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Transcript of Presented to: By: Date: Federal Aviation Administration Environmental Requirements For Extraction of...
Presented to:
By:
Date:
Federal AviationAdministration
Environmental Requirements
For Extraction of Gas & Oil on Airport Property
35th Annual Airports Conference
Edward Gabsewics, CEP
April 3, 2012
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012
Objective
Provide consistent guidance to sponsors on environmental documentation needed to comply with requirements of all environmental laws
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012 3
OverviewSee Chapter 3. FAA Review Process
Proposed ALP Changes trigger need for environmental review
As with other airport development, sponsor needs to consult with/assist FAA in complying with all environmental laws
Consult your Environmental Protection Specialist (EPS) early
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012 4
Level of Environmental Review / NEPA Documentation
Environmental Assessment likely
Scope and Nature of Proposed On-Airport Operations will dictate extent of environmental review and timeframe for FAA determination
Proposed ALP changes should identify overall infrastructure and type and location of gas & oil operations including individual well heads if known
Include as much detail as possible on well locations to avoid need for supplemental environmental reviews
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012 5
Outline Entire Process Exploration Well Design/Site Prep Drilling Well Construction H20 & Fracturing Fluid Prep & Storage Hydraulic Fracturing Collection, Handling, and Disposal of Flow-Back &
Wastewater Collection of Gas, Processing & Transmission Well Closure Site Reclamation
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012 6
Environmental Risks Each stage of process has associated environmental risks Risks will vary depending on:
- Scope & Nature of Operations
- Geographic Location / Geologic Characteristics of Site Must consider SOPs for each stage Spill Response and Blowout Plans also need to be analyzed
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012 7
What If…A drilling site or other related facility was not addressed in initial NEPA analysis?
A separate environmental analysis must be undertaken and documentation developed for each new drilling site or other facility
Sponsor Action
Airport sponsor must notify FAA asap with proposed location of new well sites or other facilities not previously evaluated
Airport sponsor will need to hold up operations on new development until FAA completes environmental determination
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012 8
Well Closure and Site Reclamation
Must be done in accord with state/local regulatory requirements
Upon closure and site abandonment, Sponsor submits changes to ALP (with reclamation requirements referenced)
NEPA document should have addressed reclamation…BUT…
If conditions at closure/reclamation have changed, FAA may need a new / Supplemental NEPA document
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012 9
State of Environmental Concerns USEPA studies on-going Nationally
USEPA critical of Pennsylvania regs on Marcellus Shale
Debates raging on Fracking impacts to Drinking Water Resources
State of New York still deliberating
Earthquake concerns
Bradford County, Pennsylvania highest number of wells…multi-faceted concerns
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012
Conclusion
Early coordination with FAA on environmental requirements
Refer to FAA Eastern Region Airports Division Sponsor Guide (Updated 11/16/2010) while AC gets finalized
Remember…ALP changes trigger need to address Environmental / NEPA
Provide as much detail as possible to avoid delays
Federal AviationAdministration
35th Annual Airports ConferenceApril 3, 2012
Questions
Harrisburg ADO EPSs
Ed Gabsewics & Susan McDonald
Ed @ 717-730-2832 / Sue @ 717-730-2841