I was looking at a couple of drilling sites. Both are at least 4-5 years old. One was unitized and the other not - again, years ago. Both had roads made and have pads but never had wells drilled. In the past month both have new permits submitted to DEP and are pending. These are E&S Stormwater General permits. Can anyone explain why a company would do that? Would that mean they are anticipating doing more work at the sites - either to clean it up before exiting or to move toward drilling? I can't remember what those type of permits are for specifically and what if anything it might signify.
I would agree with John, the company will renew or apply for new permits to stop the clock from ticking for reclamation. Without an active permit or activity on the site, the company is required to reclaim the pad within 9 months (up to 2 years) and that cost is much higher than a several thousand dollar permit.
So it may be just a matter of holding onto a site and extending the time-frame. That would make sense. Thank you guys for taking the time.
E&S stormwater permits are for Erosion and Sedimentation control only, and basically have nothing to do with the actual drilling for a well. It is all to do with the pad construction site and the "acres of disturbed ground" on and around the pad and preventing storm water/erosion and sediment run-off. It is required for any "land disturbance" activities that meet the scope of the general permit for land disturbance. ( a building site, large parking lot, pond, whatever land disturbance activity has to have a E&S permit in place to start construction if it meets certain size and location criteria) It is easier and cheaper to renew permits than to start all over. Not to mention without a renewed permit, they would be in "non-compliance" and be subject to legal action, or have to return the site to original grade, slope and re-vegetate etc...