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When Numbers Aren't What They Seem

Recently PA DEP announced that between 2017 and 2021, DEP issued 3123 Notices of Violation for abandoned conventional oil and gas wells. That sounds bad. And, indeed, groups like PA Environmental Digest published articles saying that conventional oil and gas operators are abandoning conventional oil and gas wells at the rate of over 500 wells per year.

In April 2023 the PA House ERE Committee held a hearing to take testimony about abandoned conventional wells. Once again, supposedly knowledgeable people testified to our legislators that the DEP numbers show that conventional operators are abandoning oil and gas wells at alarming rates.

Trouble is: DEP doesn’t actually track the number of wells that conventional operators abandon each year. In fact, during the time period 2017 to 2021 the number of wells abandoned might have been zero. The DEP doesn’t know.

At the May 2023 PA Grade Crude Development Advisory Council meeting, DEP was asked to address gaps in its database. The DEP admitted that its database “is not granular enough to tell us when the 3123 wells were abandoned.” Indeed, the DEP admitted the wells may have been abandoned decades ago.

The number of conventional wells on DEP’s Abandoned List is going through the roof because DEP is applying for Federal money for well plugging. The more wells on the list, the more money. Below is a chart that tracks how DEP is “growing” the number of wells on the DEP abandoned list. Between January 2022 and May 2023 the number of wells on the DEP Abandoned List leapt from 2,656 to 20,577!!!!!!!!

DEP will be the first to admit that 18,000 conventional wells were not abandoned in the 17 months between January 2022 and May 2023. Instead, DEP is catching up with its record keeping. And 94% of the wells on DEP’s Abandoned List were drilled prior to 1984—meaning the wells were never subject to bonding.

People who live in glass houses shouldn’t throw stones. DEP has to explain its sudden “finding” of abandoned conventional wells. The current DEP data does not justify HB 962 or any other legislation meant to “rein in” an alleged abandoned well problem. Responsible conventional oil and gas operators are being smeared by sloppy data that doesn’t add up. DEP needs to pause and explain how it has suddenly discovered 18,000 abandoned conventional wells.

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