EPA methane rollbacks contradict agency’s own scientific findings

By Rosalie Winn and Hillary Hull

As the world races to adopt cleaner fuels and implement carbon-reducing strategies to combat a warming climate, the Trump administration is moving feverishly to severely weaken federal methane emissions regulations across the entire oil and gas industry.

The Trump EPA’s current proposal to weaken the New Source Performance Standards 2016 methane rule will add 480,000 tons of methane, a potent greenhouse gas, into the atmosphere within the next seven years, while simultaneously wasting tens of millions of dollars-worth of natural gas.

The EPA is proposing to weaken the current standards in the face of recent research warning that excessive waste of natural gas (methane) from the oil and gas sector is much higher than previously estimated, underscoring the harmful climate implications of methane leaks from oil and gas production well sites. This move also comes on the heels of a new federal government report published last month highlighting the dire social and economic consequences of climate change.

Particularly baffling is that the EPA’s own new analysis recognizes that increasing methane detection efforts will reduce methane emissions in the atmosphere, and doing so is more cost-effective than originally estimated by the agency. Despite the agency’s own scientific conclusions, the Trump EPA is choosing to move forward and weaken the standards, disregarding logic and common sense.

The new EPA proposal targets methane leak detection efforts, otherwise known as leak detection and repair (LDAR), by significantly decreasing the frequency of routine operator equipment visits conducted to check for methane leaks. Details on the proposed changes can be found here.

Looking for leaks less often will result in more wasted gas—and further warming of the atmosphere. For instance, in Colorado, which requires oil and gas companies to check for leaks as often as every month, companies found roughly 75,500 leaks from 2014-2017.

Costs decreasing, benefits rising

In its rush to justify its proposal based solely on cutting short-term costs for the industry, the EPA has ignored that the current rule is in effect and working. The measures required by the current rule have been successfully implemented across the country and have consistently proven to be not only feasible, but also less costly than EPA originally predicted, as operators earn additional profits by capturing and selling gas that would otherwise be lost.

Even now, the EPA re-analyzed the 2016 rule’s fugitive emissions standards and found the benefits of LDAR to be even greater—and cheaper—than the Obama EPA had estimated. EPA admits in in its proposal that the original standards “appear to be cost-effective” under its own updated analysis.

Furthermore, the true benefits and cost-effectiveness of the current standards are likely underestimated by EPA, which calculated emissions reductions based on data from the U.S. Greenhouse Gas Reporting Program. Earlier this year, a study found methane emissions were underestimated by 60 percent by the EPA. When EDF calculated the impacts of EPA’s proposed rollback using this latest evidence, we found it will in fact allow over 160,000 tons per year of additional methane in 2025—which is 2.9X higher than estimated by EPA.

Harm to public ignored

In its proposed rollback, EPA has failed to fully account for harm to the public—including the social costs of additional climate emissions, pollution, and other health-harming pollutants, such as smog-forming volatile organic compounds and cancer-causing benzene.

The agency also dramatically underestimates the social cost of methane, an economic measure of the future harm caused by climate change due to methane emissions. EPA disregards the widely accepted and peer-reviewed social cost of methane developed by a group of federal agencies, and instead relies on an “interim” social cost metric that ignores huge swaths of the harm caused by climate change. EDF analysis of the full social cost of methane shows that the climate costs of the proposal are more than seven times higher than estimated by EPA.

Rule gives states shortcuts

At the same time EPA is proposing to weaken federal leak detection requirements, the agency is also seeking to allow state programs with little to no protections to substitute for federal standards.

This runs contrary to the longstanding history of the New Source Performance Standards—which were meant to provide a uniform set of protections that all Americans can rely on. For example, in Texas, EDF analysis indicates that of the more than 12,000 wells subject to the current federal standards, at most eleven percent, and possibly as few as two percent, are required by the state of Texas to conduct some form of leak detection and repair. EPA is proposing to exempt Texas well production sites from LDAR requirements because of this program leaving the vast majority of wells currently subject to the NSPS in Texas unregulated.

While there is a growing segment in the industry of operators that are voluntarily adopting methane management programs, this group only represents 20 percent of the oil and gas industry, making common sense federal methane standards imperative to cut the needless waste of natural gas and reduce greenhouse gas emissions.

EPA’s proposed rollback ignores the extensive evidence supporting the current standards, including the agency’s own analysis, and will allow significant additional emissions of methane and other harmful pollution into the air. Please submit your comments here to the EPA by Dec. 17th to urge the agency to withdraw this ill-advised proposal.

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