A look at how the state is (or is not) regulating fracking and aquifer exemptions
One of the most controversial areas of current environmental policy is the debate over hydraulic fracturing (or fracking). The process involves the injection of pressurized fluid deep underground to break apart the subsurface layers to enhance oil and gas recovery. Hydraulic fracturing has occurred in California and nationwide for decades; however, recent advancements in horizontal drilling technologies and “well stimulation” techniques have been instrumental in triggering an oil and gas boom, making the U.S. the world’s largest producer of oil and gas reserves. California produces more oil than all but three other states (Texas, North Dakota and Alaska), and Kern County is responsible for more than 70 percent of the state’s oil production.
Environmentalists and other members of the public became concerned that the hydraulic fracturing process may contaminate groundwater aquifers, trigger earthquakes, release methane emissions, and delay the task of weaning the state from the long-standing dependence on fossil fuels. In 2013, the California legislature responded to these concerns by enacting SB 4, which amended the California Public Resources Code and Water Code for Well Stimulation Treatment (more commonly known as fracking) and created new requirements for oilfield operators, the Department of Conservation, Geologic Energy Management Division (CalGEM), State Water Board, Regional Water Boards, and other state agencies. SB 4 expanded the Water Boards’ role in reviewing Underground Injection Control projects and aquifer exemption proposals in response to increased concern from the legislature, US EPA, oil and gas operators, and the public. Lastly, SB 4 called for a study to evaluate the risks associated with hydraulic fracturing in California (Here is the Executive Summary of that report.)
At the April 6 meeting of the State Water Board, the Division of Water Quality provided board members with an update on work conducted to date for the Oil and Gas Monitoring Program, including Well Stimulation Treatment trends, area-specific, and regional groundwater monitoring, aquifer exemption proposal status, Underground Injection Control project review progress, carbon sequestration projects, public access to program information, and next steps and future work for the program. This was an informational item; no Board action was taken.
Janice Zinky, chief of the Underground Injection Control unit in the State Water Board’s oil and gas monitoring program, began with an overview of the program.
The Oil and Gas Monitoring Program consists of three main areas of work:
monitoring associated with well stimulation treatment, also known as hydraulic fracturing,
underground injection control, which includes aquifer exemption review and injection project review,
and work associated with oil field-produced water ponds.
Currently, there are 39 staff members dedicated to this work statewide, which includes staff from Central Valley, Central Coast, and the Los Angeles regional boards. Ms. Zinky noted that the presentation today will not include an update on produced water ponds as that program is overseen by the Central Valley Regional Water Quality Control Board.
There are 487 onshore oilfields in California and over 225,000 active, idle, or abandoned wells located across the state. The work in the Oil and Gas Monitoring Program is primarily located in Kern County and also includes areas such as San Luis Obispo, Ventura, Santa Barbara, and Los Angeles counties.
Chair Esquivel asked about the plugged or abandoned wells … How much of an issue are abandoned wells in this state? Ms. Zinky said that typically a plugged well is an abandoned well. Staff noted that there are orphan wells, which are those that need to be plugged and abandoned, but haven’t; staff does not have a number of how many orphan oil wells there are.
WELL STIMULATION TREATMENT MONITORING UNIT
Bill Patzelt, Chief of the Well Stimulation Treatment Monitoring Unit, provided an update on the unit’s activities, which oversees the area-specific groundwater monitoring conducted by oil and gas operators, as well as the regional groundwater monitoring program led by the USGS. He noted that an annual performance measures report is produced and posted on the website each year. (Here’s the latest report.)
Well stimulation treatment uses high pressure to inject a fluid mixture that consists of gel and sand into a geologic formation to increase production. Depths of well stimulations in California can range from approximately 600 feet to over 13,000 feet below ground surface. Well stimulation treatments have occurred for decades, predominantly in southern San Joaquin Valley and Los Angeles Basin. Since 2015, it’s occurred mostly in Kern County and now includes groundwater monitoring requirements, said Mr. Patzelt.
Before the development of the program, the public expressed concern about water quality and the protection of water resources in areas where well stimulation was occurring. This led to the passage of SB 4 in September 2013, which set the framework for regulating well stimulation treatments. A Memorandum of Agreement was signed in 2014 between the California Geologic Energy Management Division of the Department of Conservation, also known as Cal GEM, which established each agency’s respective authority associated with well stimulation treatment activities.
As required by SB 4, the Water Boards developed groundwater monitoring requirements known as the ‘model criteria’ in 2015. These criteria were adopted by the State Water Board and outlined the requirements for operator monitoring and the regional monitoring program.
The figure shows the number of wells stimulations from 2012 through 2020, along with the price of oil per barrel. Before 2016, operators submitted well stimulation data to a national database called FracFocus. Since then, Cal GEM has permitted and tracked all wells stimulations, as shown in orange.
“Well stimulation activities have decreased since 2015,” said Mr. Patzelt. “Factors that may have affected the number of well stimulations include increased regulation after SB 4 was enacted, fluctuation oil prices, and a temporary moratorium on well stimulation applied by the governor in 2020.”
Area-specific monitoring is required when operators propose stimulating a well in areas where protected water is present. Protected water is a term specific to the Well Stimulation Program and is defined as water that contains less than 10,000 milligrams per liter of total dissolved solids and outside of an exempt aquifer.
Water boards may grant operators an exclusion from groundwater monitoring if the well to be stimulated does not pass through zones containing protected water. Operators must notify nearby property owners prior to well stimulations, and those property owners can request water sampling. Mr. Patzelt noted that only one property owner has requested sampling since 2015. Additional details of these groundwater monitoring requirements are laid out in the model criteria.
Operators are required to collect and submit groundwater data related to well stimulation. To date, water board staff have reviewed and approved 14 groundwater monitoring plans in 10 oil fields, as shown in blue on the map. Water Board staff has also reviewed 139 groundwater monitoring reports associated with these approved plans. This review process includes working with Regional Water Board staff to provide operator comments.
Area-specific groundwater monitoring conducted by operators is intended to characterize baseline water quality conditions and to assess potential impacts to groundwater. Operators have been requested to evaluate these sites to determine the nature of any elevated compounds and whether they are related to well stimulation treatments. Additionally, water board staff has worked closely with Cal GEM to review and provide comments for over 2200 well stimulation permits.
Operators have also requested and received approval from the Water Boards for 20 exclusions from groundwater monitoring in six oil fields, shown in orange on this figure. These requests for exclusions are based on detailed technical proposals submitted by an operator indicating that a certain area proposed for well stimulation does not contain protected water. An area may be granted exclusion from groundwater monitoring either for water greater than 10,000 milligrams per liter total dissolved solids or no groundwater at all.
Mr. Patzelt noted that all information associated with area-specific groundwater monitoring plans, reports, and exclusions is publicly available on the Water Board Geotracker information website. Performance measures report summarizing work conducted in the unit are also posted on the Oil and Gas Program page annually.
REGIONAL GROUNDWATER MONITORING PROGRAM
Valerie Petela, an engineering geologist with the Board’s Division of Water Quality, then provided an update on work conducted and findings to date for the regional groundwater monitoring program.
The objective of this program is to evaluate potential impacts from well stimulation treatments and other oilfield development on groundwater resources. As shown in the figure on the slide, these could include oil and gas well failure or breach, injection for oil production, or disposal practices, such as water disposal wells and produced water ponds. Through a cooperative agreement with the State Water Board, the USGS is the technical lead for implementing the regional monitoring program.
In 2014, the USGS performed a prioritization analysis of California’s 487 onshore oil fields. From that study, they have focused on regional areas to perform historical data compilation of lab analyses, well completion reports, and borehole geophysical logs. They have also conducted salinity mapping using historical and newly collected total dissolved solids measurements, oilfield fluid and groundwater sampling, and monitoring well installation.
The prioritization analysis categorized fields as high, medium, or low priority, based on vertical proximity of water supply will soil wells, well density, and injection volumes. To date, the regional monitoring program has been implemented in 33 oil fields.
In addition to incorporating historical data, the USGS has collected 332 groundwater samples, depicted as the gray triangles, and 58 oilfield fluid samples, shown as orange dots. The USGS has also drilled and installed three multiple depth monitoring wells at different oil fields to provide additional site-specific data.
“We strive to make study results accessible to the public through public meetings,” said Ms. Petela. “And we have recently released the Regional Monitoring Program mapping tool. This tool can be found on our webpage and allows users to view study areas and sampling results. Each study area on the map has links to the associated published manuscripts and data releases. Publications often include maps and detailed figures of the study results. This tool is great for those that aren’t familiar with oil field names or locations but are interested in finding out more about oil and gas related studies near them.”
To conduct these studies, the USGS uses innovative approaches to gain knowledge about groundwater conditions in oil fields in California, such as using data mining and digitization techniques to work with millions of historical data points at a time. Using these data and other methods, such as airborne electromagnetic surveys, they create 3D salinity maps of aquifers overlying oilfield development to identify baseline conditions and observe any effects from disposal activities.
The USGS uses a suite of groundwater chemistry analytes to investigate natural and manmade properties between oil fields and groundwater resources. Studies often include looking at isotopes of methane, noble gases, and other elements. Each study area has complex local groundwater and geologic influences that contribute to individual study results. However, these approaches also lead to a better understanding of regional-scale groundwater quality.
“The USGS regional monitoring program work is ongoing, and we will continue to share results on our State Water Board web page,” said Ms. Petela.
UNDERGROUND INJECTION CONTROL (UIC)
The work of the Underground Injection Control unit focuses on the review of aquifer exemption proposals and underground injection projects. The Underground Injection Control (UIC) program is built on collaboration between agencies. The US EPA granted Cal GEM primacy to oversee oil and gas-related underground injection in California, and the water boards work closely to implement the program with Cal GEM. The memorandum of agreement between the State Water Board and Cal GEM was updated in 2018 and clarified the coordination of administering the state’s UIC program.
“Working closely with the regional boards, Cal GEM, and the US EPA is key in implementing a successful UIC program,” said Ms. Zinky.
Aquifer exemption proposals
An aquifer exemption proposal is only allowed if it meets both federal and state criteria. Ms. Zinky noted that an exempted aquifer does not automatically give the green light to injection projects. Underground injection is only allowed if Cal GEM approves a permit for either enhanced oil production or wastewater disposal.
Since 2015, the State Water Board, Cal GEM, and the US EPA have been working to bring aquifers into compliance, where injection either had been or is occurring outside of exempted aquifers.
The criteria that an aquifer exemption proposal needs to meet include that the aquifer is not a current source of drinking water and will not in the future be considered a source of drinking water; and that injected fluids will stay in the exempted zone and will not affect any beneficial use water.
Ms. Zinky noted that the approval process includes many stakeholders and often takes multiple years, and ultimately the US EPA approves or rejects an aquifer exemption proposal. But before then, Cal GEM and the water boards collaborate in an in-depth technical review and a public process, including a hearing and comment period.
Since 2015, the water boards have reviewed 36 aquifer exemption proposals, shown in the map in red. The majority of these proposals were initiated to bring wells that have been injecting outside of an exempted offer into compliance with the Safe Drinking Water Act. The State Water Board has issued final concurrence letters for 24 proposals, 22 of which the US EPA approved.
“Where we have concurred with an aquifer exemption, we have often indicated potential conditions on future UIC projects, which can include monitoring to verify that the fluids are remaining in the exempted zone,” said Ms. Zinky. “Where the water boards do not agree with a proposal, it is either modified or withdrawn. This is most often due to the lack of information to confirm that injected fluids will remain in the exempted zone or that the aquifer is non-oil bearing and contains high-quality water, typically less than 3000 milligrams per liter of total dissolved solids. Where the water boards do not agree with an exemption proposal, we work with Cal GEM to ensure that future injection does not occur.”
“We also work with operators to transition existing injection projects out of non-exempt aquifers. The transition projects are often large-scale and take multiple years to complete. Currently, two such transition projects are occurring at two large oil fields in Kern County.”
Underground Injection Control (UIC) Review
Tina Bauer, an engineering geologist with the Division of Water Quality, then discussed Underground Injection Control project reviews.
Under the Safe Drinking Water Act, fluids related to oil and gas production may be permitted for injection into an aquifer that does not qualify as an underground source of drinking water, either because it is exempt or because it exceeds the threshold for total dissolved solids.
Cal GEM issues the UIC permits, and there are about 870 active projects in this state consisting of over 55,000 wells. A UIC project can include a single well or hundreds of wells. Each UIC permit has specific operational, regulatory, and reporting criteria outlined in a Project Approval Letter or PAL.
Since 2015, nearly 300 UIC projects have been reviewed by the water boards. There are five types of UIC projects; the chart shows how many of each type have been reviewed. The majority of our UIC reviews are non-expansion, followed by new and expansion projects.
“Modifying a PAL is a critical component that brings the permits up to current regulatory standards,” said Ms. Bauer. “All project types require changing or creating a new PAL, except for non-expansions, also known as infills. Project-by-project reviews are a one-time comprehensive review and take significant effort to prepare and review.”
Consistent coordination and collaboration between the state and regional boards are driving forces in creating a balanced and efficient UIC program, Ms. Bauer said. The regional boards are the lead agency for UIC projects within their boundaries. And the state currently assists as the lead agency for the occasional pilot and project by project review. But all projects have some level of peer review.
“Over the past five years, the state and regional boards have strengthened our working relationships with Cal GEM and work together in resolving technical issues and PAL requirements,” she said.
There are over 800 active UIC projects in the state; about 500 are in Kern County. About 62% of the projects reviewed are located in the Central Valley region, 35% in the Central Coast region, and a combined 3% in the Los Angeles and Santa Ana regions.
While most UIC project reviews of all types are in the Central Valley, the Central Coast Regional Board is currently busy with non-expansion reviews, and the LA regional board has had several new and expansion projects primarily in LA and Ventura counties.
The UIC project review process is outlined in the memorandum of agreement, which contains a comprehensive checklist that took nearly three years to develop. The figure shows the overall review process that begins and ends with the operator since it is a permit to inject.
The project review is a collaborative technical review effort between Cal GEM and the water boards. Key project criteria include where the injections zone is, the horizontal and vertical limits of the injection, and potential injection pressure effects on wells within the review area.
“It is not uncommon for the water boards to require additional information to complete its review or add monitoring or reporting requirements to the PAL,” said Ms. Bauer. “If the water boards do not object to the project, Cal GEM issues the PAL so they can operate. A new UIC project requires a public comment period. There have been a few projects that the water boards objected to, and those UIC permits were not issued.”
During the development of the UIC project review program, it became apparent a long term mapping and tracking system was needed, as both Water Board management and industry stakeholders requested updates on where the UIC project reviews were in the process and how fast the projects were being reviewed.
The Water Board’s GeoTracker was used for this purpose. The slide shows an example of the UIC project review tracking report.
“As with many other programs, GeoTracker is an invaluable tool and continues to be modified to meet the UIC program and evolving needs,” said Ms. Bauer. “The entire project review and accounting process is now digital, transparent, and accessible to the public and stakeholders.”
A new type of injection project the Water Boards have recently been involved with is carbon capture and sequestration, an emerging strategy to reduce greenhouse gas emissions and mitigate climate change. The graphic on the right is a conceptual model of a carbon capture and sequestration project. This is a process by which large amounts of carbon dioxide are captured, compressed, transported, and stored. The storage component includes carbon dioxide injection via class six wells into deep geologic formations.
While the US EPA is the permitting agency, the water boards are part of a multi-agency effort to develop a process for permitting these wells in California. The UIC program is currently reviewing the first project of this type in the state, located in the San Joaquin Valley.
“Over the last five years, the UIC project review program has certainly experienced Growing Pains but has accomplished significant tangible results,” said Ms. Bauer. “We’ve developed and memorialized water board review criteria for UIC projects. We’ve developed a standard protocol for the efficient UIC project submittals from Cal GEM. We’ve developed GeoTracker protocol and tools for efficient task tracking, accountability, and public access. We’ve reviewed 280 and counting UIC projects. But above all this, the water board’s actions have increased the protection of beneficial use water as an active participant in the critical review and permitting process of UIC projects.”
FUTURE GOALS FOR THE PROGRAM
Ms. Zinky then discussed the future goals for the program. “In well stimulation, we plan to start an evaluation of the effectiveness of the model criteria for groundwater monitoring through a stakeholder process, and based on those findings, we will be updating the groundwater monitoring requirements if deemed necessary. We will continue to communicate findings of the USGS-led regional monitoring programs through public meetings and publications.”
“We will continue to work with Cal GEM to develop interagency best practices and help streamline injection project review, while focusing on the protection of beneficial use waters. We will continue to work with Cal GEM to comprehensively review all existing projects in the state, bringing them up to current regulatory standards. And we will continue to make the information easily accessible to the public via the State Water board’s GeoTracker Information System, public meetings, and our oil and gas website.”
CLARIFYING NUMBER OF UIC PROJECTS REVIEWED
Board member Laurel Firestone noted that it looks like about a third of the active UIC projects have been
Bill Patzelt said the Board has few entries into the process. “One is when they’re proposing to expand or add new injection or new wells, or a new project, that’s the primary entry into it. There is a plan that Cal GEM has to do a comprehensive project-by-project review, and there’s a small number of those. During that process, we would look at existing projects as they do those reviews; we’re part of that. That has had a slow start, and we’re hoping that that will increase in pace and scale. But at this point, we don’t really have an entry into an existing project that doesn’t have a project-by-project review, so I can’t give you a timeline when we would get to those. We are dependent on Cal GEM initiating that review for us to become part of it.”
Liz Beall is the Executive Director of Climate First Replacing Oil and Gas, an environmental community-based advocacy organization in Ventura County, spoke about her concerns about an aquifer exemption proposal under consideration in Ventura County.
“I’m coming here to you today to encourage the State Water Board to stick to objective truth when presenting scientific outcomes to our local communities. So the State Water Board is currently contemplating an offer for exemption application here in Oxnard. And in 2017, water samples were gathered here by USGS under the regional monitoring program, and that was done in order to determine whether or not oil and gas operations have caused migration pathways into the Fox Canyon Aquifer, which is a source of drinking water for over 400,000 Ventura County residents. There were preliminary findings that were published in 2019. That raised serious concerns because thermogenic gases were found in the Fox Canyon aquifer. Our Board of Supervisors enacted a two-year moratorium on cyclic steam extraction, waiting for more information. Unfortunately, that information was a really long time coming. So the moratorium came and went.
“The final USGS study didn’t come out until January 2021, and gave us a lot more questions than it gave us answers. The test results of the final USGS study were inconclusive. Fourteen wells were tested once in 2017. Oil companies apparently denied access to additional water wells, and no attempt was made to demand access or expand the scope of the study. So between April 2017 and 2019 and today, no additional samples were taken, no substantive new analysis was conducted, and no new conclusions were made. So we’re still sitting here today with the conclusion that those thermogenic gases found in the Fox Canyon aquifer could be naturally occurring, or they could be evidence of contamination.
“Yet even with these inconclusive study results, the Water Board published a study summary with a misleading headline; it claimed there was ‘no evidence’ of hydrocarbon-bearing formation water mixing into overlying groundwater aquifers. As a scientist, I would argue that the headline is not factual but that no evidence headline is being repeatedly thrown around by the oil industry to support operations of cyclic steam on the Oxnard oilfield. It’s also being used to undermine our organization’s credibility, and any scientists will tell you that a lack of conclusive evidence is not the same as no evidence. …
“I’m here requesting that the Water Board retract this summary headline and do a review of how such headlines get generated at the agency. I’m also asking that the Water Board conduct an additional, more definitive, and rigorous study before undertaking any final review of the aquifer exemption proposal for the Oxnard oilfield. … “
She also noted that the Oxnard Oilfield has numerous abandoned wells, many not plugged or insufficiently plugged, and many wells have overdue test requirements. They are out of compliance with CalGEM’s own regulatory and test standards.
She concluded with two questions: “How can 40 or 50 years of aggressive cyclic steam activity be justified when just one accident could permanently damage the extremely important Fox Canyon aquifer and if this aquifer exemption is granted and allowed to proceed, who will monitor groundwater quality so that if deep subsurface contamination event occurs, oilfield operations can be shut down before the contamination becomes widespread?”
Tara Messing is a staff attorney with the Environmental Defense Center, and she spoke about the Cat Canyon aquifer exemption applications.
” … On behalf of our clients, I study the application, work with experts, and analyze various reports. And from this research, we have provided ample evidence to demonstrate that the criteria under Public Resources Code 3131 have not been satisfied and that this application must be denied. Cat Canyon has hundreds of active idle and abandoned wells and a long history of drilling wells with confirmed pathways for injected fluids to travel into protected groundwater and contaminate groundwater quality. The application, however, omits the study of the wells to determine if any wells need to be repaired or abandoned … We cannot gamble with such a critical natural resource by allowing more seeming and more wastewater injection into these aquifers. … “
Katherine Dodd is a registered nurse representing the California Alliance of Nurses for Healthy Environments. “… As a nurse specifically, I’m concerned with not just of water pollution, but also with air pollution associated with well stimulation. And I hope that monitoring of both will go on simultaneously. … These toxic chemicals that are injected underground for oil and gas extraction must be kept out of our precious water. And these aren’t just toxic chemicals. These are acid. … it will poison our water. Not only the water the humans rely on but also the water the birds and animals rely on. … “
Chair Joaquin Esquivel thanked the commenters for their thoughtful comments, noting that this is just an informational item, and the Board is making no decision at this time. “The comments certainly remind us of the balancing the board is constantly and continually called to do, the job that we have here to protect water quality for the long term.”
Board member Laurel Firestone expressed her concerns about the lack of adequate progress on project-by-project reviews for the ongoing UIC projects ongoing in our state, acknowledging that it’s likely out of the Board’s control. “I do feel like we have the responsibility of ensuring that activities in our state are not impacting water quality. I also understand there are some procedural pathways … it sounds like two-thirds of the active projects haven’t been able to be brought before us yet to do that review, but I am particularly concerned about that. I’m particularly concerned about the lack of identification and plan around orphan sites and orphaned wells. That’s something that I think is a very significant and important threat to our water quality, and one that I think is a real concern to ensure our mission as the water board.”
“I want to speak on the aquifer exemption process because I know that is particularly important to our role to protect drinking water aquifers in particular,” said Ms. Firestone. “I am very concerned about actions to adopt exemptions, which are basically permanent abandonment of aquifers to be protected as a drinking water source. It’s a very, very serious and permanent decision. And it especially concerns me when we have scarcer and scarcer resources for drinking water sources. It’s probably appropriate in certain places, and we have roles and clarity around when that is the case. But in making that determination, we really need to take that extremely seriously because of the permanent impact that that exemption has.”
“One of the real challenges we have especially given the lack of information around orphan sites, lack of access to land or monitoring capabilities in certain places, and particularly the lack of information on abandoned wells and other sources of conduits,” continued Ms. Firestone. “I have real concerns on being able to make the determination that there isn’t a migration pathway when we lack evidence around those very real potential conduits.”
Board member DeDe D’Adamo thanked the staff for the report. “I just want to express the confidence that I have in staff and really want to thank stakeholders for raising issues and for just being patient with us as we undergo our due diligence in working with our sister agencies and for identifying some really good areas for us to dig a little deeper.”
Board member Sean Maguire noted that there are many unknowns about what goes on thousands of feet underground. “I appreciate certainly all the concerns about the orphan wells, all the kinds of conduits that exist, and just the uncertainty that’s inherent in these practices. … I really appreciate the public comments, particularly the comments on the Fox Canyon USGS study that was recently released. I want to flag for staff that’s something I’m certainly interested in learning more about. … I certainly want to be sure that we’re careful and how we characterize the results of those studies, in terms of what we know, and what we don’t know, and what we were able actually to determine or where there are no additional uncertainties going forward. … certainly, if folks are misinterpreting some of the results and findings, I’d be interested in finding ways to summarize better and articulate where those limitations are.”
Board member Tam Dudoc said she shares Board member Firestone’s concerns because of the magnitude and the consequences of the decisions that are being made. “I appreciate not only the technical complexity but the policy complexity. There’s also this dynamic that we have with Cal GEM, who is the lead on most of these projects, and all of that together provides for some complicated situations. This is something that we’ve delegated to our wonderful staff, who have a great deal of expertise in this matter. It is evolving over time – our expertise, our involvement, our engagement with Cal GEM, and our engagement with the stakeholders. Potentially in the future, this Board may examine some of the current processes and the current delegations in decision making. But so that is not the decision to be made today. But I’m grateful that Board members Firestone, Maguire, and others are paying a great deal of attention to, to the efforts involved ... “
Chair Joaquin Esquivel then closed the agenda item by acknowledging that it’s only been a few years of implementing the legislation that created the role for the Board as a technical sister agency to Cal GEM in oversight of the program, and the program will continue to evolve. “I think we have opportunities there to continue to do better by the decision making. Certainly, what we hear is, the technical nature of it is sometimes hard for even communities to follow along and understand how they’re being protected. And I think there are ways that we can continue to make sure we incorporate everybody in a transparent way around the studies around continuing to just be data-driven, and understand where the sources of the various hydrocarbon and other residuals we see in the aquifers are. They are linked to activities that we have a hand in regulating, ultimately.”