The state review process is a collaborative process by which review teams composed of stakeholders from the oil and gas industry, state environmental regulatory programs, and members of the environmental/public interest communities review state oil and gas waste management programs against a set of guidelines developed and agreed to by all the participating parties.
STRONGER has assembled a review team consisting of two representatives from each of state governments, industry, and environmental organizations. The in-state portion of the review will take place on May 28-31 in the DEP offices in Harrisburg. The review is open to observation by the public. Following the in-state portion of the review, the review team will develop a report that includes both findings of program strengths and recommendations for program improvement. This will be the fifth review of Pennsylvania's oil and gas program since 1990. For more information, contact Jim Erb at email@example.com.
In 2010 the STRONGER Board approved guidelines for state oil and gas regulatory programs relating to hydraulic fracturing. Stakeholder review teams have compared seven state programs (Pennsylvania, Ohio, Oklahoma, Louisiana, Colorado, North Carolina and Arkansas) against the guidelines.
Although the hydraulic fracturing guidelines were recently developed, several issues have been raised during reviews and STRONGER Board discussions. These include the management of source water supply (recycling/reuse, alternative sources such as acid mine drainage), criteria for groundwater protection through proper well construction (cementing and casing), groundwater monitoring, and monitoring of Bradenhead annular pressures during hydraulic fracturing operations. Consequently, the STRONGER Board decided to reconvene the Hydraulic Fracturing Workgroup to review these and perhaps other issues identified by the workgroup and to recommend revisions to the hydraulic fracturing guidelines.
In 2012 the Hydraulic Fracturing Workgroup developed revisions to the guidelines. These were shared with and reviewed by the U.S. Environmental Protection Agency and the Bureau of Land Management in the Department of the Interior. Comments from both agencies were considered by the workgroup and proposed hydraulic fracturing guidelines were sent to the Board with a recommendation that they be made widely available for review and comments. On February 1, 2013 the Board approved that recommendation. Subsequently, the proposed changes were distributed to state, industry and environmental organizations for review and comment. Comments were received from six organizations. Those comments were reviewed by the Hydraulic Fracturing Workgroup and several changes resulted. The Workgroup forwarded the revised guidelines to the Board with a recommendation for approval, and on May 13, 2013 the STRONGER Board approved the revisions.
Since April 2012, STRONGER has engaged a multi-stakeholder Air Discussion Workgroup to evaluate the potential involvement of STRONGER in improving state air quality regulatory programs related to oil and gas exploration and production activities. The Workgroup was made up of representatives of industry, state agencies and public interest organizations as well as official observers from three federal agencies; EPA, DOE and BLM.
In October 2012 the Air Discussion Workgroup made recommendations to the STRONGER Board on a path forward. The STRONGER Board unanimously approved the recommendations of the Workgroup at its Board Meeting later the same month. The recommendations include: conducting a survey of state air programs, developing guidelines for state air programs that apply to program development and implementation, conducting several reviews of state programs, evaluating the adequacy of the guidelines based on the results of the state reviews, and modifying the guidelines as necessary based on actual state reviews. The recommendations also encourage education, communication and outreach with agencies, industry and public interest groups regarding oil and gas air quality issues.
The STRONGER Board has established an Air Workgroup to implement the Air Discussion Workgroup recommendations. The workgroup includes representatives of state and federal air and oil and gas programs, industry, and environmental organizations. The Workgroup has had telephone conference call conversations and met face-to-face on April 4-5, 2013. The Workgroup has developed an outline and is currently drafting sections of air guidelines for state agencies. Rough drafts are to be circulated to Workgroup members by June 1, 2013. The Workgroup will strive to develop a consensus document by the end of 2013.
The August 2011 Secretary of Energy’s Advisory Board (SEAB) Interim Report on Shale Gas Production included recommendations to improve communication among state and federal regulators: Provide continuing annual support to STRONGER (the State Review of Oil and Natural Gas Environmental Regulation) and to the Ground Water Protection Council for expansion of the Risk Based Data Management System and similar projects that can be extended to all phases of shale gas development.
The September 2011 National Petroleum Council (NPC) report "Prudent Development: Realizing the Potential of Abundant North American Natural Gas and Oil Resources" included the statement, "STRONGER should be bolstered and increase the scope of its activities. All states with natural gas and oil production should actively participate in STRONGER and use its recommendations to continuously improve regulation. It should be adequately funded, including from the federal government."
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