The Sportsmen Alliance for Marcellus Conservation is not opposed to shale gas development and recognizes the potential economic and social benefits. Rather, the Alliance is concerned that the current state and local policies governing gas drilling and related infrastructure development in the eastern shale gas region do not adequately protect valuable and irreplaceable natural resources, including clean water and critical habitat for fish and wildlife. Together, we can have a strong voice in protecting our valued fish and wildlife habitat as the eastern shale gas region is developed.
While shale gas development is regulated independently by each state – often leading to inconsistent regulations and environmental protections – common concerns about each state's oversight of shale gas development exist across the entire eastern shale region.
Many of the recommendations here relate to all phases of shale gas development.
To understand the recommendations of the Alliance, it's important to realize that there are many difference impacts – to water and fish, and to the sportsmen's experience. Each presents unique challenges and opportunities.
Water and Fish
- Each state should adopt a comprehensive statewide water withdrawal law, requiring any entity proposing to withdraw a certain amount of water, above a pre-determined threshold, to receive a permit. This law would allow the state to track and prioritize essential uses and provide a predictable, consistent mechanism for managing water resources. Each state should determine the maximum amount of water that can be extracted from a given stream. When necessary, it should limit total withdrawals for gas drilling, to ensure hydrologic functions and ecological needs. Water withdrawals should be prohibited from sensitive trout streams during spawning periods.
- Placement of well pads, compressor stations, storage pits and other drilling infrastructure should be evaluated on a case-by-case basis to ensure adequate buffers between surface waters.
- The gas drilling industry should be required to collect independently certified pre-drilling water quality monitoring data for nearby streams, as part of the permit process. This monitoring data will document contaminants that may already be present in the water. Water quality monitoring should occur regularly in nearby surface waters where a drilling site is active. Monitoring should continue for at least one year after the hydraulic fracturing process is complete.
- States should require each well operator to report the amount of water being withdrawn from a source and the total amount of water available from that source. States should then compare those volumes to the projected demands on that watershed. Prior to issuing drilling permits, comprehensive studies should be required that assess existing and available surface and groundwater supplies and uses.
- Stormwater best management practices (BMPs) and technology should be employed, and the well operator should be required to prove that such practices are functioning prior to drilling. Gas drilling industry exemptions under the federal Safe Drinking Water Act and Clean Water Act should be repealed.
- Pre-lease planning on state lands should include mapping of high quality habitats important to fish and wildlife and core interior forests where limited or no drilling should occur.
- Vegetation loss should be minimized in construction of well pad or other drilling-related infrastructure. Remediation plans for well sites should be required and should include requirements for re-vegetation in phases.
- States should evaluate whether well pad sites are appropriate based upon their Comprehensive Wildlife Conservation Strategies and areas where species of greatest conservation need have been identified. Mitigation measures should be taken to avoid impact to the identified species in these areas.
- High fencing should be required around all drilling related infrastructure to reduce the likelihood that wildlife will enter well pad sites and consume wastewater or other toxic chemicals. Netting and appropriate bird deterrents should be installed over storage impoundments to keep birds from consuming wastewater.
- Inspection of all vehicles for invasive species should be required. Gas industry workers should be trained on how to identify invasive species and how to clean equipment prior to entering and/or leaving a drilling site.
- To protect world-class angling and other outdoor experiences, drilling operations should not be permitted in watersheds with special state-designated conservation status, such as Pennsylvania watersheds with designated wilderness trout streams (or other state equivalencies), without additional regulatory requirements, review and inspection.
- Wherever possible, existing roads should be used for access and gathering pipelines should be co-located along existing roads to minimize habitat fragmentation.
- Strict monitoring of erosion and sediment control practices, especially during and after storm events, must be required with an emphasis placed on performance and not just compliance.
- Stream crossing methods must be determined on a site-specific basis, taking into account the individual stream characteristics including bank stability, potential for scour and migration of the stream channel. Construction should take place in a 24-hour period, with appropriate sedimentation controls and barriers in place to avoid impacting water quality. Seasonal restrictions must be imposed to protect spawning fish.
- Clearing of vegetation in the riparian area along stream crossings should be minimized and temporary workspaces kept away from riparian corridors.
- Water withdrawals for hydrostatic testing of the pipeline must account for seasonal restrictions and include minimum flow standards to ensure adequate stream flow for aquatic life.
- Discharged hydrostatic water must be filtered to avoid sediment loading.
- Streams should be restored to original conditions. The restored stream channel should be comparable in width, depth, slope and substrate to upstream and downstream reaches, and should be constructed of native materials similar in condition, appearance, type, composition and species to those in the vicinity of the crossing.
- Sensitive natural resources and steep slopes (in excess of 15 percent) should be avoided and stream crossings minimized.
- Proposed pipelines should be co-located with existing rights-of-way where possible, reducing fragmentation across the landscape.
- Avoid compaction of soils along the pipeline corridor. Sod mats – about 8-12 inches of soils and rootstocks – can be lifted, stored near the corridor and replaced within a few days as construction progresses.
- Vegetation in the temporary construction corridor area should be restored with native grasses and shrubs. Successional habitat should be planted along the corridor edge, to create a transition zone for wildlife.
The Sportsmen's Experience
- Drilling operations, including truck traffic, should be prohibited on state lands during opening days of hunting, fishing and trapping seasons and should be minimized during key breeding seasons.