised the original proposed policy in responses to the many comments. These documents will be considered by the Board on its Dec. 21 call. You can find the original policy and background below.
[ revised proposed policy (doc) | report to board (doc) | compilation of comments (doc) ]
Unconventional gas is increasingly replacing domestic conventional gas resources in the United States.
Unconventional domestic gas supplies include coalbed methane as well as gases produced from ‘tight’ sandstones and gas shales. Gas from shales and tight sandstones (referred to collectively as “deep shale gas”) has potential to displace more destructive fuels when produced using rigorous best management practices. Deep shale gas is not an acceptable transitional fuel unless its production is governed by a rigorous and comprehensive regulatory structure, and is done according to best practices that minimize environmental damage.
At present, deep shale gas operations seldom follow such standards. Many states lack the treatment capacity to manage wastewater associated with the hydraulic fracturing (“frac’ing”) process and the permitting and enforcement staff to oversee production. Sierra Club cannot support development of deep shale gas without a rigorous regulatory structure in place.
All natural gas production, including deep shale gas, should be governed by a robust and effective regulatory structure; all gas should be produced using rigorous best management practices to limit environmental damage.
The Club opposes all coalbed methane extraction because it poses unacceptable risks to water quality in shallow aquifers. The following provisions apply to deep shale gas:
First, the Sierra Club opposes frac’ing projects if the identity and volume of frac’ing fluids are not fully disclosed to the public.
Second, the Club opposes any projects using frac’ing fluids that pose unacceptable toxic risks, including fluids which contain benzene, ethylbenzene, toluene, and xylene.
Third, the Club opposes any projects that do not properly treat, manage, and account for frac’ing fluids, drilling muds, and produced water. Frac’ing should not be permitted unless it can be demonstrated that drinking water acquifers and surface waters are adequately protected from contamination.
Fourth, the Club opposes frac’ing projects that would endanger water supplies or critical watersheds, that would seriously damage important wildland resources, significantly increase habitat fragmentation, that would imperil human health, or that would otherwise violate the Club’s land conservation policies.
Fifth, the Club opposes any frac’ing projects that would cause violations of air quality standards, individually or cumulatively.
Finally, as the industry matures, a series of best management practices will emerge, some already identified, some evolving with time. These best management practices should, to the maximum extent possible, be swiftly incorporated into regulatory requirements as they are developed. The Club opposes any unconventional or conventional drilling projects that do not comply with best management practices, even in regions where state or federal law may permit lower standards of environmental management.
The Club will use these standards as a yardstick for any regulatory reform efforts it undertakes or supports, and to judge which new drilling projects, if any, cause unacceptable environmental damage and warrant opposition.
Chapters are encouraged to press for effective regulatory frameworks to control the impacts of deep shale gas and may oppose specific projects that are inappropriately sited or that fail to comply with best management practices.
ORIGINAL PROPOSED POLICY & BACKGROUND
Request for Comments on Proposed Policy on Unconventional Natural Gas
[ proposed policy | proposed policy (doc) | background | comment board | task force |
natural gas fracturing task force report to board — EXECUTIVE SUMMARY (doc) ]
The Natural Gas Fracturing Task Force is requesting comments from Sierra Club members on the proposed policy regarding Unconventional Natural Gas. Comment period ends October 30, 2009.
Unconventional domestic gas supplies include coalbed methane as well as gases produced from ‘tight’ sandstones and gas shales. Unconventional gas is increasingly replacing domestic conventional gas resources. The Club opposes all coalbed methane extraction. Gas from shales and tight sandstones (referred to collectively as “deep shale gas”) is an acceptable transitional fuel if produced using best practices to limit environmental damage.
There are a series of best management practices, some already identified, some evolving with time. The Club opposes any unconventional or conventional drilling projects that do not comply with best management practices, even in states where state law may permit lower standards of environmental management.
The Sierra Club opposes hydro-frac’ing projects if the identity and volume of frac’ing fluids are not fully disclosed to the public. The Club also opposes any projects with unsafe frac’ing fluids or frac’ing fluid management plans which do not properly manage, and account for, ALL of those fluids.
The Club squarely opposes frac’ing projects that would endanger water supplies or that would seriously damage important wildland resources. Production water coming out of gas wells, conventional or unconventional, should be recycled with filtration and reused to the extent feasible, and the residual wastewater should be disposed of in an appropriate and licensed facility. Because frac’ing fluids may be toxic, meticulous surface management of well pads, waste pits, and other sites is essential to avoid release of these compounds into the ambient environment.
Chapters may oppose specific projects that are inappropriately sited or that fail to comply with best management practices.
The Sierra Club's Energy Resources Policy and energy road map recognize natural gas, appropriately sited and regulated, as a "transitional fuel." The Club has determined that over the next 20-30 years, while the transformation of the energy economy to high performance, low carbon renewables and efficiency is underway, there will be continued reliance on fossil fuels, and with the lowest carbon content among the fossil fuels, natural gas is to be preferred.
However, the Club's current policies presume that in the U.S., natural gas either comes from existing natural gas fields (which we support), or from wilderness, coastal or other so-called "frontier" public land areas, which we have opposed. The Club's current policies do not consider how new, unconventional natural gas production technology, primarily horizontal drilling and fracturing, fits into this picture. Siting is not a sufficient measure of the environmental effects of these projects.
In the summer of 2008, the Board approved a call for additional policy addressing unconventional gas production. The Executive Committee was tasked with appointing and charging a task force to develop a new policy recommendation. The Executive Committee named the Natural Gas Fracturing Task Force consisting of: Lane Boldman, (Chair), Thomas Au, Len Griffiths, Kirby Hughes, Kate Johnson, Athan Manuel, Rusty Middleton, Craig Segall, and Joanne Spalding.
The task force was given the following charge:
- Brief itself on the environmental issues involved in unconventional natural gas development, particularly horizontal drilling and hydraulic fracturing. Identify best practices and appropriate regulatory requirements. Make recommendations on the Club's priorities to ensure that appropriate regulatory requirements are put in place.
- Assess whether or not the existence of these new technologies so fundamentally alters the natural gas supply situation in the US that the Club should reconsider the overall role of natural gas in our Roadmap to reduce CO2 emissions by 80% by 2050. Is considering gas a transition fuel still the appropriate view, or should gas have a larger or smaller role in the transition to a low carbon economy?
- If the Task Force feels that the role should be smaller, it should indicate how confident it is that a smaller role for gas does not in the real world yield a larger role for oil and coal.
- Finally, the Task Force should recommend a set of geographic parameters to guide the Club. In what kinds of locations is unconventional natural gas development, properly regulated, appropriate? What kinds of areas should be viewed as off limits to such development, even with good regulation?
The Task Force researched the issue, deliberated and submitted a report and draft policy recommendation to the Board at the May, 2009 meeting. The Board approved the draft proposed policy in principle, and instructed Lane Boldman, Carl Pope and Robin Mann to finalize the draft policy language to post for Club-wide comment. The Board also instructed that the Task Force reorganize the background report to facilitate the review and comment on the draft policy language.
The Task Force prepared the this Executive Summary (doc) and revised
Natural Gas Fracturing Task Force Report, which summarize the issues and provide a basis for the proposed policy.
Comments are sought from all Sierra Club members, volunteers and staff alike, on proposed policy language. To comment, please go to the comment board.
[Note: Please provide citations for any factual information provided in your comments]