Let's add a little teaser from the article.
A recently released analysis, “An Analysis of Unconventional Gas Well Reporting under Pennsylvania’s Act 13 of 2012” states the Pennsylvania Department of Environmental Protection did not report all of the state’s natural gas wells and this could result in the loss of hundreds of millions of dollars.
- Finally, fees depend on spudding, or “the actual start of drilling of an unconventional gas well” (58 Pa.C.S. §2301). In the oil and gas industry, spudding is distinct from activities such as completion and production, which can occur only after spudding, if at all. By anchoring the assessment of fees on spudding, Act 13 requires the identification of unconventional gas wells without reference to completion or production. But, in that case, how does one differentiate unconventional and conventional wells, as both are essentially identical at the start of drilling? And how can the DEP retroactively determine whether an unconventional well has been spud if the necessary records were not kept?
- Phase 1: The DEP Omitted 1,500 “Recent” Unconventional Spuds: The first phase of our analysis started with the DEP’s Act 13 report and focused on determining the extent to which the DEP accurately reported on recent unconventional well spuds—those between 2002 and 2011, as this was the time period explicitly covered by its report. In particular, we compared the DEP’s Act 13 report with its previously published reports covering the same period. Essentially, we used the DEP’s existing reports to assess the accuracy and completeness of its Act 13 report. This entailed downloading five additional DEP reports—permits, spuds, production, wastes, and compliance—all of which were publicly available on the DEP’s Office of Oil and Gas Management website.
I have to wonder if this is intentional because of the DEP relationship with the drillers, or if it is just incompetence. One if just as likely as the other.
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