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22 Groups Express Concerns With Pennsylvania’s Carbon Storage Plans, Capacity To Regulate Injection Wells
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On March 31, twenty-two Pennsylvania-based and national groups expressed serious concerns in a letter to the Department of Environmental Protection regarding their interest in assuming primary management, or primacy, over the EPA’s Class VI Program, which regulates wells used for longterm, underground storage of carbon dioxide in deep rock formations.

“This primacy effort is an accelerant to the burden shouldered by Pennsylvanians of a deficient permitting system that favors polluters over community health and safety. For the DEP to so casually pursue something of this scope without talking to the communities likely to deal with its impacts sets the wrong tone for Pennsylvania’s decarbonization strategy,” said Sarah Martik of Center for Coalfield Justice.

"Assuming primacy over the EPA's Class VI Program to fast-track the development of carbon capture and sequestration is a risk to communities and the climate. However, industry proponents positioned to capitalize on the proliferation of carbon capture and sequestration and the projects that depend on it are aggressively pursuing its development despite wide-ranging risks and diminishing returns,” said Sarah Carballo of FracTracker Alliance.

"Our regulators should not engage in ushering in the next generation of fossil fuel development. Blue hydrogen's feedstock is methane, a dangerous greenhouse gas. Carbon Capture and Storage is added to the production process to capture and sequester CO2 that is emitted, but is an unproven, dangerous process," said Karen Feridun, Co-founder of the Better Path Coalition. "If our regulators will not advocate in our best interest over the process as a whole, why should we give them primary authority over any part of it?"

"The DEP has struggled with staffing for years. The EPA and state should not add to DEP's burdens and overworked staff a major, new, untested program that has such serious consequences for residents of the Commonwealth," stated Matthew Mehalik, Executive Director of the Breathe Project. "We have seen major problems with DEP's permitting in other areas involving other classes of wells over the last decade because of DEP cutbacks. This rushed effort is misguided."

Industry groups, including the Pennsylvania Chamber of Business and Industry, have identified delays with permitting of Class VI wells by the EPA as a barrier to carbon capture and sequestration (CCS) development, including the development of fossil fuel-based blue hydrogen hubs, like Pennsylvania’s Decarbonization Network of Appalachia.

Primacy over the Class VI program has been suggested as a potential solution by CCS proponents.

However, the complexity of these projects pose serious concerns for Pennsylvanians, including:

-- The potential for an increase in the pace and volume of reviews, which could result in a reduction in the quality and thoroughness of permit reviews and limit the ability of the public to review and provide feedback to these projects;

-- Insufficient protections and considerations for environmental justice communities in the Class V program;

-- Gaps in technical expertise and lack of administrative capacity to regulate these complex projects due to underinvestment in the Department and the lack of familiarity with carbon dioxide pipelines, of which there are only about 5,000 miles in the U.S.;

-- Increased health and safety risks due to the unique potential for pipeline failures and corrosion when transporting carbon dioxide and accidental releases of CO2, as seen in Satartia, MS when a carbon dioxide pipeline ruptured, resulting in dozens of hospitalizations and hundreds of evacuations; and

-- Significant gaps in regulations regarding carbon dioxide pipelines.

North Dakota and Wyoming are the only states that have primacy over the Class VI program. However, seven states are in the process of applying for primacy — including Ohio and West Virginia, sponsors of the Appalachian Regional Clean Hydrogen Hub — and several others have expressed interest.

Ohio and West Virginia have primacy over the Class I, II, III, IV, and V programs in their respective states but the EPA remains the primary enforcement authority for the entire Underground Injection Control program in Pennsylvania.

Click Here for a copy of the letter.

Related Articles - Injection Wells:

-- DEP To Submit Letter Of Intent To EPA As Early As This Week For Primacy To Regulate Underground Injection Wells

-- PA Business Groups Urge EPA To Speed Up Approval Of State Primacy Applications For Injection Well Regulation

-- PA Environmental Council, Environmental Defense Fund Express Concerns About Legislation Requiring DEP To Apply For Injection Well Primary For Carbon Dioxide Storage

PA Oil & Gas Public Notice Dashboards:

-- Pennsylvania Oil & Gas Weekly Compliance Dashboard - March 25 to 31; More Violations At Equitrans Gas Storage Area; Spring Walk Yields Hissing Gas Well On State Game Lands  [PaEN] 

-- PA Oil & Gas Industrial Facilities: Permit Notices/Opportunities To Comment - April 1  [PaEN]

-- DEP Posts 55 Pages Of Permit-Related Notices In April 1 PA Bulletin  [PaEN]

PA Oil & Gas Compliance Reports

-- Feature: 60 Years Of Fracking, 20 Years Of Shale Gas: Pennsylvania’s Oil & Gas Industrial Infrastructure Is Hiding In Plain Sight [PaEN]

-- Conventional Oil & Gas Well Owners Failed To File Annual Production/Waste Generation Reports For 61,655 Wells; Attorney General Continues Investigation Of Road Dumping Wastewater  [PaEN]

-- DEP Issued 754 Notices Of Violation For Defective Oil & Gas Well Casing, Cementing, The Fundamental Protection Needed To Prevent Gas Migration, Groundwater & Air Contamination, Explosions  [PaEN]

-- DEP Report Finds: Conventional Oil & Gas Drillers Routinely Abandon Wells; Fail To Report How Millions Of Gallons Of Waste Is Disposed; And Non-Compliance Is An ‘Acceptable Norm’  [PaEN]

-- DEP 2021 Oil & Gas Program Annual Report Shows Conventional Oil & Gas Operators Received A Record 610 Notices Of Violation For Abandoning Wells Without Plugging Them  [PaEN]

-- PA Oil & Gas Industry Has Record Year: Cost, Criminal Convictions Up; $3.1 Million In Penalties Collected; Record Number Of Violations Issued; Major Compliance Issues Uncovered; Evidence Of Health Impacts Mounts  [PaEN]

NewsClips:

-- PJM This Week Sends Penalty Assessments Of Up To $2 Billion To Electric Generators That Failed To Perform During December’s Winter Storm Elliot; Natural Gas Power Plants Had 63% Of Outages  [PaEN]

-- Post-Gazette - Anya Litvak: As Shell Shuts Down New Beaver County Petrochemical Plant For Repairs, And Burns Off Natural Gas In Flares, Company Says It Hasn’t Exceeded Air Emission Limits

-- Shell Petrochemical Plant Beaver County: Bad And Dangerous Start; Shell Shut Down Part Of Plant For Repairs, Beings Full Natural Gas, Flammable Gases Flaring Operations For Unknown Period

-- Beaver County Times: Expect ‘Continuous’ Flaring- Burning Off Natural Gas, Flammable Gases At Shell Petrochemical Plant In Beaver County

-- BreatheProject.org /Reddit: March 31 Video Showing Shell Petrochemical Plant Still Flaring Natural Gas, Still Using Hose To Cool Barrel Tower Around Flare

-- AP: Probe Of Reading Chocolate Factory Explosion Centers On Natural Gas Pipeline

-- Guest Essay: Protect This Place - Fracking Threatens The Allegheny Plateau And Its Biodiversity - By Lisa C. Leib, Pittsburgh

-- Marcellus Drilling News/Argus Media: Wild Swings In Natural Gas Price ‘Here To Stay For Foreseeable Future’

-- Marcellus Drilling News: Consultant Suggests Drillers Fight Low Natural Gas Prices By Choking Wells 50% [To Reduce Supply]

-- Marcellus Drilling News: Acting DEP Secretary Disappoints By Spouting Enviro Justice Nonsense

Related Articles This Week:

-- PUC Denies Conventional Oil & Gas Industry Petition To Reconsider Regulation Of Class One Natural Gas Gathering Pipelines [PaEN]

-- 22 Groups Express Concerns With Pennsylvania’s Carbon Storage Plans, Capacity To Regulate Injection Wells  [PaEN]

-- Guest Essay: A Conservative Argument For Clean Energy -- Follow The Market, Fossil Fuels Are No Bargain - By Dave Jenkins,  Conservatives For Responsible Stewardship    [PaEN]

-- Washington & Jefferson College Hosts April 5 Webinar On Justice40 - Bringing Energy Transition Benefits To Disadvantaged Communities  [PaEN]

-- PUC Urges Consumers To Contact Utilities About Payment Of Past-Due Or High Bills As Winter Moratorium Ends March 31

-- PUC Concludes 2022 Pottstown Explosion Investigation Finding No Evidence Natural Gas Service Contributed To Deadly Event

[Posted: March 31, 2023]


4/3/2023

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