Natural Gas Well Regulation in Fort WorthTo establish regulations for the siting and permitting of...

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Natural Gas Well Regulation in Fort Worth Intro to GIS Daniel Querejazu December 10, 2012

Transcript of Natural Gas Well Regulation in Fort WorthTo establish regulations for the siting and permitting of...

Page 1: Natural Gas Well Regulation in Fort WorthTo establish regulations for the siting and permitting of natural gas wells, city officials must first have an understanding of the health

Natural Gas Well Regulation in Fort Worth

Intro to GIS

Daniel Querejazu

December 10, 2012

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I. EXECUTIVE SUMMARY

The natural gas boom that has occurred in the United States in the last decade has seen a dramatic increase in the drilling and production of gas in many areas of the country. One of these areas is the Barnett Shale region in the northeast part of Texas, home to a number of cities, including Dallas and Fort Worth. While natural gas wells have traditionally been found in rural areas, the recent years have seen gas drilling begin to encroach into the more urban areas of the Dallas-Fort Worth metroplex. Because Texas leaves the siting and permitting of natural gas wells to its municipalities, each city in the region has chosen its own statutes and permitting regimes for gas wells within their limits. This paper will focus on the permitting and siting of natural gas wells in the City of Fort Worth.

Cities around the Barnett Shale have created permitting regimes for drilling based on what they consider best for their residents and their safety. Dallas has yet to issue any permits for gas wells within its city limits and has created a task force to study whether its current regulations are adequate to mitigate the impacts that urban wells could have on its communities. The City of Denton has placed a moratorium on drilling gas wells inside its city limits. Fort Worth, on the other hand, is one of the only dense urban areas in the nation that allows, and even encourages, natural gas drilling. Fort Worth currently has over 1,700 producing wells within the city limits, plus an additional 250 wells that have received permits but have not yet been constructed.

This paper will look at the possible environmental and social impacts of urban gas wells, and examine the regulations that Fort Worth has established for drilling within the city. It will also look at regulations that other cities in the Barnett Shale have been established and how they compare to those of Fort Worth. It will examine how Fort Worth came to have so many wells, while some of its smaller, less dense neighbors have so few. Using GIS mapping techniques, it will analyze how closely Fort Worth enforces its own siting and permitting ordinances. It will also look at what would happen if the siting regulations of neighboring cities were applied to Fort Worth, and how many of the city’s 1,700 wells would not have received permits under these alternate city drilling ordinances.

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II. INTRODUCTION

Environmental and Social Impacts of Natural Gas Wells

To establish regulations for the siting and permitting of natural gas wells, city officials must first have an understanding of the health and social impacts of natural gas wells in cities. Unfortunately, these impacts, particularly the social impacts, are not yet well understood. The environmental concerns of hydraulic fracturing – or fracking – get more headlines, but the drilling, production and transportation of conventional natural gas also carries some risks. The environmental and health risks come from air emissions associated with drilling and compression machinery and from the heavy truck traffic that is associated with well sites. Emissions at well sites are heaviest during the construction and drilling phases of a well’s life cycle, when drilling machinery, diesel generators and heavy trucks for hauling equipment are needed. The operational phase of a well’s life typically sees fewer emissions, though compressors and gas transportation trucks are still present during this period.1 Additional impacts from urban wells include noise from drilling activity, compressors and trucks, and from increased heavy truck traffic on roads that do not normally experience industrial traffic.

A 2011 air quality study of natural gas well sites in Fort Worth found that an estimated 20,818 tons of volatile organic compounds (VOCs) were emitted from Fort Worth’s natural gas sites per year.2 That number was expected to rise nine percent by 2012. Most of these VOC emissions came from natural gas leaking from wells, storage tanks and transportation equipment. Roughly 98 percent of those VOCs were compounds with relatively low toxicities, like ethane, methane and propane. However, the remaining two percent of emissions came from VOCs with relatively high toxicities, such as benzene and acetone. VOCs can break down into ground level ozone, which lowers air quality, causes smog and haze, and can lead to respiratory illnesses. The more toxic compounds can cause cancer and respiratory problems.

The study found that emissions from well sites were normally localized 200 to 300 feet from the well site, and did not pose a health threat beyond that. The study included data from eight ambient air monitoring stations, which found low variability among VOCs

1 Clarke, C.E. et al. Life Cycle Analysis of Shale Gas and Natural Gas. Argonne National Laboratory, Argonne, Illinois (2011): 18. 2 City of Fort Worth. City of Fort Worth Natural Gas Air Quality Study. City of Fort Worth, Fort Worth, Texas (2011): 15.

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across the monitoring stations. It concluded that these VOCs were not due to localized emissions from well sites, but rather that they exist as background pollutants.

This Fort Worth air quality study is one of the most comprehensive studies to date on the health impacts of urban natural gas wells, yet it only analyzed localized leaks and emissions of natural gas itself – VOCs. It did not look at whether the well activity had increased background levels of VOCs around the city, nor did it analyze other types of air emissions, such as particulate matter (PM) or nitrogen oxide (NOx) from trucking and machinery associated with drilling. These industrial emissions vary widely by site, depending on whether compressors are present and operating and on truck traffic to and from the site. No study has been done of the effects of these non-VOC emissions from natural gas wells on dense residential areas.

While there has not yet been a comprehensive study of the social impacts from natural gas sites, a study of oil and gas sites in Alberta, Canada, found that the environmental risk, coupled with the noise impacts, visual impacts and increased heavy truck traffic, served to significantly reduce property values of residential properties near oil and natural gas sites.3 A study done by the Town of Flower Mound, Texas, found that residences adjacent to well sites experienced a three to 14 percent drop in property value. It also found the impact on property value generally dissipated around 1,500 feet from the well.4

Natural Gas Well Regulation in Fort Worth and Around the Barnett Shale

As mentioned in the Executive Summary, the citing and permitting of extraction wells is not regulated at the federal level or, in Texas, at the state level. Therefore, different cities in the Barnett Shale and around Texas have established their own ordinances related to natural gas wells, based on what their city governments have determined safe and in the best interests of its residents.

The City of Fort Worth puts no zoning restrictions on well sites, even allowing them to be built on land zoned for residential use. The city has established a setback of 600 feet – meaning that a new well cannot be built within 600 feet of a protected use. A protected use is defined in the ordinance as a residence, religious institution, hospital building or public park. The well applicant is responsible for ensuring that there are no protected use buildings within 600 feet of the site when filing for a permit. An applicant can obtain a 3 Boxall, Peter C., et al. “The impact of oil and natural gas facilities on rural residential properties: a spatial hedonic analysis.” Resource and Energy Economics 27 (2005): 266 – 267. 4 Town of Flower Mound. ORDINANCE NO. ________. First accessed November 19, 2012. http://www.flower-mound.com/DocumentCenter/View/900

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variance (exemption) from the 600 foot buffer if they get written waivers from protected uses within the setback. However, a well can never be placed less than 300 feet from a protected use, even if it is granted a variance from the 600 foot setback.

The 300 foot and 600 foot buffers are measured in a straight line, without regard for intervening structures or objects, to the closest exterior point of the building or boundary line of a public park or property line of a school. Therefore, if only the corner of a park or protected use structure falls within one of these boundaries, the setback has been violated.5

The City of Arlington, located between Fort Worth and Dallas on the Barnett Shale, has a regulatory structure that closely mirrors that of Fort Worth, though it only has 300 active wells within the city, whereas Fort Worth has over 1,700. It has identical setbacks and the same definitions for a protected use.6

The City of Dallas has no producing wells within the city and has created a Gas Drilling Task Force to study whether its current regulations are adequate. The task force has recommended that the city increase the setback requirements on natural gas wells from 300 feet to 1,000 feet and add retail and office structures to its protected use classification,7 which currently includes residences, religious institutions, hospital buildings and public parks. The city task force was created, in part, because of citizens’ concerns over the current regulations.

The Town of Flower Mound, north of Dallas and Fort Worth, has established a setback of 1,500 feet from a public park, residence, religious institution, hospital, school, public building or habitable structure. It also has a setback of 750 feet from any public road, highway or right-of-way. Its drilling ordinance also specifies when variances to the setback requirements can be granted, but those variances cannot reduce the prescribed setback by more than 25 percent.8

5 City of Fort Worth. ORDINANCE NO. 18449-02-2009. First accessed November 10, 2012. http://fortworthtexas.gov/uploadedFiles/Gas_Wells/gasdrilling_ordinance.pdf 6 City of Arlington. ORDINANCE NO. 11-068. First accessed November 19, 2012. http://www.arlingtontx.gov/planning/pdf/Gas_Wells/Gas_Drilling_and_Production_Ordinance.pdf 7 City of Dallas. Dallas Gas Drilling Task Force Recommendations for Regulating Gas Drilling and Production. First accessed December 1, 2012. http://www.scribd.com/doc/83539151/Dallas-Gas-Drilling-Task-Force-Recommendations 8 Town of Flower Mound. ORDINANCE NO. ________. First accessed November 19, 2012. http://www.flower-mound.com/DocumentCenter/View/900

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The City of Denton, north of Dallas on the Barnett Shale, has placed a moratorium on all drilling activities within the city until it can study the impacts that drilling could have on its residents. This year it has held a series of public meetings to ask for input on new ordinances for well citing and permitting.9

9 Peyton, Ben. “Denton Discusses New Drilling Ordinances as Moratorium Ends.” North Texas Daily, October 23, 2023.

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III. PROBLEM STATEMENT

This project will examine how Fort Worth came to have so many gas wells located in an environment that is densely populated with protected use areas and structures. It will look at where the natural gas wells are in Fort Worth in relation to the protected uses, as defined by the city’s natural gas well ordinance. It will examine the following:

• Are Fort Worth’s current setbacks strictly enforced? How many the city’s wells have protected use structures within the 300 foot well setback? How many wells are within 600 feet of protected uses? How many permitted, but not yet constructed, wells are within 300 and 600 feet of a protected use?

• How many of Fort Worth well’s would have received permits if alternate city ordinances were applied? The small town of Flower Mound has implemented a much stricter setback than Fort Worth. How many of Fort Worth’s 1,700 wells would have received permits under Flower Mound’s city ordinance? How many of the wells would receive permits if the Dallas task force’s recommended 1,000 foot setback were applied?

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IV. METHODOLOGY

Data Acquisition and Preparation

To analyze the enforcement of Fort Worth’s current regulatory setback and to find the effects of alternate cities’ setbacks, it was necessary to find spatial data on the locations of natural gas wells in the city of Fort Worth, as wells as the locations of protected use structures in the city.

GIS data on natural gas wells and leases were obtained from the City of Fort Worth through Freedom of Information Requests. The data include information on the status of the gas well (producing, permitted, pending, applying or abandoned), the address, the operator and the permit number. Using the selection tool, wells were selected and exported into different shapefiles based on their status – producing, permitted, applying or pending. Data on abandoned wells were discarded. The data includes 1,766 producing wells, 253 permitted wells, 1 pending well and 27 applying wells.

Protective use structures, for the purpose of this report, are those defined by the Fort Worth city ordinance – residences, religious institutions, hospital buildings and public parks. To find where the protected use structures are located in the city, freedom of information requests were submitted to the City of Fort Worth for the locations of all hospitals and schools within the city limits, as well as for building footprint and land use data within the city. Data on roads and the city limits were also obtained through FOI requests. The Tarrant County outline and block group data was downloaded from the Texas Data Center.

The spatial data for hospitals and schools were sufficient to go forward with analysis. The data obtained were point data that included the address and name of the facility. The data includes 267 schools and 20 hospitals.

To find the location of residences, a proxy was created:

• Using the land use data, all residential land uses (suburban residential, rural residential, single family, manufactured housing, low density residential, medium density residential, high density residential) were selected and exported to a new shapefile that only included residential land use.

• The building footprint data was clipped to the residential land use shapefile, and the remaining building footprints were categorized as “residential structures”. It should

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be noted that there is no guarantee that these structures are actually used as residences – they are simply structures that are on land zoned as residential. This method resulted in 268,655 residential structures.

Public parkland is one of the categories of land use in the land use data obtained from the city of Fort Worth. Public parks were selected from the land use shapefile and exported to create a new public park shapefile. The data includes 1,102 public parks.

Unfortunately, no spatial data could be found on the location of religious institutions in Fort Worth, so this protected use was no included in the analysis.

Spatial Analysis

With the data prepared, analysis was conducted on the existing Fort Worth setbacks (600 feet, but with exemptions the setback can be lowered to 300 feet at the minimum), the recommended Dallas setback (1,000 feet) and the Flower Mound setback (1,500 feet).

The buffer tool was used to spatially represent the 300 foot setback around producing wells.

• To find the number of residential structures within the setback: o The 300 foot buffer shapefile was spatially joined to the residential structures

shapefile. This created a new field in the 300 foot buffer shapefile attribute table that contained a count of all of the residential structures that fall (partially or totally) within the setback. By examining the attribute table, one can find how many wells have a residential structure within 300 feet.

o The intersect tool was used to intersect residential structures and the 300 foot setback. The intersection gives a count of the number of residences that fall within the setback citywide.

• To find the number of schools and hospitals within the setback: o The 300 foot buffer shapefile was spatially joined to the schools point data

shapefile. This created a new field in the 300 foot buffer shapefile attribute table that contained a count of all of the school that fall within the setback. Looking in the attribute table shows how many wells have a school within 300 feet. This step was repeated for the hospital point data shapefile.

o The intersect tool was used to intersect the schools shapefile to the 300 foot buffer shapefile. The remaining schools give a count of the number of schools within the 300 foot buffer. Repeat the same of the hospital shapefile.

• To find the number of public parks within the setback:

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o The 300 foot buffer shapefile was spatially joined to the public parks shapefile. This created a new field in the 300 foot buffer shapefile attribute table that contained a count of all of parks that fall (partially or totally) within the setback. Looking in the attribute table shows how many wells have a park within 300 feet.

o The intersect tool was used to intersect public parks and the 300 foot setback. The remaining parks give a count of the number of parks that fall with the setback citywide.

• These steps for the 300 foot buffer were repeated for permitted wells, applying wells and pending wells

Using the same steps, this spatial analysis was repeated for the 600 foot setback, the 1,000 foot setback and the 1,500 foot setback on producing wells. The 600 foot setback analysis also included permitted wells. None of these setbacks were applied to applying or pending wells.

Visualization

Because the setbacks are difficult to see at the citywide level, the maps created for this project focus roughly on a single block group, where the effects of the various neighborhoods can be seen more easily. The block group with the most producing wells within it was chosen as the study area for mapping. It is important to note that focusing on a particular block group was done purely for ease of visualization. The spatial analysis and findings of this project are for the whole of the City of Fort Worth.

Using Google Earth, the study area was located and a screenshot was made. Using the georeferencing tool, the screenshot was georeferenced with the study area with three reference points at important intersections.

The setbacks are displayed as transparent buffers, so better show the protected use areas and structures that may fall within them. Hospitals and schools are displayed as points, while parks and residential structures are displayed as polygons, because this is was how the data were initially received.

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V. FINDINGS

Enforcement of Current Fort Worth Setbacks

The first part of this analysis looks at how closely Fort Worth monitors and enforces its current gas well ordinance. As detailed in the introduction, the city’s setbacks are two tiered: a 300 foot setback (figure 1) and a 600 foot setback (figure 2). A setback variance (exemption) can be granted from the 600 foot buffer if protected uses within the setback grant waivers to the well operators; however, a well must be a minimum of 300 feet from protected use structures. Note that a gas well legally violates the setback if any portion, however small, of a protected use structure or area falls within the setback.

300 foot setback – absolute minimum allowed

Producing wells with protected use within setback 227 (of 1,766) Permitted wells with protected use within setback 39 (of 253) Pending wells with protected use within setback 0 (of 1) Applying wells with protected use within setback 11 (of 27) Producing wells with residential structure within setback 184 (of 1,766) Producing wells with school within setback 0 (of 1,766) Producing wells with hospital within setback 0 (of 1,766) Producing wells with public park within setback 88 (of 1,766) Residential structures within a producing well setback 252 (of 268,655) Schools within a well setback 0 (of 267) Hospitals within a well setback 0 (of 20) Public parks within a well setback 20 (of 1,102)

Figure 1

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600 foot setback – exemption allowed

Producing wells with protected use within setback 550 (of 1,766) Permitted wells with protected use within setback 96 (of 253) Producing wells with residential structure within setback 486 (of 1,766) Producing wells with school within setback 2 (of 1,766) Producing wells with hospital within setback 0 (of 1,766) Producing wells with public park within setback 203 (of 1,766) Residential structures within a well setback 2,344 (of 268,655) Schools within a well setback 2 (of 267) Hospitals within a well setback 0 (of 20) Public parks within a well setback 58 (of 1,102)

Applying Alternate City Setback Ordinances

The second part of the analysis applies alternate city setback ordinances to the Fort Worth wells to see how many of the wells would receive permits under neighboring cities’ permit regimes. It also analyzes how many protected uses would be considered in unsafe locations under these alternate regulations.

The first alternate setback examined is the Dallas Gas Drilling Task Force’s recommended 1,000 foot setback from protected uses, as shown in figure 3.

Figure 2

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1,000 ft setback–Dallas Task Force recommendation

Producing wells with protected use within setback 897 (of 1,766) Wells with residential structure within setback 774 (of 1,766) Wells with school within setback 31 (of 1,766) Wells with hospital within setback 0 (of 1,766) Wells with public park within setback 276 (of 1,766) Residential structures within a well setback 11,069 (of 268,655) Schools within a well setback 11 (of 267) Hospitals within a well setback 0 (of 20) Public parks within a well setback 132 (of 1,102)

Figure 3

The second alternate setback examined is the Town of Flower Mound’s current setback of 1,500 feet from a protected use, as shown in figure 4.

1,500 foot setback – Flower Mound ordinance Producing wells with protected use within setback 1,131 (of 1,766) Wells with residential structure within setback 1,073 (of 1,766) Wells with school within setback 114 (of 1,766) Wells with hospital within setback 4 (of 1,766) Wells with public park within setback 401 (of 1,766) Residential structures within a well setback 33,690 (of 268,655) Schools within a well setback 38 (of 267) Hospitals within a well setback 1 (of 20) Public parks within a well setback 251 (of 1,102)

Figure 4

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VI. ANALYSIS

Before presenting this analysis, it is important to note that the ‘residential structures’ used for the purposes of this analysis may not all be used as residences, so it is probable that the number of wells in violation of the setbacks is, in reality, lower than the numbers presented in this analysis. This analysis is also not commenting on the actual safety of the residents of Fort Worth. Siting laws are a reflection of a city government’s own thoughts on what is safe – this paper is an analysis of the differences in those siting laws, and whether they are enforced.

As demonstrated in figure 1, 227 of Fort Worth 1,766 producing wells violate the minimum setback requirements established by the city. The city has also issued permits for 39 wells that would violate the 300 foot setback if constructed. Figure 2 shows that 550 of the city’s 1,766 wells – nearly a third – violate the 600 foot setback. For this to be legal, all 2,344 residential structures, two schools and 58 public parks would have had to sign waivers allowing the well operators to get a variance from the 600 foot setback.

From these two figures, it is clear that Fort Worth has not been strict in enforcing its own ordinances for siting of natural gas wells in the city, as over 200 wells violate the absolute minimum setback requirements. Therefore, one of the reasons as to why Fort Worth has so many wells compared to its neighbors may likely be that Fort Worth does not closely monitor or enforce its own drilling ordinance.

The second part of the analysis, which applied the ordinances of neighboring cities, shows that stricter siting regulations would have a dramatic effect on the amount of wells that could receive permits in the city. Under the Dallas task force’s recommended siting ordinance, half of Fort Worth’s 1,700 wells would not have received permits. Under Flower Mound’s ordinance, two thirds of the wells would not have received permits.

One of the underpinnings of these gas well siting laws is safety, and these cities – Fort Worth, Dallas, and Flower Mound – clearly have different ideas about what distance from a natural gas well is safe for their residents and sensitive receptors. According to Flower Mound’s ordinance, 33690 residential structures in Fort Worth are in unsafe locations, along with 38 schools and one hospital.

With natural gas drilling continuing to creep into cities in Texas and around the country, there is clearly a need for more study on the impacts of natural gas wells in urban locations. It begs the question whether our city governments have the resources to

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examine these impacts and make their own decisions, or whether there should be a more comprehensive, statewide law regarding siting and permitting of natural gas wells.

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APPENDIX

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Data Acquisition

Data for Fort Worth land use, building footprints, hospitals, schools, roads, city limits, gas wells and gas leases were obtained through freedom of information requests though the City of Fort Worth’s website, found here: http://mygovhelp.us/fortworthtx/_cs/supporthome.aspx?sSessionID=2CA4EF73184B43109126178F9570C37FEESXYGRX

2010 Census data on Texas county outlines and Tarrant County block groups were obtained through the Texas State Data Center’s website, found here: http://txsdc.utsa.edu/Data/Tiger/2010/Index.aspx

Data Preparation

All files were prepared and projected on the NAD 1983 State Plane Texas North Central FIPS 4202 Feet projected coordinate system.

• The buffer tool was used to create a 300 foot buffer around the producing wells to create the 300 foot setback.

o This step was repeated for permitted wells, applying wells and pending wells.

o This step was repeated, creating a 600 foot buffer, 1000 foot buffer and 1500 foot buffer to create the different setbacks used in the analysis. The 600 foot buffer was also applied to permitted wells.

• The dissolve tool was used to create dissolve the 300 foot buffer and create a new dissolved 300 foot setback layer. This step was repeated for the 600 foot, 1000 foot and 1500 foot setback.

• To create the proxy for residences: o Using the selection tool, all residential land uses (suburban residential,

rural residential, single family, manufactured housing, low density residential, medium density residential, high density residential) were selected from the land use shapefile. These were then exported to a new ‘residential land use’ shapefile.

o The building footprint shapefile was clipped to the residential land use file, creating a new ‘residential structures’ shapefile to serve as a proxy.

• Using the selection tool, public parks were selected from the land use shapefile. The data was then exported to a new ‘public parks’ shapefile.

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Data Analysis

• To find the number of residential structures within the setback: o The 300 foot buffer shapefile was spatially joined to the residential structures

shapefile. This created a new field in the 300 foot buffer shapefile attribute table called Count_. This field contained a count of all of the residential structures that fall (partially or totally) within the setback.

o The intersect tool was used to intersect residential structures and the dissolved 300 foot setback. The intersection gives a count of the number of residences that fall within the setback citywide.

• To find the number of schools and hospitals within the setback: o The 300 foot buffer shapefile was spatially joined to the schools shapefile.

This created a new field in the 300 foot buffer shapefile attribute table called Count_. It contained a count of all of the school that fall within the setback. Looking in the attribute table shows how many wells have a school within 300 feet. This step was repeated for the hospital point data shapefile.

o The intersect tool was used to intersect the schools shapefile to the dissolved 300 foot buffer shapefile. The remaining schools give a count of the number of schools within the 300 foot buffer. Repeat the same of the hospital shapefile.

• To find the number of public parks within the setback: o The 300 foot buffer shapefile was spatially joined to the public parks

shapefile. This created a new field in the 300 foot buffer shapefile attribute table that contained a count of all of parks that fall (partially or totally) within the setback.

o The intersect tool was used to intersect public parks and the dissolved 300 foot setback. The remaining parks give a count of the number of parks that fall with the setback citywide.

These steps for the 300 foot buffer were repeated for permitted wells, applying wells and pending wells.

Using the same steps, this spatial analysis was repeated for the 600 foot setback, the 1,000 foot setback and the 1,500 foot setback on producing wells. The 600 foot setback analysis also included permitted wells. None of these setbacks were applied to applying or pending wells.

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Visualization

The Tarrant County block groups spapefile was spatially joined to the producing wells shapefile. The block group with the most producing wells became the study area, for the purposes of visualizing the setbacks.

Because of the strange shape of the Fort Worth City limits, the study area does not exactly correspond with the block group.

Using Google Earth, the study area was located and a screenshot was made. Using the georeferencing tool, the screenshot was georeferenced with the study area with three reference points at important intersections.

The setbacks were displayed as the semitransparent buffer layers. Houses within the setbacks were displayed as the intersect layer between the buffer and the residential structures. Affected schools were shown as schools that were clipped to the dissolved buffer.

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http://www.arlingtontx.gov/planning/pdf/Gas_Wells/Gas_Drilling_and_Production_Ordinance.pdf

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Fort Worth GIS Data Hospital Locations [computer file]. Fort Worth, Texas: City of Fort Worth,

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