High Volume Hydraulic Fracturing in Michigan INTEGRATED ASSESSMENT FINAL REPORT SEPTEMBER 2015 About This Report
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High Volume Hydraulic Fracturing in Michigan INTEGRATED ASSESSMENT FINAL REPORT SEPTEMBER 2015 About this Report his report is part of the Hydraulic Fracturing in Michigan Integrated public comments received throughout this process. However, the report Assessment (IA) which has been underway since 2012. The guiding does not necessarily reflect the views of the Advisory Committee or any T question of the IA is, “What are the best environmental, other group which has provided input. As with preparation of the technical economic, social, and technological approaches for managing reports, all decisions regarding content of project analyses and reports have hydraulic fracturing in the State of Michigan?” been determined by the IA Report and Integration Teams. The purpose of the IA is to present information that: While the IA has attempted to provide a comprehensive review of the current status and trends of high volume hydraulic fracturing (HVHF), specifically, in • expands and clarifies the scope of policy options, and Michigan (the technical reports) and an analysis of policy options (this report) • allows a wide range of decision makers to make choices based on their there are certain limitations which must be recognized: preferences and values. • The assessment does not and was not intended to provide a quantitative As a result, the IA does not advocate for recommended courses of action. assessment (human health or environmental) of the potential risks Rather, it presents information about the likely strengths, weaknesses, and associated with HVHF. Completing such assessments is currently a key outcomes of various options to support informed decision making. point of national discussion related to HVHF despite the challenges of The project’s first phase involved the preparation of technical reports on key uncertainty and limited available data–particularly baseline data. topics related to hydraulic fracturing in Michigan which were released by the • The assessment does not provide an economic analysis or a cost-benefit University of Michigan’s Graham Sustainability Institute in September 2013. analysis of the presented policy options. While economic strengths and/ This document is the final report for the IA. or weaknesses were identified for many of the options, these should not The IA report has been informed by the technical reports, input from an be viewed as full economic analyses. Additional study would be needed Advisory Committee with representatives from corporate, governmental, to fully assess the economic impact of various policy actions, including no and non-governmental organizations, a peer review panel, and numerous change of current policy. PARTICIPATING UNIVERSITY OF MICHIGAN UNITS Graham Sustainability Institute Energy Institute Erb Institute for Global Sustainable Enterprise Risk Science Center For more information on this project, please go to: http://graham.umich.edu/knowledge/ia/hydraulic-fracturing You may also contact John Callewaert, Graham Sustainability Institute Integrated Assessment Center Director, (734) 615-3752 or [email protected]. GRAPHIC DESIGN BY SUSAN E. THOMPSON DESIGN ILLUSTRATIONS BY JACK CURRY, MARLI DU PLESSIS, ZLATKO NAJDENOVSKI, STEFANIA SERVIDIO, AND SUSAN THOMPSON HIGH VOLUME HYDRAULIC FRACTURING IN MICHIGAN INTEGRATED ASSESSMENT FINAL REPORT SEPTEMBER 2015 Table of Contents List of Tables, Figures, and Boxes . ii CHAPTER 6: LIMITATIONS AND KNOWLEDGE GAPS. .118 List of Acronyms/Abbreviations. iii 6.1 Limitations . 119 Executive Summary . 1 6.2 Knowledge Gaps . .119 List of Policy Options. 13 APPENDIX A: GLOSSARY. 122 CHAPTER 1: INTRODUCTION 18 1.1 Purpose and Scope . 19 APPENDIX B: BROADER CONTEXT . 126 1.2 Overview of Activity in Michigan . 20 B.1 Introduction. 127 1.3 Structure of the Report . 21 B.2 Climate Change: What are the Effects of Natural Gas 1.4 Technical Report Summaries. 22 Production and Fugitive Methane Emissions? . 127 1.5 Integrated Assessment Process. 26 B.3 Renewable Energy: Will Natural Gas Be a Bridge to a Cleaner Energy Future?. 129 CHAPTER 2: PUBLIC PARTICIPATION . 30 B.4 Manufacturing: Will Natural Gas Development Revitalize Domestic Manufacturing? . 130 2.1 Introduction. 31 2.2 Incorporating Public Values in HVHF-Related Policies and B.5 Exports: What are the Implications of Natural Gas Exports? . 132 Decision Making . 32 B.6 Human Health Risks: How Do We Know If Shale Gas Development is “Safe”? . 133 2.3 Public Input in State Mineral Rights Leasing . 39 B.7 Conclusion . 134 2.4 Public Participation and Well Permitting . 43 2.5 Summary of Options for Improving Public Participation . 47 APPENDIX C: ADDITIONAL ISSUES. 144 CHAPTER 3: WATER RESOURCES . 54 C.1 Introduction. 145 C.2 Environmental Impacts. 145 3.1 Introduction. 55 C.3 Air Quality. 145 3.2 Regulating HVHF through Water Withdrawal Regulation . 59 C.4 Landowner and Community Impacts . 147 3.3 Wastewater Management and Water Quality . 74 C.5 Agency Capacity and Financing . .151 CHAPTER 4: CHEMICAL USE . .84 APPENDIX D: REVIEW PROCESS . 158 4.1 Introduction. 85 D.1 Review Panel Summary Report . 159 4.2 Information Policy . 86 D.2 Response to the Review Panel Summary . .161 4.3 Prescriptive Policy . 95 D.3 Review Panel Individual Review Form. 162 4.4 Response Policy . .101 APPENDIX E: PUBLIC COMMENT SUMMARY CHAPTER 5: POLICY FRAMING ANALYSIS . .114 AND RESPONSE . 164 5.1 Introduction. 115 5.2 Adaptive Policies . .115 5.3 Precautionary Policies . .116 5.4 Summary . .116 U-M GRAHAM SUSTAINABILITY INSTITUTE LIST OF TABLES TABLE 3.1 Different Requirements for Registration and Permitting of Large-Volume Water Withdrawals in Michigan under WWAP TABLE 3.2 Relative Water Use Rates Associated with Different Types of Hydraulic Fracturing TABLE 3.3 Comparison of Registered Water Withdrawal Capacities in Six Stream-Sized Subwatershed Units in Michigan That Have No More Available Water for Withdrawal TABLE 4.1 Production Characteristics of States Surveyed TABLE 4.2 Demographic Characteristics of States Surveyed TABLE 4.3 Policy Characteristics of States Surveyed TABLE 4.4 Summary of Information Policy Options for Michigan TABLE 4.5 Summary of Prescriptive Policy Options for Michigan TABLE 4.6 Summary of Planning, Response, and Liability Policy Options LIST OF FIGURES FIGURE 1.1 Activity in Michigan. a) Oil and gas wells in 2005 and b) HVHF wells as of May 28, 2015 FIGURE 1.2 U.S. dry shale gas production FIGURE 1.3 IA report organization FIGURE 1.4 Hydraulic fracturing process FIGURE 1.5 IA process FIGURE 3.1 Simplified structure of the WWAT, indicating how a proposed water proposal generates a Policy Zone assessment FIGURE 3.2 Flow diagram of the process of registering a water withdrawal through the WWAT and potential SSR process FIGURE 3.3 Location of Utica-Collingwood Shale and existing and pending large-scale withdrawals associated with State-defined HVHF operations (left) and existing policy zone designations through January 2014 FIGURE 4.1 FracFocus chemical disclosure registry search page FIGURE 5.1 Adaptive policy conceptual framework LIST OF BOXES BOX 1.1 Key Terms BOX 1.2 Hydraulic Fracturing and High Volume Hydraulic Fracturing BOX 3.1 The WWAT and SSR BOX 3.2 Why use the WWAT if it wasn’t designed for HVHF? BOX 3.3 Water Metrics BOX 3.4 Groundwater withdrawal, geographic scale, and the concept of consumptive uses BOX 3.5 Importation of Hydraulic Fracturing Waste into Michigan LIST OF APPENDIX TABLES & BOXES TABLE C.1 Environmental Impacts—Example Approaches TABLE C.2 Air Quality Impacts—Example Approaches TABLE C.3 Landowner and Community Impacts—Example Approaches TABLE C.4 Michigan OOGM Staffing and Budget, 2010-2014 TABLE C.5 Agency Capacity and Financing—Examples from Other States BOX B.1 Differences and uncertainties in GHG emissions estimates ii U-M GRAHAM SUSTAINABILITY INSTITUTE List of Tables, Figures, and Boxes LIST OF ACRONYMS/ABBREVIATIONS API American Petroleum Institute MCL Michigan Compiled Laws ARI Adverse Resource Impact MLP Master Leasing Plans CAS Chemical Abstracts Service MSDS Material Safety Data Sheets CBM/CBNG Coal Bed Methane / Natural Gas NMEAC Northern Michigan Environmental Action Council CDP Comprehensive Development Plans NORM Naturally Occurring Radioactive Materials CLOSUP University of Michigan Center for Local, State and NOX Nitrogen Oxides Urban Policy NPDES U.S. Environmental Protection Agency National Pollutant CGDP Comprehensive Gas Drilling Plan Discharge Elimination System CNG Compressed Natural Gas NRC Michigan Department of Natural Resources Natural Resource Commission CO Carbon Monoxide OOGM Michigan Department of Environmental Quality Office of COGCC Colorado Oil and Gas Conservation Commission Oil, Gas, and Minerals CO Carbon Dioxide 2 PM Particulate Matter CSSD Center for Sustainable Shale Development POTW Publicly Owned Treatment Works CWA U.S. Clean Water Act PSE Physicians, Scientists, and Engineers DCH Michigan Department of Community Health PwC PricewaterhouseCoopers DEP Pennsylvania Department of Environmental Protection RDSC Royal Dutch Shell DEQ Michigan Department of Environmental Quality RFF Resources for the Future DMRM Ohio Division of Mineral Resources Management SCA Stipulation and Consent Agreement DNR Michigan Department of Natural Resources SDWA U.S. Safe Drinking Water Act DOGGR California Division of Oil, Gas, and Geothermal Resources SO2 Sulfur Dioxide DOH New York State Department of Health SRBC Susquehanna River Basin Commission DRBC Delaware River Basin Commission SSR Site-Specific Review EPA U.S. Environmental Protection Agency