Hayley Scott Address to Shale Insight 2024
The following is a summary of remarks by CNX Chief Risk Officer Hayley Scott on Sept. 25, 2024 at the Shale Insight conference in Erie, PA
September 25, 2024
Today, Pennsylvania is the second largest producer of natural gas in the nation, and perhaps the most politically consequential state in the entire nation as well. And clean, abundant energy plays a key role in our economy and supports our local communities. Taken together, it’s easy to see why we are at the center of the national debate around energy and environmental issues. That fact presents both challenges and opportunities for all of us in this room, and we must rise to the occasion. This will be the focus of my remarks today.
All of us here know how crucial this energy resource is and the many benefits it provides for Pennsylvania, and for society at large – and I know these benefits will be discussed by a number of the speakers later today, so stay tuned for that.
But at the same time, while we continue to invest in this life-sustaining energy, we also need to ensure it is produced responsibly, holding public health and public safety in the highest regard.
Let’s talk for a moment about who we are. CNX Resources has called the Appalachian region home for 160 years. Abraham Lincoln was in the White House when we got our start in a small town in western Maryland. And since that start and across our history, there are two things to know about us that explain why I am here talking to you about this topic today.
First, we are the community, and the community is us. You simply cannot separate CNX or the natural gas industry and the community in Pennsylvania; we share the same DNA. And at CNX, we have a very strong commitment and love for this region. I mentioned how long we have been in this region. Our team lives in these communities. Our kids and our parents breathe the air and drink the water. Our homes are here. The vast majority of us intend to stay here for the rest of our lives. And so, if there is a way to advance the ball when it comes to the natural gas industry, this great commonwealth, and quality of life, you can be 100 percent certain that CNX will be leading the charge.
The second thing to know about CNX is that we have a proud legacy of pioneering the next thing and innovating to a better place. We did it back in the day with coal bed methane capture which laid the foundation for the company we are today. We achieved it in the arena of safety before talking about safety was en vogue. We pivoted into the shale revolution and the Marcellus rush. We are doing it now with the deep Utica and a host of new technologies that have the potential to fundamentally change not just our industry or Pennsylvania but also, frankly, the world. When there is a window to hit the next level of innovation, rest assured that CNX will be first in line to level up.
Circling back to where I began my remarks, most recently we saw an opportunity to innovate and advance the industry and our communities yet again when it comes to this awesome endeavor that is natural gas manufacturing – we call it Radical TransparencyTM.
Radical Transparency is guided by science and provides an unprecedented level of monitoring along with real-time public disclosures (this is a crucial point I will touch on later in greater detail). But before I talk about what Radical Transparency is, let me first talk about why Radical Transparency is necessary.
Pennsylvania has experienced a massive oil and gas boom over the past two decades and many community members have real questions about the public health risks fracking could present. These questions are further fueled by accusations and innuendo from those ideologically or financially opposed to natural gas development who point to ambiguous and suspect statistics that goal-seek to their desired conclusions. This results in policy lines being drawn based on speculation, emotion, fear and ideology instead of objective facts and data.
At CNX we believe this state of play must change – again, there is a massive opportunity in front of us to flip the script.
We also fundamentally believe that public health concerns and resultant public policy created by manufactured fearmongering is an existential threat to our industry. We all watched what happened to the nuclear industry. Environmental groups, government, and yes even elements of the energy industry ganged up on nuclear and even coal, primarily based on fearmongering. We cannot and must not allow the same thing to happen to this critical industry.
We’ve tried the softer approach – industry-funded studies, positive messaging campaigns, you name it – and none of it has countered the agitation and innuendo about public health. Incidentally, the recent events in Cecil Township in southwestern Pennsylvania give us all a concerning glimpse into the future. If the natural gas industry continues to employ the same safe playbook, the first thing that dies is truth, facts, and logic. Once those die, the industry itself won’t be far behind. Let’s be honest with ourselves, we still have this massive overhang tied to public health, and it’s not going to go away on its own. If the current trajectory continues, the people in this room will be the next nuclear or coal industry. Fundamentally, this is what Radical Transparency is all about.
We all want to do everything we can to keep our communities (which includes us) safe. And that starts with collecting more facts and more data, and perhaps most importantly, disclosing it in real time, so that we can clearly display that the industry has the necessary protections in place. We must do this to protect energy jobs and the important role the energy industry plays in society. We must prove definitively that it is a false choice between projecting jobs and the environment – we can do both - and at CNX through our Radical Transparency measured data to-date, we’ve shown that energy production and environmental and public health protection can and do coexist, despite the vitriol you’ve seen from the environmental groups over the program.
Yes, we’ve seen all the public statements, social media posts, and environmental media articles denouncing CNX and the program. We hear you. Our call in return is to come to the table in good faith. If you have ideas to make the program better and help provide residents the answers they deserve, we’re all ears. Shutting the program down is not an option, so let’s bootstrap it and make it better. We want to arrive at the truth, whatever that may be. Our hope is that regional environmental groups and activists share the same goal; however, that answer will be ascertained from their actions.
Now, what does Radical Transparency mean? It means:
- We are monitoring air and water quality, waste, and methane in and around our operations.
- We are open sourcing data for all to see in real time. This is critical. We can’t continue to hold our data in a black box and release it on our terms to a limited audience.
- The data is collected independently by an accredited third party.
- And the PADEP is provided this data unabridged at the same time as it is provided to CNX – this provides further transparency and confidence to the public in its reliability.
- Without the real time transparency at the heart of our program, the data will always be questioned and dismissed. We must change course from our past practices.
Ten months since we began this program, it’s hard for us to understand how everyone in the industry could not be part of this. We have to set ideology, personal political preferences, short term political goals, personal agendas, and petty industry squabbles to the side and see the existential threat and our moral obligation for what it is. Radical Transparency is our moral and fiduciary obligation to our owners, our employees, and our communities. More data and more sites are the prerequisites to definitive success and making fearmongering forever obsolete.
In place of endless speculation and dueling rhetoric, we change this paradigm by open-sourcing facts and data to all stakeholders and creating mutual trust which can serve as the basis for cooperation and real environmental and economic progress.
So, let’s take a deep dive into what have we seen since we started our Radical Transparency program in November of last year.
As of August 1st, 2024, over 101,000 data measurements had been collected and reported to PADEP and posted on our Radical Transparency website. That tally grows by the hour, daily.
This data is collected by and reviewed for quality assurance by an independent accredited third party, Clean Air Engineering. CleanAir will be presenting the scientific and technical details of how the data collection was set up, so if you are interested in hearing more about that please attend their breakout session tomorrow.
The collected air quality data shows that even at just 500 feet from the wellbore, unconventional natural gas well development and production add little to no fine particulate matter contribution to local air quality, regardless of the activity occurring on the well pad.
The results demonstrate that emissions from CNX's responsible natural gas development fall well below science-based air quality standards that are designed to protect the public from negative health effects resulting from emission of PM2.5 (associated with asthma) or the BTEX Volatile Organic Compounds (associated with cancer).
There have been no sustained levels of any significance of PM2.5 or BTEX at these sites during any phase of development.
PM2.5 concentrations were (i) below the EPA’s National Ambient Air Quality Standards at all sites and (ii) well below levels observed within regional urban environments.
Measured concentrations of BTEX are trivial and well below Department of Health minimum risk levels for inhalation exposures at all sites.
Throughout the sample period, CNX trended the measured data points against those from the closest PADEP regional air quality monitoring sites. Concentrations we measured trended well with the PADEP regional monitor readings.
Our region includes the Pittsburgh metropolitan area, and begs the question, if well drilling and production PM2.5 concentrations compare well with background measurements from the closest rurally located PADEP monitors, how do concentrations compare to urban areas? To answer this, we compared the measurements taken 500 feet from shale gas development activities to the measurements collected in the Pittsburgh neighborhood of Lawrenceville, which is the site of the Allegheny County Health Department Air Quality Program offices and serves as a monitoring site for PM2.5 and other pollutants. The Lawrenceville measurement station is positioned near the geographic center of Allegheny County. It is 36 miles northeast of our measured well pad and only five city blocks from the Children’s Hospital of Pittsburgh.
Overall, PM2.5 concentrations at the well sites are consistently lower than the urban Lawrenceville measurements.
BTEX readings from the well sites were also compared to results from the Allegheny County Health Department Lawrenceville site. BTEX results from the well pads were negligible, with only Benzene presenting any results to register at a minimum reporting limit. The results from Allegheny County Health Department Lawrenceville are markedly different. The urban setting where there is no natural gas development, but with much higher traffic volumes exposed its denser population to inhalable concentrations of benzene that were 10 to 30 times greater than those encountered near the well pads. Either we truly care about public health and want real answers to our actual challenges, or we don’t. If we don’t care and continue to fail to acknowledge and address the real root cause of these issues, then all the advocacy against our industry is simply a political means to a political end, using our neighbors as political pawns.
CNX will continue to monitor its operating sites through all phases of development and 6 months post production, and we will expand the number of well pads and midstream stations as our operations progress. Currently, we are reporting air quality monitoring at 11 unconventional gas well pads and 3 compressor stations, a number which will grow until the Radical Transparency program covers all unconventional CNX operations.
We also intend to supplement the scope of data that we are collecting and transparently sharing as the program matures.
Our methane disclosures are also very transparent with unprecedented detail and timeliness of information. Our public website has lots of information about our emissions reduction program and our diligent work to reduce methane emissions through innovative facility design, improvements in operational practices and procedures, advancements in detecting and measuring emissions and improved accuracy in emissions reporting. One way that we reduce our methane emissions is through our comprehensive leak detection and repair or LDAR program. If there is an unintended leak, we want to quickly identify and repair it to limit the release of methane.
The interactive graph we added to our methane monitoring page shows you details about our LDAR program including how many repairs we had to make, how long the leaks lasted, how often we are monitoring, and even the location and component that was leaking. These charts are updated monthly so that there is transparent and timely data provided to all of our stakeholders.
At CNX, we are a low methane intensity natural gas producer in the lowest methane intensity basin in the United States, but we don’t stop there – we are continuously working to reduce methane emissions and enhance transparent disclosures – we are producing the most responsibly sourced natural gas molecule anywhere in the world right here in Pennsylvania.
In addition to air quality data, we are also providing water quality, chemical, and waste transparent disclosures.
We expanded and improved upon the disclosure of chemical additives used in our process. Under the current regulatory requirements, we report the ingredients of hydraulic fracturing fluids we utilize through the FracFocus chemical disclosure registry. But we have expanded and improved these disclosures and now provide fluid formulations for drilling and completions ahead of their use on our website.
And very importantly, our service partners have joined us in our Radical Transparency program and where they previously had several chemicals with components listed as "proprietary" or “trade secret” we are now transparently disclosing all chemical components.
For water quality, under current guidelines and industry practice, operators typically collect one groundwater sample to determine baseline conditions prior to natural gas development activity commencement. CNX has committed to a much more comprehensive water quality monitoring program:
- We expanded pre-drill water surveys for private residential drinking water supplies to within 2,500 ft of a vertical unconventional well bore, centralized large volume storage tank battery, or centralized impoundment.
- The pre-drill survey includes at least four samples taken quarterly ahead of drilling activity to obtain a more comprehensive understanding of groundwater quality ahead of natural gas activity. Private residents can opt-in to public disclosure of the water test results on our website.
- After well turn-in-line, at least four samples taken quarterly are collected and compared to pre-drill conditions, with the same election options for public disclosure.
- In addition to the pre- and post-drill samples, operators collect similar pre- and post-drill seasonal upgradient and downgradient samples of the nearest streams receiving surface run-off.
In addition to transparent disclosures, we are also collaborating with PADEP to provide the department with unprecedented access to two future, to-be-constructed CNX well sites, allowing for in-depth independent monitoring of the air emissions at both locations before, during, and after the development of the new wells – this is critical in confirming the results of the daily monitoring program as well.
This unprecedented brand of transparency is good – good for residents’ health, good for the industry worker, good for economic development, good for energy security, good for the environment, and good for community investment.
But the ultimate measure of success will be Radical Transparency becoming the norm or the standard across the basin and hopefully beyond. If it isn’t, it will be a failure of everyone in this room and a missed opportunity with potentially catastrophic consequences for all stakeholders.
I’m here today to implore you to join us, help us, improve the program.
We also implore regulators and policymakers to follow the measured data, which is indicating that there may be no need for restrictions that go beyond what is already one of the most robust regulatory regimes in the entire nation. The data should dictate policy, not ideology. If people in communities are getting sick, its incumbent on us, state government, academia, and environmental groups to get to the bottom of it and provide affected families with real answers. Simply blaming it on the natural gas industry may be the easy political answer, but don’t those individuals and families deserve more from all of us? Don’t they deserve real answers? Why are cancer rates higher in Canonsburg, PA? Why are asthma rates higher in disadvantaged urban communities? Is it the natural gas industry or are there other factors at play that no one has the will or political courage to discuss? At CNX, we demand answers and we’re determined to find them. But those families are the ones who truly deserve answers, and the system is failing them each and every day.
Any future studies by any entity or organization should now reference actual data – not loose statistics molded to infer vague associations.
This is historic. We are doing something unprecedented with what is currently the lowest life cycle carbon intensive energy source in the world: Pennsylvanian and Appalachian natural gas.
And I’ll circle back to two final points as I conclude.
First, when you are the tip of the spear, it comes with both opportunity and responsibility. We are learning a lot with Radical Transparency. When we see something unexpected or atypical, we are prepared and committed to acting in a way where we engineer and design our way to even better performance. Radical Transparency and the data it provides will inevitably make the process of natural gas manufacturing better. It is a catalyst for continuous improvement.
And second, it is imperative for us in this industry to be able to use Radical Transparency to make the rhetoric, speculation, and sensational headlines obsolete – to definitively confirm for all stakeholders that there are no adverse human health issues related to responsible natural gas development. To confirm what we already know: that the natural gas industry is essential, responsible, and inherently good for society.
We call on government, media, academia and environmental groups to follow the data, let the data dictate policy, and provide affected families with the truth.
And most fundamentally, we call on industry to join us in these efforts. It’s our responsibility to address these health concerns, no one else. If those of us in this room fail in this effort, the effects will be felt by many more than those here this morning – this is much bigger than us and CNX is committed to seeing this through for all of us.
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