The U.S. Environmental Protection Agency took a big step this week, announcing the nation’s first methane pollution standards for the oil and gas industry. But to understand the impact of these new draft rules, it’s important to look at what they do – and what they don’t – and measure them against the nation’s bold but readily achievable goals set out by the Obama administration earlier this year.
The president’s target of reducing methane emissions by 40 to 45 percent in the next decade is historic – currently there are no national limits on methane pollution from the oil and gas industry. It’s also critical to protecting the climate and public health – methane packs more than 80 times the warming power of carbon dioxide over a 20-year timeframe, and is released along with other toxic pollutants.
The scale of the problem is massive, with industry releasing more than 7 million tons of methane each year. It could also be even bigger than we realize. A new study published just this week reported unrecorded methane emissions from thousands of facilities in only one part of the supply chain. It concluded gathering facility emissions were eight times higher than estimated, a staggering figure that if included in EPA’s inventory would increase current estimates of total industry emissions by 20 percent.
So, how does the new proposal measure up? Here is our first take on some of the key elements:
A down payment on the nation’s goal
EDF has always believed that a direct approach is the best approach. So it’s great to see that EPA addressed methane head-on. But targeting existing sources of methane pollution will be critical to achieving the nation’s reduction goal, and EPA’s proposed rules deal largely with methane from new and modified sources, leaving 6.7 million metric tons on the table from infrastructure supporting the 1 million wells already in operation. Taken together, EPA projects these actions will reduce methane by 560 to 620 thousand short tons which, for context, represents about 7 to 8 percent of the total emissions from the oil and gas supply chain in the 2012 Inventory.
While the EPA rules are just one of several actions that will help the nation cut methane pollution by 45 percent, they are one of the most important.
Additional actions will be needed to meet this goal, including decisive action to tackle the biggest part of the problem—emissions from wells, pipelines, and facilities in operation now. Indeed, over the next few years, 90 percent of emissions will come from existing, not new sources.
The proposed standards include a pathway for addressing existing sources in non-attainment areas, through control technique guidelines (CTGs) to get at volatile organic compounds, an ozone precursor. For many of the existing sources covered by CTGs, EPA leverages the same technologies and practices that the agency proposed to apply to new sources in the rest of its rules – demonstrating that we have the technologies to cost-effectively deal with new and existing emission sources. Indeed, states like Colorado and Wyoming have effectively applied standards to reduce oil and gas emissions from existing and new operations based on these technologies, and EPA should follow.
Frequent Leak Monitoring is a Priority
We know that leaks are a big source of oil and gas methane emissions and that regular inspection and maintenance can go a long way toward reducing the emissions. It’s a good thing that EPA’s proposal included leak detection and repair, and that these requirements apply to both well sites and compressor stations across the natural gas supply chain. They also require operators to look for leaks at components and pieces of equipment (like storage tanks) that can be very significant sources of emissions.
Frequent monitoring for leaks is critical to mitigating methane emissions, as leaks can emerge anywhere at any time and can be difficult to predict. EPA’s proposal included provisions for semi-annual and annual monitoring, and in certain cases, also proposed to allow facilities to reduce the frequency of their monitoring requirements. States like Colorado and Wyoming have recognized that more frequent monitoring is necessary and highly-cost effective to stay on top of emissions. EPA has requested comment on this and it will be important for the final standards to reflect these states’ leading practices.
Liquids unloading sidelined, for now
Last fall, EPA issued a set of five technical white papers, analyzing the biggest sources of methane and cost-effective technologies capable of reducing those emissions. EPA’s new standards address new and modified sources in four of these five categories—equipment leaks, pneumatic devices, compressors, and oil well completions. It took some good steps here, including extending green completions to oil wells, as leading states Colorado and Wyoming have already done. And, these requirements apply across segments—including production, gathering and boosting, processing, and transmission and storage.
EPA took comment on, but did not propose to address, the fifth source—liquids unloading, a common maintenance practice operators use to purge liquids that accumulate during production. We know from scientific research that this is a big source of emissions, and states like Colorado have already taken action to address these and standards for liquids unloading will be an important feature of a rigorous final rule.
Let’s Get Going
The lion’s share to the reductions needed can be achieved simply by transforming the best practices already demonstrated by companies in the industry into the standard practices used throughout the industry.
Those who have first-hand experience successfully putting these practices to use didn’t shy away from sharing their thoughts on the rule. Some of the more responsible companies in the field, who have already seen the benefits of methane reduction efforts, showed support for EPA’s action, despite the typical outcry against regulation by many of the usual industry players.
And from Colorado, which in 2014 became the first state to directly regulate methane emissions, Governor John Hickenlooper also put his support behind the rule, saying that “protecting public health and the environment, and promoting our energy industry are not mutually exclusive endeavors.”
It’s time to translate this success and support into action – working over the coming months to strengthen EPA’s rules so we can put them into practice and start achieving the reductions we need to protect our health, environment and economy.