Improving Regulation of Natural Gas Extraction: My Internship Experience at EDF

After seven months of interning at the Environmental Defense Fund (EDF) in their New York City office, I left not only feeling confident that I obtained a new set of professional skills and connections, but also that I took my first step towards impacting state energy policy.  The internship started in June 2012, when I was given a list of project ideas from my supervisor, an EDF toxicologist based in Austin, TX.  However, over the course of the internship, this list morphed from a set of seeming simple tasks into a massive collaborative effort, with occasional lag periods that provided opportunities for me to reach out and participate in additional undertakings throughout the EDF network across the country.

My list of projects initially included creating an interactive virtual map of the laws regulating oil and gas (O&G) development in key producing states in the U.S.  As I combed through the relevant O&G laws state-by-state, I learned the complexity of these regulations and realized that this was not a task I could complete alone.  I reached out to several lawyers on the EDF natural gas team, who agreed that this project would help EDF and others to better understand the O&G development regulatory framework.  We divided the regulations by area of concern—chemical disclosure, waste management, air quality, climate impacts, and community impacts—as defined by EDF’s new natural gas info-graphic, which I helped design during its initial development stages.

I worked with the natural gas team to put together a detailed table of the regulations in the first two of these areas. Coming from the academic world, I was accustomed to submitting a written assignment and receiving feedback within a week or two, at most.   However, over the course of the internship, I realized the need to coordinate work plans with the agendas of my colleagues and soon found additional tasks to complete while EDF’s policy experts reviewed my material.  For example, while an EDF attorney reviewed a draft of my summary of the state-level O&G waste management regulations, an email was sent around that would result in the official presentation of my research in a state agency hearing.

The email asked for help identifying data on the average number of underground sources of drinking water (USDWs) within a given vicinity of an O&G well in Colorado. I quickly responded, explaining that I could easily use graphic information systems (GIS) and simple statistics (abilities obtained through my BCEP coursework) to fulfill their request.  Although I didn’t know it at the time, this information would be necessary to validate the cost-effectiveness of requiring industry to sample and analyze all underground drinking water sources within ½ mile of an O&G well prior to the drilling activity commencement.  Justification of this point would be essential for EDF to make its case in a hearing on a proposed rule change by the Colorado Oil and Gas Conservation Commission (COGCC).

I collected data from CO agency websites and used ArcGIS 10.0 to create maps (see image below) and calculate the number of water sources within ½ mile of 30 randomly selected O&G wells in three major O&G producing areas in CO—the Denver-Julesburg Basin, Piceance Basin, and Greater Wattenberg Area (GWA).  I used STATA to calculate the numerical average and standard error of the datasets, and presented my tabled findings in a neatly written report.  The natural gas team applauded my work and asked that I write an affidavit so that my research could be used in the COGCC hearing.

Although I found between approximately 2 and 6 USDWs on average within ½ mile of an O&G well (and the cost to test each well was estimated by a colleague as relatively minimal compared to overal production costs), the rule that finally passed was insufficient in many ways.  First, it failed to apply to the GWA, which contains more than 25% of Colorado’s O&G producing wells.  In addition, the rule caps the number of required water sources, allows industry to choose the wells to be tested (ignoring up-gradient and down-gradient suggestions from groundwater experts), and failed to dictate how USDW samples would be collected and analyzed.  In the end, although I can’t say that I helped assure the environmental adequacy of this law, I obtained a glimpse of what is required to influence such complex policy and I am proud that my research as an intern made it so far.

This particular experience, as well as working with the natural gas team on a host of other projects, demonstrated the need for meticulous work, but also the importance of speaking up and quickly engaging when the opportunity arises.  With this in mind, I attended several other meetings with state legislative officials and environmental experts.  I learned a great deal by listening to negotiations between experts, industry, and politicians, but also occasionally chimed in where appropriate with the environmental policy knowledge I obtained throughout my graduate experience.

The internship ended January 11, at which point I felt like an integral part of the EDF natural gas team—questions relating to waste management were frequently brought to my attention, given my thesis research and collaboration with EDF on the issue.  Although I still have a master’s thesis to complete and goal to attend law school ahead of me, this experience opened many doors and has brought me one step closer to realizing the type of policy work I hope to conduct by the end of my academic career.

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About Maxine Segarnick