Navigating EPA’s Climate and Environmental Justice resources and grant programs.
The U.S. Environmental Protection Agency (EPA) recently announced the launch of the Community, Equity & Resiliency initiative to help communities navigate funding opportunities. EPA’s Office of Air and Radiation and Office of Environmental Justice and External Civil Rights are facilitating community-driven partnerships and providing a place for communities to learn, network, and cultivate ideas on how to access the resources, especially in low-income and disadvantaged communities.
Climate and Environmental Justice Resources
EPA will host live virtual and in-person events, including panel discussions and fireside chats featuring environmental leaders and their peers, to help community-based organizations, community partners, and potential grant applicants navigate funding opportunities. These engagements are designed to spark ideas on taking advantage of Investing in America programs while considering each community’s unique context when confronting the climate crisis and advancing environmental and climate justice.
Website
EPA’s new Community, Equity & Resiliency website offers information on multiple funding opportunities and resources to ensure community-driven partnerships can inspire meaningful change in their communities.
On Monday, November 6, 2023, EPA will kick off the Community, Equity & Resiliency initiative with a National Virtual Open House that is open to the public. This six-day event will include a series of virtual panels and fireside chats featuring prominent environmental leaders and peers discussing their ideas to overcome environmental pollution and climate change challenges through funding opportunities that are now available. Panel and fireside chat topics will include climate change in rural communities, green jobs, electric vehicle infrastructure, technical assistance, and more.
Starting this winter, EPA will host in-person, community-based Regional Roadshow events. These will provide opportunities for community leaders to develop or leverage existing community-based partnerships and dream and cultivate ideas on the Inflation Reduction Act and other new Investing in America programs. More details on the Regional Roadshow will be available soon.
We’ll keep you posted, and as always, we’re here to help your community meet its social, economic, and environmental goals – sustainably. Find us at www.scsengineers.com.
One of many unplugged wells is shown here, which presents several environmental hazards, such as surface water or groundwater contamination, and the potential for greenhouse gas emissions.
Pennsylvania has a problem. A $2 billion problem.
From 2005 to 2015, I managed the plugging of nearly 1,000 wells in Pennsylvania, New York, and West Virginia. Many of the wells were old wells open to the atmosphere, leaking water, gas, or oil. My research indicated one firm had drilled tens of thousands of wells until the 1990s. Responsible companies like Shell Oil Company plugged many of the wells during my tenure after they learned they had acquired old wells through land transactions.
Many more wells were abandoned or orphaned for every responsibly plugged well.
Drake Property, Bradford, PA, 1940
The Pennsylvania Department of Environmental Protection (PADEP) stated there are nearly 27,000 abandoned and orphaned wells on the state and private property. PADEP estimates it will cost $1.8 billion to plug the known wells. In addition, there may be as many as 200,000 unaccounted wells. Large and smaller operators abandoned many of these wells 50-100 years ago. By 1880, 4,000 wells were producing in the Bradford Oil District alone, yielding 50,000 barrels of oil daily. Oil City had 2,000 wells along the shores of the Allegheny River. In the 1940s, the Drake property near Bradford, Pennsylvania, had over 800 wells on 1,200 acres. Many of these wells had since been abandoned or orphaned.
The abandoned/orphaned wells present several potential problems: surface water contamination, groundwater, or drinking water; methane migration to water wells or basements; hazardous air pollutants and greenhouse gas (GHG) emissions; and open holes.
Why have so many operators abandoned their wells without plugging them? And why are wells not properly plugged? The answers are multifaceted.
Loss of ownership. According to regulations, the last entity to receive economic benefit from the well is responsible for plugging the well. However, if the last entity is economically unable to plug the well, the responsibility falls on the prior owner or operator. Orphan wells, in most cases, have long lost ownership through death, bankruptcy, or abandonment.
Inadequate plugging. In the early days, regulation of the oil and gas industry was motivated by the need to protect the oil and gas resources and not the environment. Many wells before the 1950s were either not plugged or plugged with little cement. Often tree stumps, brush, wood, and rocks, with a sack of cement thrown in, were used to plug wells. Even wells plugged in the 1950s and 1960s are not adequately plugged. When cleaning out old wells, we found junk in the hole like a deer skull, tools, brush, wireline, and trash.
Loss of surface casing. During World War II, steel was in short supply, so people pulled the surface casings and sold them. In some cases, leaving behind a hole big enough to swallow a man.
The process of plugging a well can be a daunting task and expensive undertaking.
Funding and Grant Programs
To address these environmental and safety issues, on November 15, 2021, the federal government enacted the Bipartisan Infrastructure Law, which allocated $4.7 billion to create a new federal program to address orphan wells. Nearly every state with documented orphaned wells submitted a Notice of Intent (NOI) indicating interest in applying for a formula grant to fund the proper closure and cleanup of orphaned wells and well sites.
Pennsylvania applied for and has received an initial grant of $25 million. The state applied for and received a Phase One Formula Grant of $79 million and is eligible for an additional $315 million Performance Grant in future years. The law also provides a separate $500 million program for the remediation of orphan wells on federal land, which the Department of the Interior (DOI) Bureau of Land Management will implement.
Pennsylvania Act 136 of 2022 (Act of November 3, 2022, P.L. 1987, No. 136 Cl. 58 – OIL AND GAS) became effective January 3, 2023. This legislation amends Title 58 (Oil and Gas) of the Pennsylvania Consolidated Statutes to provide a mechanism for using grant money. It provides $40,000 for every eligible orphan well plugged with a depth of 3,000 feet or less or the actual cost of the qualified well plugger to plug the well, whichever is less. The Statutes also provide $70,000 for every eligible orphan well plugged at a depth greater than 3,000 feet or the actual cost of plugging, whichever is less.
In the event the qualified well plugger encounters unusual technical difficulties due to the condition of an orphan well, the department may, at its discretion, amend the grant award to cover the additional cost, with adequate documentation of those unexpected additional costs, if it doesn’t exceed the amount of the grant for a specific orphan well.
Success in managing this pressing issue requires dedicated effort and expertise from environmental professionals, in addition to government funding, who consider these factors:
Ownership due diligence. Researching ownership through title and tax records.
Engineering services. Engineering services for managing all the non-drilling and permitting required to protect human health and the environment.
Locating abandoned wells using historical documents, maps, GIS/GPS, site walks, magnetometer, and physical uncovering by excavation. On a 100-acre property, wells could be spaced at 200-foot intervals, leading to nearly 100 wells on just one property. Usually, a few scattered single wells drilled earlier could be found. Sites with hundreds of wells require significant time to locate and evaluate their environmental impact.
Shale drilling. In areas where unconventional shale-gas reservoirs are under development, plugging of older wells has become an issue due to the potential for stray gas to migrate from the shale formation to other formations that are open to the old wells in the area. The old wells can transmit gas from the formation to freshwater or even the surface, posing an environmental risk to the local area. Older wells are a risk if they are inadequately plugged or not plugged across the shale production zone.
Type of well. All current orphan wells are conventional wells, either gas, oil, or a combination. The type of well and the condition must be identified and evaluated. Does it have an open casing? Casing size? Gaping hole? Casing, rods, and tubing? Damaged or broken tubing/casing? Wood casing? Are there tanks and pipelines?
Methane qualification. One of the considerations for obtaining grant money is methane quantification. Methane emissions monitoring before and after plugging the well is required to determine the net GHG reductions for wells.
Access issues. Landowners, permits for stream crossings, permits for wetland areas, traffic considerations, and highway occupancy permits.
And finally, there is site remediation and cleanup.
Where there are challenges, there are opportunities.
The investments to plug and remediate abandoned and orphaned wells create jobs, advance economic growth, reduce hazards, and greatly reduce GHG emissions to meet carbon reduction goals.
The process requires close coordination between the state, geologists, environmental engineers, and drillers. All are benefactors, and beneficiaries, along with the general public and the environment.
About the Author:David Palmerton, PG, has extensive experience in environmental site assessment remediation, due diligence, and construction quality control. His experience includes consulting services to large commercial, industrial, and academic entities. He has also provided litigation support. He has managed the closure of large oil fields, plugged over 1,000 oil and gas wells, deconstructed oil and gas pipelines and facilities, and performed remediation of petroleum contaminated soil and groundwater.
EPA anticipates awarding a total of 73 Cleanup Grants for an estimated $60 million. Fund your Brownfields projects.
The FY 2023 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Grant Guidelines are now available (go to Open Solicitations). The application submission deadline is November 22, 2022.
Cleanup Grants provide funding to carry out cleanup activities at brownfield sites owned by the applicant. An applicant may only submit ONE Cleanup Grant application in the FY23 competition cycle.
FUNDING/AWARDS: EPA anticipates awarding a total estimated 73 Cleanup Grants for an estimated total of $60 million
Up to $500,000 to clean up one brownfield site or to allocate up to $500,000 among multiple sites;
Between $500,001 and $1,000,000 to clean up one brownfield site or to allocate among multiple sites; or
Between $1,000,001 and $2,000,000 to clean up one brownfield site or to allocate among multiple sites.
Brownfields Assessment Grants
Assessment Grants provide funding for developing inventories of brownfield sites, prioritizing sites, conducting community involvement activities, conducting planning, conducting site assessments4, developing site-specific cleanup plans, and developing reuse plans related to brownfield sites. A portion of the Assessment Grant funding must be used to conduct site assessments. Assessment Grant funds may not be used to conduct cleanup activities.
Coalition Assessment Grants
FUNDING/AWARDS: EPA anticipates awarding an estimated 20 Assessment Coalition Grants for an estimated total of $20 million
Community-Wide Assessment Grants for States and Tribes
FUNDING/AWARDS: EPA anticipates awarding an estimated 17 Community-wide Assessment Grants for States and Tribes for an estimated total of $35 million
Community-Wide Assessment Grants
FUNDING/AWARDS: EPA anticipates awarding an estimated 61 Community-wide Assessment Grants for an estimated total of $30.5 million
Brownfields Multipurpose Grants
A Multipurpose Grant is appropriate for communities that have identified, through community engagement efforts, a discrete area (such as a neighborhood, a number of neighboring towns, a district, a corridor, a shared planning area, or a census tract) with one or more brownfield sites. Multipurpose Grants provide funding to carry out a range of eligible assessment and cleanup activities, including planning and additional community engagement activities. Applicants can apply for funding up to $800,000 per grant under this solicitation.
FUNDING/AWARDS: EPA anticipates awarding an estimated 17 Multipurpose Grants for an estimated $800,000 per grant
Brownfields Revolving Loan Fund Grants
Revolving Loan Fund (RLF) Grants provide funding to a grant recipient to capitalize an RLF program. RLF programs provide loans and subgrants to eligible entities to carry out cleanup activities at brownfield sites contaminated with hazardous substances4 and/or petroleum5. Site eligibility will be determined by EPA after grant award and prior to expending grant funds at any site. Sites where hazardous substances and petroleum contamination are distinguishable must meet eligibility requirements for both contaminants.
FUNDING/AWARDS: EPA anticipates awarding an estimated 10 RLF Grants for an estimated total of $10 million
SCS Engineers has a successful track record supporting communities interested in land recycling and obtaining EPA Brownfields grants. Please visit our website for more information.
EPA anticipates awarding a total of 73 Cleanup Grants for an estimated $60 million. Fund your Brownfields projects.
The FY 2023 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Grant Guidelines are now available (go to Open Solicitations). The application submission deadline is November 22, 2022.
Cleanup Grants provide funding to carry out cleanup activities at brownfield sites owned by the applicant. An applicant may only submit ONE Cleanup Grant application in the FY23 competition cycle.
FUNDING/AWARDS: EPA anticipates awarding a total estimated 73 Cleanup Grants for an estimated total of $60 million
Up to $500,000 to clean up one brownfield site or to allocate up to $500,000 among multiple sites;
Between $500,001 and $1,000,000 to clean up one brownfield site or to allocate among multiple sites; or
Between $1,000,001 and $2,000,000 to clean up one brownfield site or to allocate among multiple sites.
Brownfields Assessment Grants
Assessment Grants provide funding for developing inventories of brownfield sites, prioritizing sites, conducting community involvement activities, conducting planning, conducting site assessments4, developing site-specific cleanup plans, and developing reuse plans related to brownfield sites. A portion of the Assessment Grant funding must be used to conduct site assessments. Assessment Grant funds may not be used to conduct cleanup activities.
Coalition Assessment Grants
FUNDING/AWARDS: EPA anticipates awarding an estimated 20 Assessment Coalition Grants for an estimated total of $20 million
Community-Wide Assessment Grants for States and Tribes
FUNDING/AWARDS: EPA anticipates awarding an estimated 17 Community-wide Assessment Grants for States and Tribes for an estimated total of $35 million
Community-Wide Assessment Grants
FUNDING/AWARDS: EPA anticipates awarding an estimated 61 Community-wide Assessment Grants for an estimated total of $30.5 million
Brownfields Multipurpose Grants
A Multipurpose Grant is appropriate for communities that have identified, through community engagement efforts, a discrete area (such as a neighborhood, a number of neighboring towns, a district, a corridor, a shared planning area, or a census tract) with one or more brownfield sites. Multipurpose Grants provide funding to carry out a range of eligible assessment and cleanup activities, including planning and additional community engagement activities. Applicants can apply for funding up to $800,000 per grant under this solicitation.
FUNDING/AWARDS: EPA anticipates awarding an estimated 17 Multipurpose Grants for an estimated $800,000 per grant
Brownfields Revolving Loan Fund Grants
Revolving Loan Fund (RLF) Grants provide funding to a grant recipient to capitalize an RLF program. RLF programs provide loans and subgrants to eligible entities to carry out cleanup activities at brownfield sites contaminated with hazardous substances4 and/or petroleum5. Site eligibility will be determined by EPA after grant award and prior to expending grant funds at any site. Sites where hazardous substances and petroleum contamination are distinguishable must meet eligibility requirements for both contaminants.
FUNDING/AWARDS: EPA anticipates awarding an estimated 10 RLF Grants for an estimated total of $10 million
SCS Engineers has a successful track record supporting communities interested in land recycling and obtaining EPA MARC Brownfields grants. Please visit our website for more information.
Inadequate plugging. In the early days, regulation of the oil and gas industry was motivated by the need to protect the oil and gas resources and not the environment. Many wells before the 1950s were either not plugged or plugged with little cement. Often tree stumps, brush, wood, and rocks, with a sack of cement thrown in, were used to plug wells. Even wells plugged in the 1950s and 1960s are not adequately plugged. When cleaning out old wells, we found junk in the hole like a deer skull, tools, brush, wireline, and trash.
