To: Bureau of Land Management RE: Fracking Disclosure Recommendations for Public Lands

The Bureau of Land Management (BLM) is currently considering regulations and guidelines for unconventional oil and gas development on millions of acres of public land, and SkyTruth believes that public disclosure must be an integral part of these new rules. The BLM has already indicated that they are strongly considering as the platform for disclosure, however, there are a number of transparency issues which are not currently addressed by the industry-funded website.
The Jonah Field in Sublette County, WY is partly managed by the BLM and has seen heavy development in recent years, based on mineral leases from the 1970’s. Millions more acres are under consideration for development, requiring strong, effective management with accurate and accessible disclosure.

Photo Credit: Bruce Gordon, EcoFlight
The BLM is a federal agency responsible for over 750 million acres of subsurface mineral rights, including an estimated 57.2 million acres of split estate properties; that is, the surface is privately owned, but the minerals belong to someone else. In this case, the deed holder is the U.S. government, and the guidelines for fracking on these lands will have significant impact on thousands of citizens and will likely set the national standard for disclosure and transparency.
In November, we released a unique database containing over 27,000 fracking chemical reports from FracFocus, an action that would have been unnecessary in a truly transparent and accessible system. In the interest of transparency, public health, and legal protection of property and resources, we advise the BLM to include the following functions in any final ruling on disclosure:
▪   Make Bulk Raw Data Download Available
▪   Lift Intellectual Property Restrictions
▪   Require “Official” Reference Copy for Reports
▪   Require a Document Publish Date
▪   Require Document Change Management
Make Bulk Raw Data Download Available:
In order to perform any aggregate analysis operation, currently a member of the public must go to great lengths to extract data from individual PDF files in order to compile them into a spreadsheet or database. We have demonstrated how this would be done with our Fracking Chemical Database, released last month.
This is necessary for tasks like the following:
The current publication mechanism presents a substantial up-front barrier to anyone seeking to use FracFocus data for research or regulatory purposes.


  • Minimum – Publish the entire collection in a simple standard text format (like CSV) that can be imported directly into a spreadsheet or database. 
  • Better – Provide a way to bulk download all the disclosure data in a search result set (as raw data, not PDFs)
  • Best – Consider automatically re-publishing disclosure content to or similar Open Data Initiative publication portal



Lift Intellectual Property Restrictions:


Intellectual Property (IP) /Copyright Statement on the FracFocus website is unreasonably restrictive
Remove the IP restriction entirely for all the disclosure data. Make an explicit statement that the data can be freely shared and used for any purpose.

Require “Official” Reference Copy for Reports:


There is no way to link directly to an individual disclosure document published on This is problematic for anyone reporting on the content of a disclosure because in order to reference the original document, they must re-publish a copy of it.
Add a mechanism to provide a permanent link to each disclosure document based on a unique document ID number. This becomes the official reference copy of the document in case there is any question about the accuracy of data re-published by a third party.

Require a Document Publish Date:


Currently there is no way to tell when a disclosure was first published, so there is no way to verify after the fact whether the disclosure was made in the required time window.
Include a “published” date with each disclosure record

Require Document Change Management:


We have observed documents that had their content altered after publication, so that the first edition of the document is no longer available and the new edition bears no indication that a previous edition was published.


Add a document change history and/or edit tracking to the document record, and assign a new unique document ID to the revised document so that the earlier revision is still accessible
Millions of acres held in the common trust of the American people are under consideration for an extractive process with a very large footprint and potentially significant impacts on air, land, and water. It is critical to the oversight and regulation of this process that the Bureau of Land Management require a disclosure and transparency system that is complete, accessible to all, and enforceable. As we have written before, FracFocus does not provide this transparency and access in its current configuration. Decisions about disclosure should either incorporate changes to the FracFocus disclosure platform, or utilize another system that accommodates the aforementioned needs.

The West Virginia Hills: Flyover of Wetzel County Gas Drilling (Part 2)

Last week I posted Part I of our LightHawk flight over West Virginia’s most active unconventional gas field in Wetzel County. Part I highlighted what an actual hydraulic fracturing job looks like and illustrated a chronic issue in  rugged terrain – frequent “slips,” which are effectively small landslides. Today I will point out several more issues that were readily visible from an aerial perspective: infrastructure, habitat fragmentation, and proximity to homes.

Highlight #3: Infrastructure

While not discussed nearly as much as water contamination, buildout of natural gas infrastructure is a certain impact of unconventional  shale gas development. Gas separator units and condensate tanks remain on the wellpad for the productive life of the well, pipeline networks crisscross the fields and forests to connect all of the wells to market,  compressor stations will run as long as there is gas moving through the pipelines, and large petrochemical facilities set up shop in traditionally rural areas. These facilities have a big footprint on the land, and contribute to air, noise, and light pollution in largely rural areas.
One facility that stood out in particular is the new Mark West Compressor Station near Mobely, WV. Because of the lack of flat ground in these hills, with the exception of floodplains, any major installation is going to have a larger than usual footprint, and this one in particular appears to have completely rearranged the natural profile of the ridge top:
Our colleagues at the Wetzel County Action Group tell us this ridge has been lowered at least 100 feet. It is apparent that the terrain has been heavily modified.                                  
Photo: David Manthos, SkyTruth; Facilitated by LightHawk

Highlight #4: Habitat Fragmentation

Add miles of access roads and pipeline right-of-ways to the footprint of development and the total area impacted increases considerably. In mixed land-use areas this may not be a major issue, but in contiguous forests and state game lands fragmentation has serious ecological consequences. The USGS recently published a paper on habitat fragmentation in Washington and Bradford County, Pennsylvania, using aerial image analysis and GIS like we do here at SkyTruth. They concluded that change was occurring in the these counties, but was not yet very significant due to the high quantity of pre-existing fragmentation of those areas. The paper explains the concepts of fragmentation very well but we need to see similar studies conducted with a narrower focus (such as the Loyalsock State Forest in PA).


In the background of the Mark West Facility, two pipeline right-of-ways are visible in the center and to the right. These are just a couple examples of the miles of pipelines and service roads that will disect the forests of active gas fields for the lifetime of well-production.
Photo: David Manthos, SkyTruth; Facilitated by LightHawk
However, infrastructure, fragmentation, and air, noise, and light pollution may seem to be insignificant if human residents aren’t directly impacted by it. Biodiversity loss aside (a topic for a whole different post), in Wetzel County and across the nation, residents are experiencing a growing number of well pads, compressor stations, and other facilities moving in close to home, bringing us to the final point for this post.

Highlight #5: Residential Proximity

West Virginia law, House Bill 401 to be specific, has restrictions on how close drilling activity can be from occupied dwellings, streams, water wells, etc. According to the law,  “The center of well pads may not be located within six hundred twenty-five feet of an occupied dwelling structure.” There are several issues with the way this law is worded, but the main problem is that the distance restriction is on the center of the well pad, not the boundary. Therefore, the edge of an active industrial site could quite easily overreach the already limited buffer zone.
The proximity of houses and farms to industrial activity is an issue across the entire Marcellus Shale play. Here in SW Pennsylvania, several homes are immediately downhill of a large pad and the service road for two well pads goes through the bottom center of the image.
Photo: David Manthos, SkyTruth; Facilitated by LightHawk
In Wetzel County, WV, Stone Energy’s Weekly pad (orange tanks in the center of the image) is surrounded by private homes. The green structures on the pad are separators and condensate tanks which remove and store ethane, butane, propane, and other gas “liquids” from the natural gas produced by the well. These units run constantly and at times emit sickening fumes that cause headaches and respiratory irritation.
Photo: David Manthos, SkyTruth; Facilitated by LightHawk


There are many more observations to make about hydraulic fracturing and unconventional shale gas development, and many more ways we want to look at it from the sky. These are just the most obvious issues illustrated by this round of images. Even developed as responsibly as possible, it is undeniable that unconventional shale gas extraction will change the landscape of West Virginia for decades to come.
Stone Energy’s Howell Pad: 16 acres of surface disturbance.
Photo: David Manthos, SkyTruth; Facilitated by LightHawk
Oh, the West Virginia hills! How unchang'd they seem to stand,
With their summits pointed skyward To the Great Almighty's Land! 
Many changes I can see, Which my heart with sadness fills; 
But no changes can be noticed In those West Virginia hills
-WV State Song: The West Virginia Hills (circa 1885)

Fishing The Line: New Nighttime Satellite Imagery Illuminates Global Fishing Activity

We were wowed like a lot of other folks this week when NASA unveiled the newest “Earth at Night” satellite imagery at the annual AGU fall meeting in San Francisco.  They’ve compiled a bunch of cloud-free, moonless night images collected by the VIIRS sensor onboard the Suomi NPP satellite to create the stunning “Black Marble” vision of Earth at night, the complement to their daytime “Blue Marble” products:

updated 20190219, original image at:

You can explore this neat global dataset in various ways.  Check out an image gallery; play with a handy interactive map; or, my favorite, bring the data into Google Earth, where you can overlay all kinds of other useful data and information to help make sense of what you’re seeing.

So what can you see with nighttime imagery from space?  Well, the lights of cities and towns, of course.  And some other interesting things:  the flaring of natural gas in North Dakota, being treated as a waste product in the Bakken Shale oil-drilling and fracking boom there; flaring offshore too, in the Gulf of Mexico and other locations; fires burning vast areas in Siberia.

And the bright lights of fishing fleets operating around the world. Here’s an example that really caught our eye, in the East China Sea.  The lights from many vessels form a distinct cluster with strikingly sharp, rectilinear edges. I’ve been told this is a real pattern, not a data artifact, possibly revealing “fishing the line” behavior: fishing vessels, armed with GPS navigation systems, are cozying right up to the boundaries of areas where fishing has been restricted or put off limits.These lines don’t seem to match the Exclusive Economic Zone (EEZ) boundaries of Japan, China or Korea. Does anyone know if these patterns we’re seeing really do match up with treaty boundaries or other fisheries agreements?

Black Marble nighttime satellite imagery showing fishing vessel activity in the East China Sea.
[UPDATE 12/07/2012 5pm ET]  A few experts weighed in today via email with some very helpful info, and agreed to let me share their comments (lightly edited).

NASA’s Jesse Allen:

…in short, what you are seeing is ‘aggressive respect for fishing boundaries,’ if I might phrase it that way.

The data we used to make the Black Marble is a composite of several moonless nights in both April and October processed by the NOAA-NGDC in Colorado.  We…mapped that data onto a background colour image and turned plain jane composite light intensity into a colourized map.  So what you are seeing are lights over several different nights in rather different times all added up together at once.
We have noticed… that in many different passes over the Yellow Sea and the general area around the Sea of Japan and the Koreas that there would be boats with lights lined up in what seemed like very unnatural patterns: linear straight lines with sharp corners and such.  If you look here, you can see a less dramatic version of this lining up (in this specific instance, the line they seem to be snuggling along is more of a curved feature).  Those features match up with various fishery boundaries and agreements about respective nation’s areas in shared fishing rights areas (so if you get GIS data for Exclusive Economic Zones, you’ll find that many of these features do not line up with those zones, though some do…)

Steve Miller at Colorado State University:

…because of the current compositing technique done for the Black Marble dataset there are considerably more ship lights than would be seen on any given night…as ships come and go, move around, from night to night you would get “new” points.  From the standpoint of improved sample density, however, it sure helps to outline the political boundaries in more striking detail than any particular night can do!

It’s just another example of how much information content exists in these measurements….and how unique they are from the standpoint of coupling human activity with the natural environment in a way that conventional visible imagery cannot do.
NOAA’s Chris Elvidge:

We have seen these EEZ boundary patterns with fishing boats for 20 years from DMSP.  So it is not surprising or new.  Fishery agencies in Japan, Korea, Peru and Thailand use DMSP data from NGDC to monitor fishing boat activity relative to EEZ boundaries.  Note that the new global cloud-free VIIRS nighttime lights product was produced at NOAA…  NASA wrapped NOAA’s product on a “black marble.”


Chevron No Longer Banned from Operating in Brazil

Remember when Chevron spilled 3,600 barrels of oil when they lost control of an exploratory well in the Frade Field off the coast of Brazil last year? Brazilian Federal Appeals Court judge Guilherme Dienthaeler has overturned the ban in what appears to be a rapid move toward a settlement.

“(Reuters) – Chevron Corp received a boost to its efforts to restart oil output in Brazil after a court overturned a ban on its operating in the country and the company agreed on a plan to improve safety procedures after an oil spill last year.” For the full story, click here.
Aerial view of oil spill in the Frade Field, Campos Basin, Brazil, on November 18, 2011. In the background is the Transocean semisubmersible drill rig operated for Chevron. Photo copyright Marcia Foletto/Agencia O Globo – All rights reserved. 
Chevron and Transocean Ltd. (yes, this Transocean) still face up to $20 billion in damages and some criminal charges, but Federal Prosecutor Eduardo Santo de Oliveria who filed the initial lawsuits is disappointed with the move toward settlement. Reuters quoted Oliveria as saying,”I’m afraid we will lose the chance to apply a giant fine and the good that will do for preventing environmental crime.”

Earlier this year, SkyTruth President John Amos travelled to Natal, Brazil to present our observations at the Brazilian Congress on Protected Areas. For more, click here if your Portuguese is up to par, if not maybe just try Google Translate.

The West Virginia Hills: Flyover of Wetzel County Gas Drilling (Part I)

[Click here to see Part II of this Report)

For all that we do working on satellite and aerial images, it is extremely refreshing to actually get a chance to go up in the air ourselves. Last month we had the one such opportunity when we were asked by the Environmental Defense Fund (EDF) if we could put together an aerial tour of active gas fields. Enabled by our partners at LightHawk, we arranged a flight over one of the most heavily drilled regions in West Virginia: Wetzel County.

This heat map from the West Virginia Dept. of Environmental Protection- Office of Oil and Gas shows density of Marcellus Shale drilling activity. Due to the profitability of the liquids-rich gas found in NW West Virginia and an energy market flooded with cheap natural gas, this area has become one of the most heavily developed parts of the state. 

If Wetzel County sounds familiar, that is because we have posted about drilling in this area before in a guest post by Jim Sheehan, a remote sensing and GIS specialist pursuing his Ph. D at West Virginia University. We are very interested in areas like Wetzel County because the United States is only at the beginning of a resource extraction boom that is promising thousands of wells to be drilled. If this occurs, areas that are now “hot-spots” could become the new norm. 
On November 15, John and I headed up to Pittsburgh to guide EDF and representatives from some of their partner foundations on an aerial tour of active natural gas fields. Since SkyTruth doesn’t have our own plane, we coordinated with LightHawk, a volunteer pilot organization that connects pilots with non-profits to promote environmental conservation. They arranged for two single-engine aircraft to fly us on a 160 mile round trip over SW Pennsylvania, into Wetzel County, and back via the Northern Panhandle of West Virginia.

Our flight-plan, from the Allegheny County Airport (KAGC) in the north, down to Wetzel County, over the Lewis Wetzel Wildlife Management area (in green) and through  an area of intense activity know as the Victory Field (in red).

There is only so much space in a blog-post, so here are just a few highlights observed flying over one of the most active unconventional gas fields in the region:
Highlight #1: Fracking
There is no need to belabor familiar talking points about fracking, but there is something commonly misrepresented I would like to clear up. Google image search the word “fracking” and you are more likely to see a generic drill rig than an actual hydraulic fracture job underway. Between incorrectly labeled pictures of drill rigs and a wide variety of diagrams, you have to sift through  dozens of pictures before you actually find an image of  an actual frack. Back in October, I posted about visually assessing well sites from aerial survey photos to determine disclosure compliance, and included a detailed breakdown of what a frack-job looks like“in-progress.” On the flight, I took some high-resolution photos of a frack underway at Stone Energy Pad #2 in the Lewis Wetzel Wildlife area, a state gameland.

Stone Energy Pad #2, Lewis Wetzel Wildlife Management Area, Wetzel County, WV. All chemicals and water appear to be stored in portable red tanks (instead of open pits), are mixed with a proppant (usually fine silica sand), and are forced down the wellbore by the blue, truck-mounted compressor engines.  The Centers for Disease Control (CDC) and the National Institute for Occupational Safety and Health (NIOSH) have issued a warning about the risk of silicosisfrom this process, but local activists across the Devonian Shale region frequently report that workers rarely use any kind of mask or respirator. 

Highlight #2: Slips and Landslides
Many of the drill rig crews working in the Marcellus are not from West Virginia or even Appalachia, but from much flatter Oklahoma, Texas, North Dakota, etc. Whether unfamiliarity with steep terrain is the cause or not, Wetzel County has experienced a significant number of “slips,” where wellpads, containment ponds and/or roads have become unstable and “slid” downhill. This has resulted in a number of wastewater ponds failing and leaking their toxic contents, blocking roads (even blocking emergency services from responding to a medical emergency).
We flew over numerous sites that have had issues with this public safety hazard, but none stood out as much as the Ray Baker pad in Marshall County. 
Citing “imminent danger” to people, the WV DEP shut down this site in December 2011,  and despite a year of work Chesapeake has been unable to stabilize the site to the satisfaction of the DEP.  The hillside has continued to slide, shutting down a public road for weeks and forcing a downhill neighbors to relocate due to danger to his home.
Chesapeake Energy has been working since 2011 to stabilize the site after being cited by the Army Corps of Engineers for “discharging pollutants into an adjacent stream.” Operators were hoping to be approved to restart work last month, but the most recent slips have left the site’s operations suspended indefinitely.
Stay tuned for more highlights, or view the whole gallery now on Flickr:

Wetzel County Gas Drilling: Aerial Tour

You can also view the point-by-point guide we created for the passengers for a more detailed view of all the sites we visited. Many thanks to EDF and LightHawk for making this opportunity possible.