How Many Unconventional Wells Not Reported?

In a series of previous posts, I identified early Marcellus shale completions by various operators in Erie and Washington Counties, early Rhinestreet shale completions by Wainoco Oil and Gas Company (now HollyFrontier Corporation) in Crawford County and early Rhinestreet shale completions by Great Lakes Energy Partners (now Range Resources) in Crawford County.

Although these wells appear to meet the definition of an unconventional well under Act 13, CHAPTER 23 § 2302, as of April 2, 2012, none were reported by the Pennsylvania Department of Environmental Protection to the Pennsylvania Public Utility Commission as liable for impact fees, an apparent violation of Act 13.

In an effort to begin documenting these missing “legacy” wells in a more systematic and structured fashion I have started a small spreadsheet. To date, I have identified more than 200 legacy wells that likely meet Act 13’s definition of an unconventional well, all drilled prior to Range Resource’s “discovery” of the Marcellus shale in 2003-2005. If you are interested, I have posted these to a Google Spreadsheet.

Assuming the wells in question were vertical and not horizontal, these numbers, if correct, imply about $1.7 million in under-reported impact fees. If I were an elected official in one of the affected counties or municipalities (e.g., Crawford, Erie), this is something I would probably want to look into a bit more closely.