Disclosing the Facts:

Transparency and Risk in Hydraulic Fracturing Operations

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Disclosing the Facts 2016

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EXECUTIVE SUMMARY

Disclosing the Facts 2016 is the fifth 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 is performed to release oil and gas from what is currently known as “unconventional resources”—shale and other geological formations from which oil and gas are difficult to retrieve without fracturing. From a production perspective, these formations are anything but unconventional; the U.S. Energy Information Administration reports that in 2015 “unconventional resources” yielded approximately two-thirds of the natural gas and roughly half of the oil produced in the United States.

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These 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, in turn, can translate into financial risk to companies and shareholders in the form of fines, regulations, lawsuits, and threats to companies’ social license to operate.

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. Review of disclosed 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.

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This 2016 scorecard benchmarks the public disclosures of 28 companies on 43 key performance indicators. It distinguishes companies disclosing more information 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 in five areas: (1) toxic chemicals; (2) water and waste management; (3) air emissions; (4) community impacts; and (5) management accountability. The scorecard relies solely on publicly available information that companies provide on their websites, in corporate SEC postings, or in other reports linked from their websites.

The report focuses on “play-by-play” disclosure, as distinct from reporting at an aggregate level such as company- or country-wide. “Play-by-play” is shorthand for localized reporting, which is appropriate since health and environmental impacts and social license controversies are usually localized. However, in addition to facilitating understanding of local stakeholder relations, localized reporting is important because it offers insight into how company systems for managing risks and impacts are functioning in practice.

This year, the report card has been compiled amid a continuing dramatic contraction of well drilling and completion activities and enormous financial write-offs. As reported by Baker Hughes, the number of operating drilling rigs dropped to 476 in March 2016 from a peak of 1,931 in late 2014. Nearly 100,000 jobs linked to the oil and gas sector have been lost in the United States, bankruptcies have multiplied, and companies are now focusing on their most profitable areas rather than expanding into new frontiers.

Despite the sharp downturn from the pell-mell growth of the prior ten years, a core group of companies within the industry has maintained and enhanced disclosures of their practices for managing the environmental risks and community impacts of their operations. While the number of leading scorers has grown,  the majority of the oil and gas sector is still leaving investors in the dark about their risk management practices.

Key Findings

  1. Many companies have substantially increased their disclosures on issues of core concern to both investors and local communities. Tremendous media attention has been paid for many years to the adverse environmental and community impacts of hydraulic fracturing operations, including high-profile reports of spills, explosions, water contamination, and impacts on community health. Investors have too often had too little information about the concrete measures companies are taking to reduce and manage these risks. Pressed increasingly by investors for greater disclosure -- via this and other investor scorecards, investor dialogues, and shareholder resolutions, companies are responding. For example:
    1. Companies are increasingly assessing and reducing the toxicity of the chemicals used for hydraulic fracturing, reducing the numbers of and amount of toxic chemicals used, and lowering the number of chemicals hidden from public disclosure by trade secrecy claims. Although quantitative disclosures are still made by only a few leading companies, a larger number of companies have increased narrative reporting on their progress. Lack of transparency around chemical issues has been a serious challenge for companies seeking to secure their “social license to operate” and has translated into investor uncertainty about company attention to chemical risks.
    2. Companies are developing systems to better track community concerns and complaints, which may encompass issues such as traffic safety, noise, light and dust pollution, and road damage. These systems, which also track company responses, promote accountability inside and outside the company, facilitate analysis of these issues at management and board level, and enable reporting to investors and communities on performance.
    3. Companies are disclosing numerous operational and technological innovations that reduce their environmental footprint, yield bottom-line benefits, and reduce social conflicts. Companies are sourcing water for hydraulic fracturing operations from treated municipal wastewater, drawing water from deep saline aquifers for which there is no current competition from other users, and treating their own wastewater. Companies are deploying moveable, flexible hoses as substitutes for trucks to move water and wastewater, reducing road hazards, lowering emissions, and saving money. Companies are increasingly using drilling rigs and engines powered by the natural gas they produce, reducing diesel emissions and saving money. Many companies also are taking voluntary  actions to reduce emissions beyond regulatory requirements.
  2. Despite these signs of progress, most companies are still lagging seriously in taking and disclosing actions to address community and investor concerns. For example:
    1. Reducing methane emissions. Methane, which has more than 84 times the global warming impact of carbon dioxide over a 20-year period, remains a critical environmental challenge. Sound management of these emissions, especially through leak reduction, can yield sizeable business benefits. To lower the climate change hazard from methane emissions, much greater effort is needed to identify methane emission sources in the natural gas value chain (production through distribution). Recent research indicates that a relatively small proportion of sources, labeled “super-emitters”, are responsible for the majority of methane emissions. Companies must do a better job of demonstrating to investors voluntary commitments to measuring and reducing methane emissions beyond regulatory requirements. In particular, much more information should be provided on companies’ leak detection and repair (LDAR) programs. Only a very small number of companies report with any detail on this critical issue, have committed to reducing emissions as a percentage of production, or support development of innovative, lower-cost methane detection technologies; more companies should join them.
    2. Addressing Seismicity. Seismicity has increased dramatically in certain locations, correlated with the location of fracturing or waste injection operations. A significant number of these earthquakes have been of magnitude 3.0 and greater, causing property damage and growing concern. Companies must be vigilant in better understanding this issue, improving their own actions, and assuring oversight and due diligence of contractors.
    3. Addressing health and environmental impacts. The impact of oil and gas operations on human health and the environment is an enduring, insufficiently researched concern. The potential for significant public health impacts led to New York State’s complete ban on hydraulic fracturing and contributes to bans and moratoria around the globe. Scientific studies and incident reports, some more rigorous than others, document adverse health effects associated with oil and gas development; however, little systematic research has been conducted to more firmly establish the likelihood and magnitude of adverse health impacts. Companies should consider contributing to an independent research endeavor co-funded by government and philanthropic foundations concerned about public health (a funding structure likely to reduce arguments over “our science vs. yours”) that would enable industry, investors, and communities to better understand the magnitude of health risks and develop precautionary measures to address them.
  3. These disparate trends are reflected in company scores. This year, BHP Billiton retained its #1 position, disclosing on 40 of 43 indicators (93 percent). BHP’s comprehensive reporting demonstrates companies’ ability to rise to the Disclosing the Facts challenge. Noble Energy, ranked #2, nearly doubled its score to report on 81 percent of indicators. Other strong and improving performers included Apache, which rose to 67 percent, and Range Resources, which moved from 28 to 63 percent. Hess and Southwestern Energy rose to 63 percent. Southwestern Energy increased its score despite the company’s 40 percent staff reduction announced in early 2016. Carrizo, soaring from 0 to 53 percent of indicators, and Newfield Resources, rising from 15 to 47 percent, also were major movers. These scores are a stunning improvement from the inaugural 2013 scorecard, when no company scored above 43 percent. Many of these companies either improved their practices or began reporting on leading practices they previously failed to disclose, or some combination of the two. Nevertheless, 15 of the 28 companies evaluated disclosed on fewer than 33 percent of indicators; investors are unable to gauge how well these companies are addressing environmental and community impact risks.
  4. Many companies are mainstreaming Disclosing the Facts and developing model disclosure formats. Southwestern Energy and Apache have integrated Disclosing the Facts indicators into the indices of their corporate sustainability reports. BHP Billiton produces an annual hydraulic fracturing case study that adopts the Disclosing the Facts outline. Noble Energy produces a stand-alone document addressing hydraulic fracturing indicators that had not been addressed in its prior sustainability reports.

Recommendations

  1. Companies: All companies that engage in hydraulic fracturing should join in the mainstreaming of risk disclosure. Laggards may face exclusion from portfolios as investors assign increasing weight to environmental, social, and governance factors in portfolio management.
  2. Investors: Investors should continue to press companies, particularly laggards, on disclosure across the five key areas addressed in Disclosing the Facts 2016 to ensure that companies are managing risk and implementing best management practices. Many of the quantitative, locally focused scorecard indicators reflect recommendations made by the International Energy Agency in its 2012 report, Golden Rules for the Golden Age of Gas. These indicators are also increasingly being used in investor engagements by a large number of PRI-signatory investors. 
  3. Communities: Officials and concerned citizens at state and local levels should use the leading practice examples highlighted in this and earlier scorecards to query companies seeking to obtain or maintain their social license to operate. 

2016 DATA TABLES

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

COMPANY2015 SCORE 2016 SCORE
Anadarko Petroleum Corp. (APC)1520
Antero Resources (AR)-7
Apache Corp. (APA)2029
BHP Billiton, Ltd. (BHP)3240
BP plc (BP)86
Cabot Oil & Gas Corp. (COG)85
Carrizo Oil & Gas, Inc. (CRZO)023
Chesapeake Energy Corp. (CHK)412
Chevron Corp. (CVX)47
ConocoPhillips Corp. (COP)1115
CONSOL Energy, Inc. (CNX)1922
Continental Resources, Inc. (CLR)22
Devon Energy Corp. (DVN)73
Encana Corp. (ECA)810
EOG Resources, Inc. (EOG)88
EQT Corp. (EQT)1421
Exxon Mobil Corp. (XOM)46
Hess Corp. (HES)2127
Newfield Exploration Co. (NFX)620
Noble Energy, Inc. (NBL)1935
Occidental Petroleum Corp. (OXY)1012
Pioneer Natural Resources (PXD)37
QEP Resources, Inc. (QEP)1512
Range Resources Corp. (RRC)1127
Royal Dutch Shell plc (RDS)1115
Southwestern Energy Co. (SWN)1627
Whiting Petroleum Corp. (WLL)22
WPX Energy, Inc. (WPX)34

2015 had a total of 39 possible points. 2016 had a total of 43 possible points.

Toxic Chemicals

COMPANYQuantitative Toxicity ReductionUse of Dry Chemicals No Diesel in Frac FluidsNo BTEX in Frac FluidsCBI Exclusion DisclaimerReducing Contractor CBI ClaimsSection Total
ANTERO0000000
ANADARKO0110114
APACHE1111116
BHP-BILLITON1111015
BP0100102
CABOT0011002
CARRIZO0011103
CHESAPEAKE1110104
CHEVRON 0011002
CONOCO PHILLIPS0011103
CONSOL 0010001
CONTINENTAL RESOURCES0000101
DEVON0000000
ENCANA0010001
EOG0000000
EQT0000000
EXXON MOBIL0010001
Hess Energy1011003
NEWFIELD RESOURCES 0000000
NOBLE ENERGY0110103
OCCIDENTAL PETROLEUM0011103
PIONEER0000000
QEP1011104
RANGE RESOURCES0111003
SHELL0010102
Southwest1011104
WHITING OIL & GAS0000000
WPX0000000

QUESTIONS

Questions in italics were newly added to the 2016 company survey.

  1. Does the company provide quantitative reporting on progress in reducing the toxicity of hydraulic fracturing fluids, including information indicating a baseline year for calculations?
  2. Does the company state a practice to use dry fracking chemicals in place of liquid chemicals wherever feasible to reduce risk?
  3. Does the company state a practice to not use diesel fuels, as defined by EPA, in hydraulic fracturing fluids?
  4. Does the company state a practice to not use BTEX in hydraulic fracturing fluids?
  5. Does the company clearly state on its website that FracFocus and/(or its own reporting) may exclude chemicals protected by claims of confidential business information (CBI)?
  6. Does the company state measures it and/or its third party contractors, take to reduce CBI claims for chemicals used in its hydraulic fracturing operations?

Water and Waste Management

COMPANYCement EvaluationWell IntegrityAssesses Offset WellsAvoids Inducing Seismic ActivityPre-drill H2O Monitor^Post-drill H2O Monitor^Flowback Water Reuse %^Total Water Use^Water Source Types^Non-potable Water PolicyWater Scarcity PlanningWater Intensity^Wastewaster Storage^Closed Loop Drilling Residuals^NORMS DisclosureSection Total
ANTERO0000000000001102
ANADARKO1001000111100107
APACHE10111111111100112
BHP-BILLITON11101111111111114
BP0001000000100002
CABOT1000000000000001
CARRIZO10111111110011112
CHESAPEAKE0000000001000012
CHEVRON 0000000001000001
CONOCO PHILLIPS0010000001100003
CONSOL 0010111111001109
CONTINENTAL RESOURCES0000000000000000
DEVON0000000001000012
ENCANA0000000001000001
EOG1000100001000003
EQT0000001001011116
EXXON MOBIL0001000001100003
Hess Energy11111111111111014
NEWFIELD RESOURCES 1110001001100118
NOBLE ENERGY10111111111111114
OCCIDENTAL PETROLEUM1000001111100107
PIONEER0001000001000002
QEP1010000001000003
RANGE RESOURCES10111111111100112
SHELL0001110001100005
Southwest01100011111101110
WHITING OIL & GAS0000000000000000
WPX1000100000000002

QUESTIONS

Questions in italics were newly added to the 2016 company survey.

  1. Does the company describe under what circumstances it uses cement evaluation logs, or temperature, acoustic, or ultrasonic measures to assess well integrity e.g., for some or every new or refractured well, when entering new plays, and/or addressing well integrity anomalies?
  2. Does the company report the percentage of its well integrity failures that result in a release to the environment?
  3. Does the company report steps it takes, when planning to drill and complete new wells, to minimize the risk that nearby offset oil and gas wells (both active and inactive) and faults and fractures will provide pathways for fracturing fluids, hydrocarbons, and other contaminants to enter the environment, including the atmosphere or surface or ground water?
  4. For each play, does the company state the practices it uses, or requires of its third party contractors, when planning completion of new production wells, drilling and operating its own deep disposal wells, or disposing of wastewater, to avoid seismic activity that can be felt at the surface?
  5. For each play, does the company disclose whether it assesses groundwater quality before it drills?
  6. For each play does the company disclose whether it routinely assesses groundwater quality after it drills?
  7. For each play does the company disclose the percentage of produced and/or flowback water from wells that is reused for subsequent well completions?
  8. For each play does the company report the aggregate quantity of water used for operations?
  9. For each play, for the quantity of water reported in response to the question immediately above, does the company report the share of water sourced from various types (e.g., x% potable, x% non-potable, x% groundwater, x% surface water, x% municipal, x% water recycled from operations or other forms of recycled water, or other such categories.)?
  10. Does the company state its practices for how and when it uses non potable water in its operations?
  11. Does the company report whether it operates in water-scarce areas (and how this is determined) and its program or practices for limiting or reducing water in water-scarce areas it identifies?
  12. For each 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] on an annual basis)?
  13. For each play, does the company state whether it uses tanks and/or open impoundments to store produced water; its criteria for such selection(s); and steps it takes to reduce spills, leaks, volatile emissions, and hazards to wildlife?
  14. For each play does the company report whether it routinely uses closed loop systems for management of drilling residuals containing oily wastes or other toxic or hazardous materials?
  15. Does the company report its practices for identifying and managing the hazards from naturally occurring radioactive materials (NORMs), including both contaminated equipment and contaminated wastewater, and for tracking its own and its contractors' management of such wastes?

Air Emissions

COMPANYLow Emission Pad Ops.^% Low Emission Vehicle ConversionAddt'l Voluntary Emission Reductions^Pipelines Replace Trucks^Methane Leakage %Low-bleed ControllersLeak Detection PracticesLeak Detection FrequencyMethane TargetGHG TargetSection Total
ANTERO10110010004
ANADARKO01010000002
APACHE01001010104
BHP-BILLITON111111111110
BP00000000000
CABOT00000000000
CARRIZO00011111005
CHESAPEAKE11000100003
CHEVRON 00010000001
CONOCO PHILLIPS00001100013
CONSOL 10100111005
CONTINENTAL RESOURCES00000000000
DEVON00000000000
ENCANA00111100004
EOG00001010002
EQT10101111006
EXXON MOBIL00000000000
Hess Energy01001100115
NEWFIELD RESOURCES 11101111007
NOBLE ENERGY11111111008
OCCIDENTAL PETROLEUM00100000001
PIONEER01010010003
QEP01000011003
RANGE RESOURCES11010101005
SHELL00001000001
Southwest10111111108
WHITING OIL & GAS00100000001
WPX00000000000

QUESTIONS

Questions in italics were newly added to the 2016 company survey.

  1. For each play does the company report the methods it uses to reduce air pollution associated with powering well pad operations, e.g., solar, natural gas, low emission diesel engines, solid state generators, micro-grids, or other emission reduction methods?
  2. Does the company report the percentage of its vehicle fleet converted to lower emission fuels, including CNG, electricity, or other non- petroleum-based fuels?
  3. For each play, does the company report the voluntary practices it takes, in addition to those practices required by law, other than reduced truck use and fuel substitutions for engines, to reduce air pollution emissions to the atmosphere from its drilling, completions, and production operations?
  4. For each play, does the company report whether it substitutes pipelines for trucks to transport water or wastewater, including, e.g., criteria for making this choice, percentages of water/wastewater transported by pipeline, or individual examples of operating or under construction pipeline systems?
  5. Does the company report the percentage emissions rate for methane from its drilling, completion, and production operations, measured as methane emissions per methane production on an annual basis?
  6. Does the company report the percentage or number of high-bleed controllers replaced with low-emission alternatives, or a program for their replacement?
  7. Does the company describe the practices through which methane leak detection and repair, or other leak detection methods, are conducted, including descriptions and proportions of facilities assessed, and methodologies employed?
  8. Does the company report, for each of the facility categories described above, the frequency of leak detection and repair efforts?
  9. Does the company disclose an active methane emissions reduction target and progress toward achieving this target?
  10. Does the company disclose an active greenhouse gas emissions reduction target and progress toward achieving this target?

Community Impacts

COMPANYCommunity Impact Concerns, Company Response^Data Tracking of Local ConcernsUpward Reporting within CompanyTraffic Congestion PoliciesDriver Training & TrackingLight, Noise, & Odor ActionsSection Total
ANTERO0000000
ANADARKO0111115
APACHE0111115
BHP-BILLITON1111116
BP0100001
CABOT0000000
CARRIZO0001001
CHESAPEAKE0000101
CHEVRON 0000101
CONOCO PHILLIPS0111104
CONSOL 0001001
CONTINENTAL RESOURCES0000101
DEVON0000000
ENCANA0101002
EOG0111003
EQT1111105
EXXON MOBIL0001001
Hess Energy0101103
NEWFIELD RESOURCES 0110002
NOBLE ENERGY1111116
OCCIDENTAL PETROLEUM0000000
PIONEER0000101
QEP0000000
RANGE RESOURCES1111116
SHELL0101103
Southwest0101103
WHITING OIL & GAS0000000
WPX0000101

QUESTIONS

Questions in italics were newly added to the 2016 company survey.

  1. For each play does the company describe major identified community concerns and the company's response or actions to resolve such concerns?
  2. Does the company disclose its internal processes, including data systems, for capturing and addressing local concerns before, and after, the drilling process begins?
  3. Does the company disclose its internal processes for reporting local concerns and response data upward within the company?
  4. Does the company disclose a practice to adjust activity schedules to prevent or reduce traffic congestion from operations?
  5. To reduce risks of accidents, and to ensure compliance with designated routes, does the company describe driver training and/or tracking methods for its own employees and third party contractors?
  6. Does the company describe routine measures to minimize light, noise, and odor pollution from its drilling completion, and production operations?

Management and Accountability

COMPANYSenior Management Pay Tied to HESSenior Pay Link to Other HES Indicators3rd Party Audit for HES3rd Party Info Used for Contractor Hiring NOVs and Fines^NOV Trends^Section Total
ANTERO1000001
ANADARKO1001002
APACHE1001002
BHP-BILLITON1101115
BP1000001
CABOT0011002
CARRIZO0011002
CHESAPEAKE1001002
CHEVRON 1010002
CONOCO PHILLIPS1001002
CONSOL 1111116
CONTINENTAL RESOURCES0000000
DEVON1000001
ENCANA1001002
EOG0000000
EQT1011104
EXXON MOBIL1000001
Hess Energy1001002
NEWFIELD RESOURCES 1011003
NOBLE ENERGY1011104
OCCIDENTAL PETROLEUM1000001
PIONEER1000001
QEP1001002
RANGE RESOURCES0001001
SHELL1111004
Southwest1001002
WHITING OIL & GAS0001001
WPX1000001

QUESTIONS

Questions in italics were newly added to the 2016 company survey.

  1. Does the company report it provides compensation and incentive packages linked to Health, Safety, Environmental, or social impact performance, in the proxy statement?
  2. In the proxy statement, does the company link management compensation to environmental indicators other than spills, e.g., methane/GHG reductions, increased water efficiency, etc.?
  3. Does the company require third party independent auditing of Health, Safety, and Environmental operations, other than verification of data in CSR reports?
  4. Does the company use third party databases, such as ISNetworld, or others providing equivalent information, to obtain information to evaluate potential contractors before hire?
  5. For each play does the company disclose notices of violation numbers (or equivalent administrative actions) and numbers and amounts of fines related to its operations?
  6. For each 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, LLC 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. The views expressed in Disclosing the Facts 2016 do not necessarily express the views of all IEHN members.