Radical Transparency – Compliance Process and Violations
Pennsylvania has one of the most comprehensive and stringent regulatory environments for oil and gas operations in the country. CNX takes our duty as a responsible operator very seriously and we have implemented an Environmental Management System that is overseen by skilled environmental compliance experts in our Operational Excellence and our Environmental Strategy teams. These teams are dedicated to our environmental stewardship efforts and ensure compliance with environmental laws, regulations, and proactive improvement efforts.
The Department of Environmental Protection (DEP) and other regulatory agencies perform regular inspections of our sites. For example, there were 969 inspections performed on CNX sites by the PA DEP Office of Oil and Gas Management and recorded in the system over 2022–2023. That’s almost 1.5 per day on average, seven days a week, 365 days a year. During that time period, 943 of these inspections had no findings, 24 inspections were triggered because CNX had self-reported events, and two events were discovered by inspectors. To learn more about the number of violations the public sees and the correlation to the number of events that actually occurred, as well as the process CNX and the DEP follow, read this article “Challenging Environmental NGO/Media Optics with Facts and Data”.
The important thing to note is that if an event occurs, CNX self-reports to the DEP and quickly acts to remediate. CNX has been around this region for over 160 years – our team members were born here, live here, and desire to stay here. Our kids and parents breathe the same air and drink the same water as everyone else. It’s why we jumped at the chance to embrace Radical Transparency. It’s also the foundational reason why CNX works diligently with the regulatory community to self-report any incident, to efficiently abate any violation, and to always work with the agency to correct or improve the system.
We have a duty to respond in writing to NOVs we receive from the DEP and while we may disagree with the number of citations cited/interpretation of the law, CNX rarely takes the step to appeal the violations we receive, preferring to work instead with our regulators to resolve outstanding issues quickly and efficiently. Because when issues can be resolved without applying undue strain on DEP resources and taxpayer dollars that a costly appeal process entails, the outcome is better for all Pennsylvanians.
CNX is further committing to our Radical Transparency program by disclosing every Notice of Violation that we receive (listed below) and will continue to disclose the data for NOVs across federal, state, and local regulatory agencies on our ESG Performance Scorecard, along with the penalties we have paid, for our entire operating footprint.
Failure to plug a non-producing well
Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards
CNX will be plugging the well. The well is being added to the plugging schedule for 2026.
Failure to identify 2 requirements when filing well site restoration reports.
Correction in progress.
CBM (Coal Bed Methane) – a type of gas well.
E&S (Erosion & Sedimentation) Controls – Controls installed to prevent earth movement caused by rain events / sheet flow.
ESCGP (Erosion & Sediment Control General Permit)- an earth disturbance permit associated with oil and gas activities.
ICS (In Compliance with Schedule) or ICP (In Compliance with Policy) – typically used to describe a pre-existing issue where the repairs are proceeding as planned.
LOD (Limit of Disturbance) – as per the permit, this refers to the outermost boundary of the area that can be disturbed.
NOT (Notice of Termination) – a document filed with the DEP to effectively terminate an existing earth disturbance permit. Filed after all planned earth disturbance is completed.
NOV (Notice of Violation) – issued by a regulatory agency to indicate a potential issue.
PUC (Public Utility Commission) – regulatory agency that oversees natural gas, pipeline, water, and wastewater services.
VIOIC (Violation Onsite Immediately Corrected) – regulatory agency identified
To find more information on compliance and enforcement or specific information on violations (when available) in these states please visit: Virginia Energy – Gas and Oil – Inspection and Enforcement, PADEP Oil and Gas Compliance – Report Extracts, WVDEP Office of Oil and Gas Enforcement Search, or Oil & Gas Inspections and Enforcement | Ohio Department of Natural Resources.
