Category Archives: Oil

It Makes Dollars & “Sense” To Capture Air Emissions

Oil and gas exploration and production is rapidly expanding across the U.S. due to technological developments that have made extraction of previously untapped unconventional resources such as shale gas feasible.

In fact, shale gas production “has gone from a negligible amount just a few years ago to being almost 30% of total U.S. natural gas production.” 

But national clean air standards covering these activities have not been updated since 1985 in one case and 1999 in another. They are limited, inadequate, and out of date, particularly given recent technological advances in this area. 

This poses a serious problem, since exploration and production activities emit numerous hazardous air pollutants and other airborne contaminants that threaten human health and the environment. Communities across the country are paying the price, suffering from air pollution in the absence of protective, comprehensive standards. 

In July, the Environmental Protection Agency (EPA) proposed new nationwide safeguards to reduce air pollution from upstream oil and gas production activities.  Recently, the public was given a chance to express their opinions on the issue at three hearings held in Pittsburgh, Pennsylvania, Denver, Colorado, and Arlington, Texas. EDF testified at all three. (Public written comments will be accepted through November 30th and EPA is required to issue a final rule by February 2012. You can submit comments online, via fax or through the mail. In your correspondence, please be sure to reference Docket Number EPA–HQ–OAR–2010–0505; FRL–9456–2.)

I testified at the EPA hearing in Pittsburgh where compelling concerns were raised by many in the communities hard hit by air pollution impacts.  People in communities across Pennsylvania expressed concern that adequate protection from dangerous pollution in their home state is simply not in place. Some pleaded with the EPA to finalize new standards, others expressed anger that EPA has not done so already, and many fear that the new standards won’t be tough enough to keep their families safe.   

The individual who testified before me declared that when it comes to our health and that of our children, the costs of cleaning up harmful pollution should not factor into EPA’s decision-making. He got a standing ovation.

Of course, the hearing also featured industry representatives, some of whom echoed the position of the American Petroleum Institute (API) calling for more time to comment on the proposed standards and to delay their implementation.

Yet, the truth is that the proposed EPA rules will standardize many practices and technologies already being used in states such as Colorado and Wyoming, and elsewhere by natural gas companies. Further, these practices and technologies reduce gas losses, which results in greater recovery and sale of natural gas, and thus increased economic gains. The return on the initial investment for many of these practices is sometimes as short as a few months and almost always less than two years.  In these tough economic times, it would seem wise to eliminate waste, save money, and reduce environmental impact.

Based on EPA estimates of natural gas losses, industry lost more than $1 billion in profits in 2009 due to venting, flaring and fugitive emissions.  The U.S. Government Accountability Office (GAO), with supporting data from EPA, estimates that around 40% of natural gas estimated to be vented and flared on onshore federal leases could be economically captured with currently available control technologies. Recouping these losses could increase federal royalty payments by $23 million annually, at a time when revenue is desperately needed.

The industry can demonstrate their commitment to bringing natural gas to market in an environmentally sound way by using best practices, acknowledging the benefits of these safeguards, and being proactive in helping them get adopted.

And, while EPA’s proposed rules are a great start, there is room for improvement (for more details, see EDF’s preliminary analysis of the regulations). Bottom line: it is critical that stronger clean air standards move forward.  They are vitally important to protect human health and the environment.

At the EPA hearing in Pittsburgh, the public demanded that EPA require industry to be more vigilant about health and safety, and reduce their environmental impact.  Considering the potential increased revenue of capturing more gas, advocating for strong clean air rules makes both dollars and “sense.”

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The Price We Pay For Outdated Clean Air Standards

The Environmental Protection Agency (EPA) is in the process of updating national safeguards to better protect Americans from the health impacts of natural gas and oil emissions. The standards address the emissions discharged during gas and oil drilling and development practices, known in the industry as ‘upstream’ activities.  

Residents around the growing number of drilling, processing and transmission sites will be relieved to hear this because while industry activity has increased dramatically in the U.S., the Clean Air Act standards that regulate the related air pollution are outdated.  Current standards are limited and fail to adequately protect public health.

These industrial activities discharge a host of air pollutants. Drilling rigs, wells and equipment emit hazardous air pollutants such as benzene, a known human carcinogen.  

A number of other airborne contaminants contribute to ground-level ozone or "smog" pollution, elevated levels of which can lead to:

  • decreased lung function, particularly in children who are active outdoors;
  • respiratory-related hospital admissions and emergency room visits  among both children and adults; and
  • lung inflammation, possible long-term damage to the lungs and premature mortality.

Upstream drilling activities were the single largest source of ozone precursor pollutants in Colorado in 2008. The Texas Commission on Environmental Quality reports that storage tanks used in the exploration and production of natural gas in Texas are the largest source of volatile organic compounds (VOCs) in the state. These contaminants contribute to smog and also are comprised of hazardous air pollutants. And according to a recent inventory, oxides of nitrogen and VOC emissions produced from gas production in the Barnett Shale are comparable to the combined emissions from all the cars and trucks in the Dallas Forth-Worth metro area.

Oil and natural gas activities also are the single largest source of U.S. methane emissions.  Methane is both a potent greenhouse gas and a contributor to smog.   In 2009, methane emitted from these activities was roughly equivalent to the carbon dioxide emissions from 60 coal-fired power plants. 

The media is starting to cover the plights of individuals and families who are suffering from exposure to these pollutants. National Public Radio did a story on a family in Pennsylvania that had a number of health symptoms due to drilling. “First Pam, her husband and two grown kids started getting headaches, and then fatigue set in. They've also had dizziness, nausea and nosebleeds. I've had a sore throat so long that I don't know what it would be to not have a sore throat," Pam says. For a week last summer, Pennsylvania state officials monitored the air at the Judys' house and the compressor station. They found…toxic chemicals they say almost surely came from the compressor station.”

It is vitally important that EPA strengthen national emission standards. Improved emission standards will help protect millions of Americans, urban and rural, who live in the vicinity of oil and gas air pollution discharges.

Rigorous federal guidelines will also foster industry innovation and emerging technologies, and increase profits by using available best practices to capture saleable gas that’s otherwise released into the atmosphere.   

Updated safeguards are long overdue but there is no guarantee that they will be the strong standards that are essential to protect the public's health. You can help ensure that they are.

We encourage everyone who wants to breathe cleaner air to let the EPA know you support strong and comprehensive standards for the natural gas and oil industry.

Please get involved by writing to the EPA in favor of updated protections. We also invite you to join us and share your thoughts with the EPA at the upcoming public hearings in: Pittsburgh, Sept. 27; Denver, Sept. 28; and Arlington, Texas on Sept. 29. If you can't make the hearings, you can submit comments online, via fax or through the mail until Oct. 24. In your correspondence, please be sure to reference Docket Number EPA–HQ–OAR–2010–0505; FRL–9456–2.

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Energy Producers Capture More Today Than In "Good Old Days" But We'll All Benefit If They Do Better

In the frontier days of drilling in the 1900s, discoveries such as Spindletop in Texas and the Drake in Pennsylvania heralded a new era of energy for America. Back then, the gaseous by-product produced at the wellhead was considered a nuisance and flared (burned) or released into the air. Today, it's considered a valuable energy source and routinely harnessed, which results in economic and  environmental benefits. Capturing gas cuts emissions that contribute to ground-level ozone, cause cancer, and contribute to climate change.

Given that it’s 2011, we’re way past the conditions of the 1900s. But, whereas the process of capturing natural gas as an energy source has come a long way, many improvements must still be made to ensure producers capture the maximum amount of natural gas “upstream” at wellheads and throughout the gas processing and transportation network.

Just because the gas can’t be seen doesn’t mean it isn't hazardous. In the last three years, new data shows that natural gas leaks might be twice as high as previously thought. This means that a lot more air pollution is fouling the air we breathe.

The pollution comes from equipment on-site (tanks, valves, compressor engines, flanges), at processing plants (where raw natural gas is purified for residential and commercial use) and throughout the pipeline system.

If you know anyone that lives near drilling sites — such as the Barnett Shale in Texas, the Marcellus Shale in Pennsylvania, Piceance and big chunks of Colorado and Wyoming — you’ve likely heard stories about their public health and environmental impacts.

EDF sponsored a study showing that the emissions produced by natural gas operations around Barnett Shale rival those from 4 million cars and trucks in the Dallas-Fort Worth metro area. Around the country, those who live nearby drilling sites have reported higher incidents of health concerns including respiratory and skin irritation, neurological problems, dizziness and headaches. And in some instances, elevated levels of benzene — a known carcinogen — have been detected.

The Environmental Protection Agency (EPA) has proposed rules that would require use of technologies and practices to capture more of the natural gas now being allowed into the air. These clean air standards are sensible, which makes you wonder why it’s taken a century to put these rules into place at the national level. It also makes you wonder why industry would fight them when they can capture more natural gas and bring it to market. Indeed, in addition to the health and environmental benefits of the rule, there are economic benefits.

A number of natural gas companies already use the practices that the EPA is proposing to cut methane and are touting the resulting economic benefits.

Similar requirements to those the EPA proposed have been in place in Colorado and Wyoming without adverse affects on companies’ profits. Who isn’t for a win-win solution?

I’ll be blogging more about this proposal in the coming days. Please get involved by writing to the EPA in favor of updated clean air protections. We also invite you to join us and share your thoughts with the EPA at the upcoming public hearings in: Pittsburgh, Sept. 27; Denver, Sept. 28; and in Arlington, Texas on Sept. 29. If you can't make the hearings, you can submit comments online until Oct. 24.

There's no better time than now to make your voice heard and show your support for clean air.

 

 

 

Also posted in Climate, Health, Natural Gas | Tagged | Comments closed

Put My Tax Dollars Into A Growth Market, Please

Guest Blog Post By: Jackie Roberts, EDF's Director of Sustainable Technologies, National Climate Campaign

Two efforts to repeal tax breaks for oil and gas companies – Senate Bill S.940 and the Administration’s budget proposals to eliminate subsidies in FY 2010, FY 2011, and FY 2012 budgets – should receive bipartisan support for no other reason than re-directing those subsidies can be an engine of job creation.  University of Massachusetts at Amherst economic researchers developed employment estimates for various energy sources, including energy efficiency strategies.  Their data show that investments in energy efficiency creates 2.5 to four times more jobs than that for oil and gas development and renewables create 2.5 to three times more jobs than that for oil and gas development.

These jobs are dispersed throughout the U.S. as shown with our LessCarbonMoreJobs mapping, and bring particular benefits to the hard hit Midwest manufacturing regions.

Large government subsidies might, just might, be justified if “Big Oil” was using profits to invest record amounts in transitioning to clean energy.  But, that is far from the case.  A Center for American Progress analysis of Big Oil investments reveals that the big five oil companies invested just four percent of their total 2008 profits in renewable and alternative energy ventures.  There are no signs that this level of investment has increased at all in the past several years. 

Clean energy will be a major new market – by some estimates the market for renewables alone will range from $1.7 trillion per year to $2.3 trillion by 2020, depending on different government policy scenarios.  Having already slipped from first to third in terms of investments in this sector, the U.S. needs to play catch up.  Government dollars should be used to help the U.S. transition to clean energy and to do so in a way that we have significant market share in as many clean energy solutions as possible.  First mover advantages are critical with new markets and worth every penny we can devote to creating strong clean energy innovation and manufacturing here in the U.S.  Such investments will also translate into cheap, homegrown energy sources in the medium- to long-term – the supposed purpose of the oil and gas subsidies.  Put my tax dollars into a growth market, please.

Also posted in Energy Efficiency, Renewable Energy, Washington, DC | Comments closed

(Update) TCEQ Buckles On Oil & Gas Rules Under Pressure From Industry

Last week we lamented about the TCEQ’s capitulation to industry pressure on proposed rules dealing with emissions from oil and gas facilities. 

State Representative Lon Burnam provided us with a sampling of documents showing the influence exerted by industry during the tail end of the process.  These are just a smattering of the roughly five reams of paper his office received in response to a public information request.

In hopes that it might serve as a resource to others, we are also posting several other documents pertaining to the rulemaking:

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Natural Gas Industry Wins The Award For Chutzpah

Chutzpah.  That’s how Washington lawyer Matt Armstrong, of Bracewell & Giuliani, characterized the possibility that the US Environmental Protection Agency (EPA) would now take enforcement action against natural gas drillers who injected millions of gallons of diesel fuel into the ground to facilitate hydraulic fracturing, or ‘fracking’, to extract  natural gas trapped in shale formations thousands of feet below.  His point was that the EPA – having taken little action to develop clear regulations banning or restricting this particular practice – can’t pretend that they always disapproved of diesel fuel injection now that a Congressional investigation spearheaded by Henry Waxman and Ed Markey has brought it to light. 

While I think Armstrong may have a point about the EPA being asleep at the switch on this one, and I take him at his word that he, and the natural gas industry clients he represents, welcome clear and effective federal regulations restricting or – better yet – banning this practice, I can’t help but conclude that it is the natural gas industry, rather than the EPA, that wins the award for chutzpah.

Part of the reason that anti-shale gas campaigners are gaining such traction with the general public is that the natural gas industry makes it so easy for them.  Does any CEO of any natural gas production company really think that the general public would ever believe that injecting diesel fuel into the ground is a good idea?  This little episode only further underscores the perception that when the natural gas industry unflinchingly opposes public disclosure of the chemicals used in “frac fluids” – or, as my colleague Ramon Alvarez pointed out yesterday – when the oil and gas industry sue to block recently adopted EPA regulations requiring basic air pollution reporting that, indeed, the industry really does have something to hide.  

Being tone deaf to public perception is not a crime, but when you turn around and blame the regulatory agency you regularly oppose for failing to stop you from engaging in what is obviously a potentially harmful practice that they should have been regulating, you certainly are guilty of chutzpah.  If the natural gas industry ever expects to be embraced as a responsible partner in transitioning this nation to a safe, secure, low-carbon, clean energy future, natural gas production practices need to dramatically improve and the stonewalling and finger pointing at others need to stop.

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Gas Industry Lawsuits Undermine Americans' Right To Know About Dangerous Pollution

It was disappointing, but unfortunately not surprising, that Chesapeake Energy and three natural gas industry trade associations filed legal challenges to EPA’s new rule that requires assessment and public disclosure of the industry’s greenhouse gas (GHG) emissions. 

I find it ironic that the industry that touts itself as the “low-carbon” fossil fuel is fighting efforts to require disclosure of its global warming pollution.

Learn more about this in our news release sent out earlier today.

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TCEQ Buckles On Oil & Gas Rules Under Pressure From Industry

After a 10-month process, the TCEQ finally ended the suspense regarding what emissions safeguards the oil and gas industry will have to follow in order to protect the citizens of Texas.   On Wednesday, the TCEQ adopted a much, much weaker rule than the one it proposed in July (see details at the bottom of this post).  The rule was dramatically scaled back to apply only to those living near the Barnett Shale near Dallas-Fort Worth and, miraculously, the process will begin anew to decide what protections will apply elsewhere. 

If you are reading this, you are probably wondering what I think about the outcome.   I’ll answer by telling you what I am going to tell my boss, who will surely ask how my efforts – scores of hours attending meetings, writing comments, coordinating and consulting with experts on this topic (as well as having to watch industry unrelentingly bully TCEQ staff) – translated into results.   

It is a fair question given that I truly threw myself into this one.  I convinced myself (and my boss) that – this time – it was going to be different.  With all of the attention focused on the emissions from natural gas operations, including reports showing how the emissions from the oil and gas industry were much higher than everyone assumed, I thought this time we actually had a chance to help TCEQ do the right thing.   

The most favorable answer I can give is that “it could have been worse.”  Maybe, just maybe, had we not made the effort, the final rule might have been even worse.  What issues went in favor of public health?  The TCEQ did expand the proposed definition of “receptors” that must be protected to include hospitals, day cares, and certain businesses (although this definition is still less protective than many other agency rules).  Oh, and in response to our expert modeler’s numerous examples showing that the agency’s modeling did not represent “worst-case” conditions as claimed, the TCEQ changed their description to “reasonable worst case” (while making numerous other changes that allowed far greater emissions of harmful pollutants than originally proposed).  Sadly, that’s all I can say went in a positive direction. 

The TCEQ’s initial proposal in July would have established a basic framework that provided greater assurances of protectiveness to the public.  But industry firepower overwhelmed the TCEQ staff, which had little, if any, apparent support from their Commissioners.  The final rule was gutted with so many exceptions and loopholes (see below) that it almost makes me wonder if there is sufficient environmental benefit left to justify the regulatory burden.  Especially troubling was the number of sweeping changes made to the rule during a 6-week continuance, out of the public eye, during which time staff was asked to attempt to resolve industry concerns.  

In the end, I have no choice but to admit that my time would have been better spent on something else.  This story is yet one more example of why the legislature’s required sunset review of the TCEQ is so timely.  It is time for the TCEQ to put the protection of public health and the environment first.

On this last point, State Representative Rafael Anchia (D-Dallas) who serves on the state’s Sunset Advisory Commission, ably captured the situation in an interview on KUT’s feature “Letters to the Lege” this morning:

“In hearings we’ve held, we’ve heard complaints from all over the state … and there’s definitely an issue at the TCEQ when it comes to the response to citizen complaints. There’s no doubt about it. The EPA is seriously put out with the TCEQ and there’s a real standoff going on right now between the Perry administration and the federal government on how the TCEQ regulates pollutants in Texas. And in my opinion, we need to shake the agency up and make it more responsive to the public.”

At EDF, we completely agree.     

Key Examples Of How The July 2010 Oil & Gas Permit by Rule Proposal Was Weakened:

  • Applies only to Barnett Shale. A new rule will have to be developed by January 2012 to apply to the rest of Texas
  • Allowable hourly emissions of benzene increased by up to a factor of 20X
  • Eliminated formaldehyde emissions limits and protectiveness review
  • Increased VOC and other pollution limits, and removed limits for others
  • Created an exception for “small operations,” specifically projects with a maximum engine horsepower (450 hp or less depending on fuel), or five defined combinations of emissions sources and components.  These only have to maintain equipment in good working order and maintain a minimum 50-foot setback with no notification to TCEQ required
  • Protectiveness review only required for new or modified sites within ¼- or 1/2- mile from a receptor (depending on size of facility), and excludes consideration of existing emissions at modified sites if the off-site concentrations are less than 10%-25% of an Effects Screening Level
  • Removed prohibition against increasing emissions of applicable pollutants in an Air Pollutant Watch List Area (where pollution levels already exceed the TCEQ’s own acceptable risk levels)
  • Replaced Executive Director’s right to deny a permit for good cause with limited additional pre-conditions for a permit

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