Energy Exchange

If The Problem Isn’t Hydraulic Fracturing, Then What Is?

Today, at the annual meeting of the American Association for the Advancement of Science in Vancouver, the Energy Institute at the University of Texas at Austin released a major report titled, “Fact-Based Regulation for Environmental Protection in Shale Gas Development.” The report’s conclusions are those of the authors, though Environmental Defense Fund (EDF) helped the University of Texas at Austin define its scope of work and reviewed drafts during the course of the project.

What are the main conclusions? As has been the case in other inquiries, the University of Texas study did not find any confirmed cases of drinking water contamination due to pathways created by hydraulic fracturing. But this does not mean such contamination is impossible or that hydraulic fracturing chemicals can’t get loose in the environment in other ways (such as through spills of produced water). In fact, the study shines a light on the fact that there are a number of aspects of natural gas development that can pose significant environmental risk. And it highlights the fact that there are a number of ways in which current regulatory oversight is inadequate.

The following conclusions are particularly important: 

  • Many reports of groundwater contamination occur in conventional oil and gas operations (e.g. failure of well-bore casing and cementing) and are not unique to hydraulic fracturing.
  • Surface spills of fracturing fluids appear to pose greater risks to groundwater than hydraulic fracturing itself.
  • Blowouts – uncontrolled fluid releases during construction and operation – are a rare occurrence, but subsurface blowouts appear to be under-reported.
  • The lack of baseline studies makes it difficult to evaluate the long-term, cumulative effects and risks associated with hydraulic fracturing.
  • Most state oil and gas regulations were written well before shale gas development became widespread.
  • Gaps remain in the regulation of well casing and cementing, water withdrawal and usage, and waste storage and disposal.
  • Enforcement capacity is highly variable among the states, particularly when measured by the ratio of staff to numbers of inspections conducted.

The report deserves widespread attention. But it is by no means the final word on these topics. Chip Groat, who led the study on behalf of the Energy Institute, plans to tackle additional topics in the future. These include air emissions from natural gas operations, induced seismicity and a field and laboratory investigation of whether hydrogeologic connectivity exists between the Barnett Shale and aquifers and other geologic units above and below the formation.

To read the complete report, visit http://energy.utexas.edu/

Posted in Natural Gas / Read 11 Responses

Though The NOAA Study Provides An Important New Set Of Data, It Is Only A Limited Snap Shot

By: Steven Hamburg, EDF’s Chief Scientist

This week the National Oceanic and Atmospheric Administration (NOAA) released a study that estimates that natural gas producers in an area known as the Denver-Julesburg Basin are leaking roughly 4% of their gas – or methane – into the atmosphere.  Leaks of that magnitude could undermine natural gas’ role as a lower carbon alternative to coal and oil.  This is yet another contribution to the long running debate about exactly how much methane is vented or leaked during the production and distribution of natural gas.  The questions are: Why does this matter, and why is what NOAA saying an interesting and new contribution to this debate?

A recent paper in Science illustrates that reducing methane emissions and black carbon can have a positive near-term impact on the climate system.  It is becoming clearer that reducing methane emissions is key to reducing net radiative forcing (or the amount of energy reaching the surface of the earth), which – in turn – helps reduce the chances of a climate catastrophe.  The Environmental Protection Agency (EPA) inventory of U.S. greenhouse gas pollution shows that the oil and gas sector is the largest source of man-made methane, and most of those methane emissions are from leaks resulting from the production and transport of natural gas. 

As we’ve mentioned before, it is clear that the actual combustion of natural gas is cleaner than the combustion of gasoline or diesel, but there are other emissions associated with the production, delivery and use of those fuels.  Natural gas is largely methane, even when it comes out of the ground, and as a result is a potent greenhouse gas.  Over the first 2o years after it is emitted, a pound of methane is 72 times more potent than a pound of carbon dioxide when it comes to trapping heat.  As natural gas is produced and piped across the country, there are plenty of opportunities for it to leak into the atmosphere.  EPA estimates that leak rate to be somewhere between 2-3%, but the exact amount is the subject of much debate.

At a 2-3% leak rate, natural gas-produced energy has a net benefit to the climate system as compared to producing energy using coal.  If we want to reduce the risk of climate surprises and increasingly frequent extreme weather events, reducing leak rates from natural gas production is one of the most effective ways of doing so, at least in the short term.

Given that natural gas produced by un-conventional means already represents more than one third of US production, the key issue moving forward regarding leak rates is not whether they are high or low, but rather how to ensure that they are as low as technically possible.  The NOAA study provides an important new set of data, but only one snap shot of what is happening in natural gas production fields. 

Unfortunately, the news here is not good, in that it finds methane leak rates to be almost twice as high as the EPA estimates – which would mean that, in the short-term and absence of leak reductions, natural gas is unlikely to be better for the climate than is coal.  Though there are a few larger studies that are gearing up which plan to use a diverse array of techniques that add to the NOAA study to better define overall leak rates, scientifically sound and rigorous sampling and monitoring is still much-needed to quantify the average amount of methane emissions that result from natural gas production.  No matter what the data will show about leak rates, though, the next steps are clear – reduce leak rates!

One of the central questions that the forth coming research needs to answer is: Where are the leaks happening and, in turn, what needs to be done to minimize them? It is possible that a relatively small percentage of wells account for a large majority of emissions, meaning that getting practices right at just these high-emitting wells could reduce overall leak rates significantly.  

Getting practices right entails implementing the Department of Energy’s Shale Gas Production Subcommittee’s recommendations, which propose a focused set of steps for strengthening environmental management in the shale gas industry.  The Subcommitte’s report calls for measures to be taken to reduce emissions of air pollutants, ozone precursors, and methane as quickly as practicable and stresses the need for gathering the data necessary to determine whether, and to what degree, natural gas provides greenhouse gas benefits when substituted for coal or oil in energy production or transportation.

As EDF, and others, collect much-needed data the picture will quickly become clearer.  Stay tuned to the Energy Exchange for more information on this topic.

Posted in Natural Gas / Read 1 Response

Clean Energy And The 2013 Budget Proposal

Source: EcoWatch

In his State of the Union Address last month, President Obama made energy issues a focal point. Taking a clear stance, he said that it was time to “end the taxpayer giveaways to an industry that’s rarely been more profitable, and double-down on a clean energy industry that’s never been more promising.”  With this statement, President Obama is addressing the reality that government support for new energy sources is the lowest it has been in any point in U.S. history, according to a report by DBL investors.  “During the early years of what would become the U.S. oil and gas industries, federal subsidies for producers averaged half a percent of the federal budget.  By contrast, the current support for renewables is barely a fifth that size, just one tenth of one percent of federal spending.”

Going further in addressing climate change the President said, “I know that there are those who disagree with the overwhelming scientific evidence on climate change.  But here’s the thing.  Even if you doubt the evidence, providing incentives for energy efficiency and clean energy are the right thing to do for our future, because the nation that leads the clean-energy economy will be the nation that leads the global economy, and America must be that nation.”

On Monday he unveiled his budget proposal for FY 2013.  So, how does it hold up to the goals of his speech with regards to a clean energy future?

The Good News:

–       The world’s largest energy consumer, the Department of Defense (DOD), would receive approximately $1 billion for energy conservation efforts. This would further the DOD’s increasing commitment to renewable energy which now makes up 8.5 percent of its energy production and procurement.

–       With a 3.2 percent increase from the year before, the budget proposes $27.2 billion for the Department of Energy. Of that:

  • Research and development for energy efficiency, advanced vehicles and biofuels would get $2.3 billion
  • Renewable energy sources will get a $522 million increase and an additional $174 million for a revamped industrial technology-advanced manufacturing program.
  • $12 million would be directed towards multi-year research investments in safer natural gas infrastructure in order to reduce risks associated with hydraulic fracturing in shale formations.
  • Furthermore, pipeline safety would receive a 70 percent, $64 million, increase.
  • This 3.2 percent increase comes just as a report vindicates the DOE loan program, confirming that the “overall loan portfolio as a whole is expected to perform well and holds less than the amount of risk envisioned by Congress when they designed and funded the program.” Energy Secretary Steven Chu states that, “we have always known that there were inherent risks in backing innovative technologies at full commercial scale, and it is very likely that there will be other companies in the portfolio that won’t succeed.  But the vast majority of companies are expected to pay the loans back in full, on time and with about $8 billion in interest — while supporting a total of 60,000 American jobs and helping us compete for a rapidly growing global industry.”

The Bad News: 

–       Seeming to cave to current attacks, the fiscal 2013 budget proposes stifling cuts to the Environmental Protection Agency (EPA):

  • Reducing current agency funding levels by $105 million, the EPA is slated to receive $8.3 billion. This would make for the first time since 1994 that the agency’s budget was cut for three consecutive years.

–       Counterproductive cuts to USDA’s Natural Resources Conservation Service:

  • Proposed cuts for Farm Bill conservation programs would be about $600 million.
  • Already Congress has cut conservation funding by $2.8 billion over the last five years, representing 81 percent of the nearly $3.5 billion in Farm Bill spending cuts over that time period(FY 2008-2012).

Despite some disappointment, overall we at EDF are pleased that the President chose to not only speak to the importance of a clean energy future but that his budget reflects this as well.

Elgie Holstein, our senior director for strategic planning here at EDF and a former associate director of the Office of Management and Budget for Natural Resources, Energy and Science, sums it up well, “despite some flaws, the president’s budget is a big net plus for the environment, and we urge Congress to embrace the positive aspects of it.” That latter part will be the true challenge.

Vice president of EDF’s Energy Program, Jim Marston continues: “The fact is: clean energy and responsible environmental policy make good economic policy as well because they create jobs, while cutting energy and medical bills for American families. Look at it this way:  environmental conservation is cheaper than environmental cleanup, just like preventive medicine is cheaper than emergency room treatment. We applaud the President’s support of job-creating, clean energy programs.”

The President understands that getting our energy future on the right path is an essential foundation that our country needs to be competitive, provide jobs and protect our health and environment.

Also posted in Climate, Energy Efficiency, Renewable Energy, Washington, DC / Read 2 Responses

Mixed Bag Out Of Pennsylvania On Hydraulic Fracturing Chemical Disclosure

Last night the Pennsylvania (PA) General Assembly passed legislation on fracturing fluid chemical disclosure that, on the whole, isn’t half bad – particularly considering where they started.  Unfortunately, the bill contains a major flaw that prevents us from being able to hold it up as a model for other states to follow.  Still, there’s quite a bit to be liked.  More on that below.

I should also point out that the disclosure legislation was part of a much larger bill that addresses a broad range of issue related to shale gas development in PA.  The overall bill has been the target of quite a bit of criticism from local environmental groups – particularly for eliminating much of the discretion of local jurisdictions to manage and plan for oil and gas activities within their borders.  We didn’t work on those provisions, so I’ll leave it to those who did to offer up their assessments and, for now, just give a run-down on the disclosure piece.

As originally drafted, the disclosure provisions in this bill were, quite frankly, useless.  All they would have done is codify current rules at the PA Department of Environmental Protection (DEP).  Under those rules, companies only reveal the chemicals that have to get reported on material safety data sheets – which leaves out maybe half the chemicals used in fracturing fluids.  And there was no requirement for posting disclosures on an easily accessible website for the public to see.  That kind of regime comes nowhere close to what EDF calls “disclosure,” and it’s way behind the times in terms of where the national conversation is today.  So, EDF teamed up with the Pennsylvania Environmental Council to improve the draft.

The Good

The first thing to understand is that PA will require two kinds of reporting.  Operators will disclose chemical information on the well completion reports they turn in to the DEP after drilling, fracturing and beginning production on a well.  And then, certain operators will be required to also post their disclosures on Frac Focus, the disclosure website run by the Ground Water Protection Council and the Interstate Oil and Gas Compact Commission.

As for the well completion reporting requirements, they’re quite good.  Operators will have to disclose all the chemicals they use, along with chemical concentrations.  They’ll also disclose the trade-name additives they use and the purposes they serve.  Taking it a step further than what other states have done, PA will also require operators to report their water sources and how much recycled wastewater they use in hydraulic fracturing treatments – an important step forward in disclosure requirements.

As with every other state disclosure rule, PA will allow operators to claim trade secret protections to keep certain chemical identities confidential.  These claims will be governed by PA’s “Right to Know” law, which means PA will be on the leading edge of how states are currently dealing with trade secrets in fracturing chemical disclosure rules.  Companies will be required to actually submit their trade secret information to the DEP (instead of completely withholding it, as some states allow).  Citizens will have broad standing to challenge trade secret claims at the PA Office of Open Records; and when there are challenges, the burden will be on the DEP and operators to prove why a trade secret claim is legitimate.  We’re aware that some in industry repeatedly tried to gut the Right to Know provisions in the bill, and credit is due to Governor Corbett’s office for fending off those attacks.

As we’ve mentioned before, we support the recommendation of the DOE Secretary of Energy Advisory Board that “the barrier to shield chemicals based on trade secrets should be set very high.”

Finally, the PA bill gives added emphasis to the need for making information available in formats that are useful and user friendly.  Mirroring the language that was pioneered in the Colorado rule, PA is now the second state to call for improving the search functions on Frac Focus.

The Bad (and Ugly)

Unfortunately, the bill took a major wrong turn on one key point.  While operators of all oil and gas wells will be required to disclose chemical information on their well completion reports, only operators of “unconventional” wells will be required to post their disclosures on Frac Focus.  The bill defines unconventional wells as those that are drilled and fractured below the Elk Sandstone formation in PA.  We’re not sure yet how many wells this will leave out, but it’s a fair guess it will be a lot.  So, we’re really only getting partial public disclosure here.

That’s a shame.  Public concern about fracturing chemicals doesn’t have anything to do with geologic stratigraphy.  Spills, bad casing and cementing jobs, loss of well control and failures in waste containment facilities can happen regardless of the depth of your target formation.  The potential pathways for contamination are there for all wells (and arguably, they’re even higher for shallower wells).  So, there’s no rational reason why all wells shouldn’t be required to post their disclosures on Frac Focus.

PA is the only state that’s made this bizarre differentiation between conventional and unconventional wells.  We’ll be looking to fix that problem in the future.  And in the meantime, we’ll be working overtime to make sure no other state repeats this mistake.

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Are Natural Gas Vehicles Good For Climate Change?

Source: Pike Research

Last week, in a speech in Las Vegas, President Obama called for getting more natural gas vehicles (NGVs) on the road in the United States.  NGV proponents applauded the speech and immediately reiterated the conventional wisdom that because natural gas burns cleaner than gasoline or diesel, NGVs lead to reduced greenhouse gas emissions.  However, recent science shows that the conventional wisdom may not be right.

While it is clear that the actual combustion of natural gas is cleaner than the combustion of gasoline or diesel, there are other emissions associated with the production, delivery and use of those fuels.  Natural gas is essentially methane, a potent greenhouse gas.  Over 2o years, a pound of methane is 72 times more potent than a pound of carbon dioxide.  As natural gas is produced and piped across the country, there are plenty of opportunities for it to leak into the atmosphere. EPA estimates that leak rate to be somewhere between 2-3%, but the exact amount is the subject of much debate. 

What we do know is that whatever the percentage of methane that is lost to the atmosphere, it erodes the climate benefits of combusting natural gas.  In other words, the higher the leak rates the less the benefits.  If leakage is high enough, NGVs can actually be worse for climate for some period of time. A newly published study concluded that over 20 years, NGVs were worse for the climate than gasoline or diesel vehicles unless current leak rates are reduced.  With current leak rates, even after 100 years NGVs are no better for the climate than gasoline or diesel vehicles.

Because methane is more potent over shorter time frames, if we remove more methane now,  we can reap quick benefits for the climate system.  However, if we emit more methane now, it will have a greater negative impact on the climate system.  This may be precisely the outcome we get if we aren’t careful in how we proceed with NGVs.  Before large-scale policies encouraging NGVs are written into law, we should better understand the leak rate of methane from the natural gas supply and take actions to ensure it is low enough that putting more NGV on the road does not harm the climate. Understanding and reducing leak rates is critical to accepting NGVs as a legitimate GHG strategy. EDF is working to do this, but until we have better data and see an industry committed to reducing leaks, we will reserve judgment on whether the President’s call for accelerating NGVs is justified.

Posted in Natural Gas / Comments are closed

Improving New York’s Proposed Hydraulic Fracturing Regulations

Around the country, states are taking a serious look at their regulations to manage shale gas development.  New York has the potential to be a leader among these states. Environmental Defense Fund (EDF) believes that strong regulations and aggressive enforcement is critical to protecting public health and the environment from high-volume hydraulic fracturing and other hydrocarbon extraction activities in New York State. To that end, we have submitted detailed comments on the New York State Department of Environmental Conservation (NYSDEC)’s proposed rules and permitting conditions for hydraulic fracturing. The NYSDEC can put New York at the forefront of safe and clean shale gas development by implementing our suggestions in several critical areas:

1)      Chemical Disclosure: Full public disclosure is rapidly becoming the industry norm across the country, but the proposed NYSDEC disclosure rules for chemicals used in the hydraulic fracturing process only covers chemicals with Material Safety Data Sheets (MSDS), thus failing to capture perhaps half or more of the chemicals used. This is especially problematic because MSDS only explore hazards in occupational settings and do not consider implications for public health or the environment. Further, the proposed rule only requires disclosure of additive products proposed to be used in hydraulic fracturing, as opposed to the chemicals actually used during the hydraulic fracturing process. EDF feels strongly that operators should disclose all hydraulic fracturing chemicals used on a well-by-well basis, posted on a searchable, publically accessible website.

2)      Well Construction: Properly constructed, tested and maintained wells are critical to protecting New York’s precious groundwater and surface water aquifers from contamination by drilling fluid, wastewater and natural gas seepage. The proposed well construction regulations and permitting conditions need improvement to meet industry best practice standards. Furthermore, some of the proposed rules represent potential safety hazards for well pad workers. A model regulatory framework EDF, and others, are developing could be used to greatly improve NYDEC’s proposed well construction regulations.  

3)      GHG Emissions/Methane Leakage: EDF is a leading advocate of strict standards on limiting methane emissions from natural gas production. Methane is a pernicious greenhouse gas, many more times more powerful than carbon dioxide.  To reduce the peak warming and improve air quality, it is critical to minimize the amount of methane vented or flared at the production site or leaked during storage and transmission. We strongly urge the NYSDEC to impose specific Green Completion and other emission-reducing requirements on operators, and to formulate hard emissions targets that provide incentives for operators to reduce methane leakage even further.

4)      Wastewater: Hydraulic fracturing produces huge volumes of potentially toxic and radioactive wastewater. New York recognizes this problem but does not seriously address the lack of capacity for processing or safely storing hydraulic fracturing waste materials within the state. Current technology does not allow for safe, cost-effective purification of hydraulic fracturing wastewater at treatment centers for re-introduction into the water system, and should be banned. Insofar as it appears that the final disposition of the bulk of the wastewater produced in New York will be trucked out of state to deep injection wells, the proposed regulations and permitting conditions must grapple with this expensive and perhaps unsustainable practice. Finally, since wastewater recycling will likely be the dominant treatment option undertaken by shale gas operators in New York, this practice needs to be more thoughtfully and transparently regulated.

5)      Phase-in: Even with the best rules on the books, it will take time to hire and train the necessary staff to implement and enforce the rules properly.  New York is essentially building a regulatory program from scratch.  EDF believes the NYSDEC should learn how to walk before it can run.  Our suggestion is that New York phase in the regulatory program region by region.  In this way, the state can be sure that the pace of drilling activity will not outpace its ability to adequately administer the regulations.  So, too, this phase-in approach will allow the state to acquire valuable experience in step-wise fashion. The key is not doing it quickly, but doing it correctly.

These and other adjustments to the proposed rules and permitting conditions are necessary to protect public health and the environment in New York. Shale gas extraction can be made safe through strong regulations and aggressive enforcement to protect communities. EDF is committed to working with the NYSDEC on these issues to produce the most responsible hydraulic fracturing regulatory framework in the nation.

EDF’s full comments on New York’s hydraulic fracturing regulations are available here.

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