Disclosing the Facts:

Transparency and Risk in Hydraulic Fracturing Operations

Previous editions: 20172016201520142013

Disclosing the Facts 2015

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Disclosing the Facts 2015 is the fourth in a series of investor reports intended to promote improved operating practices among oil and gas companies engaged in horizontal drilling and hydraulic fracturing. Hydraulic fracturing operations often use toxic chemicals and high volumes of water, release significant levels of greenhouse gases and other pollutants, and have the potential to adversely impact local communities when not properly managed. These issues translate into financial risks to companies and shareholders in the form of fines, regulations, or threats to companies’ social license to operate.

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Following the maxim of “what gets measured, gets managed”, this report encourages oil and gas companies to increase disclosure about their use of current best practices to minimize the environmental risks and community impacts of their “fracking” activities. Disclosure of best management practices and associated key performance indicators is the primary means by which investors gauge how companies are managing the business risks associated with their environmental and community impacts. Disclosure helps both investors and other stakeholders determine whether companies have the systems in place to minimize the community and environmental risks of their operations.

This 2015 scorecard benchmarks the public disclosures of 30 companies on 39 key performance indicators. It distinguishes companies disclosing more about practices and impacts from those disclosing less. The scorecard assesses five areas of environmental, social, and governance metrics emphasizing, on a play-by-play basis, quantitative disclosures for: (1) Toxic chemicals; (2) Water and waste management; (3) Air emissions; (4) Community impacts; and (5) Management accountability. It relies solely on publicly available information companies provide on their websites or in corporate financial statements or other reports linked from their websites.

This year, the report card has been compiled amidst a dramatic contraction of well drilling and completion activities and enormous financial write-offs. In this operating environment, companies might be tempted to slow disclosure efforts and perhaps even cut corners on best practices. However, this year’s scorecard results show that corporate disclosure efforts have increased among a core group of industry disclosure leaders and even some companies that have been disclosure laggards. Companies continue to pursue operating innovations that not only save money but also yield environmental benefits. These include, for example, substituting pipelines for trucks to move water and waste water, enhancing leak detection and repair efforts, and using less, but safer and more cost-effective chemicals.

Yet, while progress has been made, much more remains to be done. For instance, the industry as a whole must improve its localized disclosures since companies’ social license to operate is often determined by local concerns and perceptions of corporate responsiveness. Local impacts can include land and water use, air and water pollution, and nuisances such as noise, light pollution, traffic, and road damage. Progress must also continue on issues such as reducing chemical toxicity, setting goals for reducing methane and other air emissions, and identifying local community concerns and company responses.

Key Findings

  1. BHP Billiton stands out as the disclosure leader. BHP Billiton scored 32 out of a possible 39 points. BHP Billiton’s disclosure scores follow a trajectory that investors hope a growing number of companies will emulate. The company ranked near the bottom of the industry in disclosure in the 2013 edition of Disclosing the Facts, raced to the top in 2014, and further outdistanced even other improving companies in 2015. Through its score, the company demonstrates that it has been putting systems in place to track data and increase disclosures. Its swift ascent from the bottom of the 2013 scorecard confirms investors’ view that at least some of the companies that are disclosure laggards may in fact have good policies, practices, and data systems in place, but are not revealing them. BHP Billiton’s website features a case study of its fracturing operations, written to the Disclosing the Facts scorecard outline and addressing investor concerns in a concise, readily accessible manner.
  2. Hess, Apache, Noble Energy, and CONSOL Energy comprise a core of disclosure leadership companies outpacing the rest of the industry, with Southwestern Energy, Anadarko Petroleum, QEP Resources, and EQT slightly behind. Hess, Apache, and Noble built on their leadership positions from 2014, disclosing information for about half of the scorecard indicators. CONSOL nearly quadrupled its 2014 score, largely by securing third-party certification for compliance with the best practice standards of the Center for Sustainable Shale Development (CSSD). Many of its standards match scorecard practices. Southwestern Energy, following in BHP Billiton’s path, moved from near the bottom of the scorecard to join the leadership group. The company accomplished this leap by incorporating the scorecard in the development of its inaugural corporate sustainability report. By nearly doubling its score in 2015, Anadarko narrowed its gap with the leaders. QEP Resources, like Southwestern Energy, significantly improved its score, moving up from near the bottom of the industry in 2014. EQT’s score dropped slightly from 2014 but the company remains ahead of most of the industry.
  3. Most of the industry — 70 percent of the companies assessed—continue to leave investors substantially in the dark about their policies, practices, and impacts, especially on a quantitative play-by-play basis. These companies disclose from zero to 28 percent on the scorecard indicators. Some companies that scaled back on reporting, or failed to update their disclosures, lost points. Some companies have good quantitative disclosures for individual shale plays, or informative narrative disclosures across their entire operations, but fail to provide sufficient, quantitative, play-by-play disclosure for each of their major plays. Carrizo Oil & Gas, Continental Resources, and Whiting Petroleum are the lowest scorers, with Carrizo earning zero points.
  4. Broad policies, not play-by-play quantitative performance metrics, remain the most commonly reported indicators. The scorecard includes a mix of quantitative indicators and non-quantitative best practice indicators. Since the initial scorecard in 2013, scores have increased by five or more points on about 40% of the original indicators, primarily the non-quantitative ones. The five most widely reported indicators include: substituting pipelines for trucks to transport water for fracturing (23 companies); declaring a practice to use non-potable water instead of fresh water for fracturing whenever feasible (19 companies); avoiding use of diesel fuel in hydraulic fracturing fluids (16 companies); relying on independent third-party databases to screen potential contractors (16 companies); and linking compensation of senior management to health, safety, and environment metrics (15 companies). The three most significant scoring changes on indicators between 2014 and 2015 were for: play-by-play reporting of the types of water sources used for fracturing activities (from 1 to 6 companies); percentages of wastewater reused for fracturing (from 2 to 7); and addressing naturally occurring radioactive materials (NORMs) (from 6 to 12).


The rising scores of leadership companies, a trend that began with the second edition of Disclosing the Facts in 2014, show that, at least for a segment of the oil and gas industry, the scorecard is having its desired effect of triggering a “race to the top” in improved disclosure.

As the scoring leader, BHP Billiton has demonstrated that companies can tell their story concisely and in a fashion readily accessible to investors and other stakeholders. Such information is critical to investors who seek clear data on which to base investment decisions, especially in an industry that is facing tremendous challenges, including the most basic challenge of retaining a social license to operate. Through this scorecard, investors seek to encourage the entire industry to implement current best management practices, to report on those practices, and to provide quantitative indicators of success in reducing impacts.

While significant improvement in reporting has been seen in a handful of companies, 70 percent of the companies assessed still score below 28 percent on scorecard indicators. Companies continue to miss opportunities to address issues of public concern that feature prominently in media reports and activist advocacy critical of the industry. These issues include, for example, use of diesel fuel in fracturing fluids, radioactive waste, and induced seismicity (earthquakes). Diesel fuel does not appear to be widely used in fracturing fluids, yet many companies are silent on whether they have a policy to avoid it. Naturally occurring radioactive material waste has surfaced as an issue, especially in Pennsylvania and North Dakota, but few companies discuss straightforward procedures for reducing radioactivity risks. Additionally, while companies increasingly acknowledge induced seismicity as a risk, they often fail to discuss the specific steps they are taking to manage the hazard.

The failure of the majority of the largest oil and gas companies to either adopt current best management practices or to report on their adoption is a continuing challenge requiring ongoing engagement by investors.


Companies should report data associated with their operational impacts using quantitative metrics, on a play-by-play basis, in order for investors to be able to rigorously assess company practices. In particular:

  1. Companies should disclose their leak detection and repair programs for methane emissions, providing information on program scope (percentage of facilities/assets covered), technologies deployed, frequency of inspection, and results.
  2. Companies should develop systems to track community concerns and corporate responses and provide such information to senior management, corporate boards of directors, investors, and other stakeholders.
  3. Companies not using diesel or BTEX chemicals in their fracturing fluids should disclose this, and companies not relying on their own toxicity scoring systems should draw on those of their principal chemical suppliers to report progress in reducing toxicity of fracturing fluids.
  4. Naturally occurring radioactive material waste has been a high-profile issue, especially in Pennsylvania and North Dakota. Companies operating in those states in particular should disclose what steps, if any, they take to measure, track, and assure appropriate disposal of contaminated materials.
  5. Seismicity has been a high-profile issue in Oklahoma, Texas, Arkansas, and Ohio. Companies operating in those states in particular should disclose what steps they take, consistent with and beyond applicable state regulations, to reduce the risk of inducing seismic events, including implementing precautionary practices for their own drilling, completion, and disposal operations and assuring sound practices by their waste disposal contractors.
  6. Companies should employ a wide range of tools for avoiding groundwater contamination, including assessing and monitoring adjacent wells, identifying existing faults and fractures, and testing ground water before and after drilling to further reduce the potential for contamination and to detect and remedy any contamination that does occur.
  7. In addition to enhancing their reporting,

  8. Companies should link executive compensation to corporate performance on health, safety, and environmental indicators, and should incorporate metrics beyond the injury and spill data which are most commonly relied on in such linked compensation systems. Additional metrics might include, for example, measures to reduce companies’ environmental impact, such as implementation of leak detection and repair programs and progress towards greenhouse gas reduction goals.
  9. Government agencies and the oil and gas industry should work together to develop more systematic research and data on the human health effects (including worker health) of hydraulic fracturing operations. This might follow the model of the U.S. government and the automobile industry agreeing on creation of the Health Effects Institute to produce credible, broadly accepted research on the health effects of air pollution.


These tables contain the score breakdown for each company by indicator. A checkmark means the company earned a point for that metric.

Company Total Scores

BHP Billiton, Ltd. (BHP)3218
Hess Corp. (HES)2117
Apache Corp. (APA)2013
CONSOL Energy, Inc. (CNX)195
Noble Energy, Inc. (NBL)1913
Southwestern Energy Co. (SWN)162
Anadarko Petroleum Corp. (APC)158
QEP Resources, Inc. (QEP)151
EQT Corp. (EQT)1416
ConocoPhillips Corp. (COP)115
Range Resources Corp. (RRC)119
Royal Dutch Shell plc (RDS)119
Occidental Petroleum Corp. (OXY)107
Penn Virginia Corp. (PVA)109
BP plc (BP)86
Cabot Oil & Gas Corp. (COG)88
Encana Corp. (ECA)815
EOG Resources, Inc. (EOG)89
Devon Energy Corp. (DVN)75
Exco Resources, Inc.(XCO)77
Newfield Exploration Co. (NFX)64
Chesapeake Energy Corp. (CHK)47
Chevron Corp. (CVX)46
Exxon Mobil Corp. (XOM)45
Pioneer Natural Resources** (PXD)3-
Ultra Petroleum Corp. (UPL)39
WPX Energy, Inc. (WPX)33
Continental Resources, Inc. (CLR)20
Whiting Petroleum Corp. (WLL)23
Carrizo Oil & Gas, Inc. (CRZO)00

* 2015 had a total of 39 possible points. 2014 had a total of 35 possible points.

** For the 2015 scorecard, Pioneer Natural Resources was substituted for Talisman Energy, Inc., which was acquired by Repsol, S.A.

Toxic Chemicals

COMPANYQuantitative Reporting Toxicity ReductionNo Diesel Fuel in Fracturing FluidsNo BTEX in Fracturing FluidsWebsite Disclaimer CBI ExclusionSection Score
BHP Billiton11114
Noble Energy01012
Occidental Petroleum01102
Range Resources01102
Southwestern Energy01102
Chesapeake 10001
Continental Resources00011
Newfield Resources01001
Exco Resources00000
Penn Virginia00000
Ultra Petroleum *00000
Whiting Oil & Gas00000


  1. Does the company provide quantitative reporting on progress in reducing the toxicity of hydraulic fracturing fluids?
  2. Does the company state a practice to not use diesel in hydraulic fracturing fluids?
  3. Does the company state a practice to not use BTEX in hydraulic fracturing fluids?
  4. Does the company clearly state on its website that FracFocus (or its own reporting) may exclude chemicals protected by claims of confidential business information?

Water and Waste Management

COMPANYReport Practices of Cement IntegrityWell IntegrityAvoids inducing seismic activityPre-drill H2O monitor^Post-drill H2O monitor^Flowback water reuse %^Total water use^Water source types^Non-potable water policyWater intensity^Closed tank waterstore^Closed loop drilling residuals^NORMs disclosureSection Score
BHP Billiton110111111111112
Noble Energy11010011110108
Penn Virginia11011000101118
Occidental Petroleum10000111100005
Range Resources00010000101115
Southwestern Energy00100100100115
Exco Resources10000000101003
Chesapeake 00000000100001
Newfield Resources00010000100001
Ultra Petroleum *00000000000011
Continental Resources00000000000000
Whiting Oil & Gas00000000000000


  1. Does the company report principal practices used to test cement integrity, such as use of cement evaluation logs, or temperature, acoustic, or ultrasonic measures?
  2. Does the company report steps it takes when planning to drill and complete new wells to assure that nearby offset oil and gas wells (both active and inactive) and known natural faults and fractures will not provide pathways for fracturing fluids, hydrocarbons, and other contaminants?
  3. When planning completion of new production wells, or drilling and operating its own deep disposal wells, does the company report steps it takes to identify and avoid inducing seismic activity of a magnitude that creates risk of damage to life and property?
  4. For each shale play does the company disclose whether it routinely assesses groundwater quality before it drills?
  5. For each shale play does the company disclose whether it routinely assesses groundwater quality after it drills?
  6. For each shale play does the company disclose the percentage of flowback water managed and re-used for subsequent well completions?
  7. For each shale play does the company report the aggregate quantity of water used for operations?
  8. For each shale play quantity reported in response to the question immediately above, does the company report the share of water sourced from various types (e.g., x% groundwater, y% surface water, z% flowback water, etc.)
  9. Does the company state it has a policy of using non-potable water sources to the fullest extent technically practicable?
  10. For each shale play does the company report the intensity of its water use—the amount of water required to produce measurable units of energy (e.g., gallons/million BTU[MMBTU])?
  11. For each shale play does the company disclose a policy to store flowback water in closed tanks?
  12. For each shale play does the company report whether it routinely uses closed loop systems for management of drilling residuals?
  13. Does the company report its practices for identifying and managing the hazards from naturally occurring radioactive materials (NORMs)?

Air Emissions

COMPANY% Green completions^Low emission engines pad ops.^% low emission vehicle conversionNOX and VOCs reporting^NOX and VOCs reductions^Pipelines replace trucksMethane leakageLow-bleed controllersLeak detection technologyLeak inspection frequencyMethane reductionsGHG reductionsSection Score
Southwestern Energy1110011111008
BHP Billiton1110011100017
Noble Energy0110010111006
Range Resources0010010010003
Exco Resources0100010000002
Occidental Petroleum0000010010002
Ultra Petroleum *1000010000002
Chesapeake 0010000000001
Continental Resources0000010000001
Whiting Oil & Gas0000000010001
Newfield Resources0000000000000
Penn Virginia0000000000000
  1. For each shale play does the company report the percentage of wells, both gas wells and other types, for which it used green completions or explain why it does not?
  2. For each shale play does the company report it uses any of the following—natural gas, low emission diesel engines, or other reduced-emission methods—to power well pad operations?
  3. Does the company report the percentage of its vehicle fleet converted to lower emission fuels?
  4. For each shale play, does the company disclose data or estimates for NOx and VOCs emitted from well drilling, completions and production operations? For each shale play, does the company report reductions in NOx and VOC emissions from emission reduction efforts?
  5. Does the company report when pipelines have been used to replace trucks in transporting water used for fracturing operations?
  6. Does the company report the percentage emissions rate for methane from its drilling, completion, and production operations?
  7. Does the company report the percentage or number of high-bleed controllers replaced with low-emission alternatives, or a policy for their replacement?
  8. Does the company describe its program of leak detection and repair for fugitive emissions, including the technologies used for leak detection and the scope of monitoring conducted?
  9. Does the company report with what frequency it conducts monitoring for fugitive emissions?
  10. Does the company have an active methane emissions reduction target in place?
  11. Does the company have an active greenhouse gas emissions reduction target in place?

Community Impacts

COMPANYDisclose community impact concerns, company response^Aggregate statistics for local concernsUpward reporting of local concern statisticsTraffic congestion policiesRoad damage payment policiesSection Total
BHP Billiton111115
Newfield Resources000101
Noble Energy000101
Range Resources000101
Chesapeake 000000
Continental Resources000000
Exco Resources000000
Occidental Petroleum000000
Penn Virginia000000
Southwestern Energy000000
Ultra Petroleum *000000
Whiting Oil & Gas000000


  1. For each shale play does the company describe major identified community impact concerns and the company’s response or actions to resolve such concerns?
  2. Does the company disclose its internal processes for capturing and addressing local concerns?
  3. Does the company disclose its internal processes for reporting local concerns, and data about resolving those concerns, upward within the company?
  4. Does the Company disclose a clearly stated policy to adjust activity schedules to prevent or reduce traffic congestion from operations?
  5. Does the company have a clearly stated policy to reimburse state and local authorities for road damage caused by its operations?

Management and Accountability

COMPANYSenior management pay tied to HES3rd party audit for HES3rd party information prior to hiring contractorsNOVs and fines^NOV trends^Section Totals
BHP Billiton101114
Exco Resources011002
Newfield Resources101002
Noble Energy011002
Penn Virginia011002
Chesapeake 100001
Occidental Petroleum100001
Southwestern Energy001001
Whiting Oil & Gas000101
Continental Resources000000
Range Resources000000
Ultra Petroleum *000000


  1. Does the company report it provides compensation and incentive packages for senior management linked to HSE and social impact performance and its results?
  2. Does the company require third party independent auditing of HSE operations?
  3. Does the company rely on third party databases for information to evaluate potential contractors before hire?
  4. For each shale play does the company disclose notices of violation numbers (or equivalent administrative actions) and numbers and amounts of fines related to its operations?
  5. For each shale play does the company report reductions, if any, in numbers of notices of violations received over the past year?

The information in this report has been prepared from sources and data the authors believe to be reliable, but we assume no liability for and make no guarantee as to its adequacy, accuracy, timeliness or completeness. Boston Common Asset Management and the mutual funds that they manage may have invested in and may in the future invest in some of the companies mentioned in this report. The information in this report is not designed to be investment advice regarding any security, company or industry and should not be relied upon to make investment decisions. We cannot and do not comment on the suitability or profitability of any particular investment. All investments involve risk, including the risk of losing principal. No information herein is intended as an offer or solicitation of an offer to sell or buy, or as a sponsorship of any company, security, or fund. Opinions expressed and facts stated herein are subject to change without notice.