Energy Exchange

Improving New York’s Proposed Hydraulic Fracturing Regulations

By Mark Brownstein / Published: January 31, 2012

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.

Posted in Natural Gas, New York / Tagged , | Read 6 Responses

Pecan Street Named #1 Electric Vehicle Initiative Of The Year

By Marita Mirzatuny / Published: December 13, 2011

Since this blog post was published, Pecan Street was also named one of Smart Grid News’ Smart Grid Winners of 2011.

Source: Pecan Street

As the Christmas season revs up and a New Year fast approaches, you may have noticed the sentimental commercials of couples giving each other new cars amidst snowy scenes and jolly music or well-choreographed salespeople urging you to shop the dealership as eager car companies showcase their new model year offerings. This happens every year around this time, some obviously more ridiculous than others. But with each year as more hybrid and electric vehicles join the marketplace, these companies are touting their environmental acumen as much as their sleek body styles and luxurious interiors. While there are still hurdles to overcome, the age of electric vehicles (EV) is beginning.

2012 will see the 100% gas-free Ford Focus, now taking reservations, Mitsubishi’s MiEV’s as the cheapest offering in the EV market, and the all electric Honda Fit, released initially as lease only until 2013. With a limited supply of Fits coming to the US, Engadget even suggests “you may want to add your local Honda dealer to the holiday card list — it certainly can’t hurt your chances of getting Fit next summer.” One analyst believes by “model year 2015, the new car market will have 108 electric-drive models.” And a University of California at Berkeley study predicts that by 2030, 64% of light vehicle sales in the US will be EV. Read More »

Posted in Grid Modernization, Texas / Comments are closed

EDF Releases Ten Recommendations For The First Offshore CCS Projects In Texas

By Tim O'Connor / Published: December 12, 2011

On December 2nd, Environmental Defense Fund (EDF) completed a 2-year long research project funded by the U.S. Department of Energy (DOE) to support a University of Texas (UT) project to find suitable sites to sequester carbon dioxide below ground in Texas’ offshore state waters.   The research report, which directs site selection, anticipates environmental risks and provides recommendations during project siting and development, was generated to safely and efficiently guide offshore carbon capture and geologic sequestration (CCS) projects to minimize risks to human health and the environment.

Source: Southeast Regional Carbon Sequestration Partnership Region

Given that a CCS project off the coast of Texas would likely be the first of its kind in U.S. history, the report offers valuable insight to help guide a future demonstration project which may open the door to a potentially huge CCS industry.  In 2010, the U.S. DOE evaluated the gulf coast region and found vast potential for storing CO2 in deep saline formations (underground salt-water deposits) as well as in depleted oil and gas fields throughout the area.  Similarly, in 2006 the University of Texas evaluated geologic formations across the coastal region, finding exceptional geology for engaging in CCS projects.

EDF’s recommendations, included in Section VII or the report, provide guidelines for use in site selection and development for offshore CCS projects in Texas, including:

  • Following threshold standards to avoid negative effects on human health or coastal natural resources;
  • Taking an overall precautionary approach wherever possible;
  • Performing site-specific evaluations within the full zone of potential impact, even if not required by law;
  • Choosing sites with the least potential for leakage;
  • Applying recently adopted U.S. EPA rules for groundwater protection even if not required by law;
  • Locating sites as far from shorelines and existing aquifers as feasible;
  • Reusing or collocating equipment new project footprints;
  • Selecting back-up sites where possible;
  • Developing site specific monitoring, verification, accounting, and reporting plan; and
  • Evaluating feasible mitigation measure prior to site operation.

To complete the research project, EDF energy and oceans experts performed an in-depth look into the current state of the Texas gulf coast environment and extrapolated lessons learned from operations analogous to CCS to analyze the potential for impact and recommend ways to mitigate overall risk.   EDF used examples and best management practices developed for offshore oil drilling, onshore enhanced oil recovery, acid gas and wastewater injection, and offshore CCS projects in other countries to make its suite of recommendations.

Posted in Texas / Tagged | Comments are closed

San Diego Outage Triggers A Green Grid Revolution (in author)!

By Lauren Navarro / Published: September 15, 2011

I landed at San Diego International Airport at 4pm on Thursday.  Since I sat towards the front of the plane, I was one of the first people to walk up the corridor.  Suddenly, the lights went out.  “Perfect timing,” the woman in front of me said.

As I walked through the airport, the lights were off, the lines had grown long.  Cell phones weren’t working, and I was reminded of a zombie movie I had seen.  Waiting in the late afternoon heat, I tried to remember the exact words in my colleague’s quickly written agreement to pick me up and drive me to the event.

I hoped that it was just the airport, but as we inched our way through the traffic, it was clear that San Diego had ground to a halt.  Gas stations became crowded with people who literally ran out of gas and couldn’t get home.  As the sunlight waned, we rushed to buy provisions (water, protein bars, etc.) at an Albertsons – possible only because it had installed fuel cells or solar panels.  From the freeway we could see that University of California San Diego, which has its own microgrid, was also lit up thanks to distributed generation. 

We learned that a transmission problem in Arizona had caused a possible sequence of events that included the protective functions at the nuclear power plant turning the plant off and lead to extensive power outages throughout San Diego, southern California, and parts of Mexico.  The funny part?  I was with a colleague from San Diego Gas and Electric, traveling to speak about our collaborative smart grid planning effort.  We couldn’t help but think about how the smart grid could have helped here. 

Storage and advanced grid sensing and control technologies could have isolated the problem at its source and kept it from growing.  The smart grid’s ability to incorporate larger amounts of renewable energy could have kept electricity flowing.  Microgrids – with their own local generation and smart technologies – could have switched to an off-grid mode and remained powered through the outage.  Buildings with demand response capabilities and appropriately designed roof top solar or other forms of distributed generation, could have reduced their consumption and used smart technologies to share their power with businesses running critical equipment or with people who need air conditioning or medical equipment to maintain their health.

Source: AP Photo/Gregory Bull

Smart grids can play an even bigger role after an outage is over: Electricity production is a huge source of air and water pollution– emissions from U.S. electricity production make up 30% of domestic climate change pollution and over 6% of global emissions.  A thoughtfully-designed smart grid could reduce harmful emissions by up to 30% and fight against the tragedy of more than 34,000 deaths a year from power plant pollution – more lives than are lost on U.S. highways.

A greener grid will also put us at the forefront of the world’s competitive clean energy economy.  A recently released Duke University report commissioned by EDF identified smart grid companies already flourishing in 37 states at 315 locations—including headquarters, manufacturing plants and hardware/software development facilities.

All of this adds up: the green grid revolution will create as many as 180,000 domestic jobs per year while saving lives.  Now that’s worth standing up for.

Posted in California, Grid Modernization / Read 1 Response

Some Bad Ideas We Can All Agree On

By Scott Anderson / Published: April 19, 2011

Source: Bellona

EDF believes that, done right, carbon capture and sequestration (CCS) can be a safe and effective tool for reducing greenhouse gas emissions.  We also think it will be a necessary tool – especially for natural gas, which is poised to make up an increasing share of our national energy portfolio.

The environmental community doesn’t have a monolithic view of CCS, though.  Some groups are skeptical about its need.  Others have concerns about whether it can really work.  Fair enough!  We welcome debate and opportunities to learn from each other.

There are certain things, though, on which we can all agree.  More than 50 organizations recently came together to express our unanimous opposition to a couple of very bad ideas about how CCS projects should be treated – ideas that could lead to sloppy projects and put public health and the environment at risk.

The first is so-called “liability relief.”  Believe it or not, on the one-year anniversary of the Deepwater Horizon oil-spill disaster, some in the coal and utility industries continue to call for a “Get Out of Jail Free” card for CCS projects.  They are basically saying that once a CCS project is sealed up, operators shouldn’t be held responsible if carbon dioxide (CO2) starts to leak or if displace formation fluids pollute ground water.  We believe this is a set-up for dangerous short cuts in project planning and implementation.  It boggles my mind that, at the same time Congress is struggling to lift liability caps for offshore drilling, anyone would entertain the idea of taking steps that would reduce incentives to properly manage CCS projects.

The second bad idea might be even more perplexing than the first – and we’re especially disappointed that it’s coming from the good folks at the Environmental Protection Agency (EPA).  Our environmental watchdogs at the agency are considering a proposal to exempt CCS projects from hazardous waste requirements under the Resource Conservation and Recovery Act, our nation’s landmark law that keeps us safe from the most toxic substances.  If CO2 streams at CCS projects get this exemption, it will eliminate important protections for clean-ups and remediation and for public participation.

EDF is helping lead the charge against these bad ideas – meeting with members of Congress and agency officials, sounding the alarm with the media, and working with other environmental groups to present a united front.  For more details, read our letter to the Administration, and stay tuned to the Energy Exchange.

Posted in Washington, DC / Comments are closed

Let The Science Do The Talking At Weyburn

By EDF Blogs / Published: January 21, 2011

By: Tim O’Connor

Canadian academics, government officials and petroleum industry insiders have undoubtedly had their hands full these past two weeks. 

On January 11, EcoJustice, a Canadian non-profit organization broke a story that Canada’s most prominent carbon capture and sequestration (CCS) project in Weyburn, Saskatchewan had been leaking CO2 for several years, expressing concern that no one in Canada was doing anything about it.   

The press release, citing a recently published site assessment performed by Petro-Find, referenced measurements of high CO2 concentrations in the air and soil, nearby animal carcasses, visible oil sheens, algae growth and foaming gravel pits as indications that something was drastically wrong with the project that has been injecting CO2 1,500 meters below the surface for the past 11 years.  

If these observations reflect leaking CO2, the Petro-Find report would call into question one of the world’s best examples of a successful CCS project (more than 13 million tons sequestered up to this point), dealing a major setback to a technology that many consider a critical tool for fighting climate change.

To understand the issues raised by the report, the Canadian research institution Petroleum Technology Research Centre (PTRC), a group comprised of Canadian CCS experts from academia, government and industry, released its own report on January 19, questioning the methods and findings of the Petro-Find study. 

Where Petro-Find had concluded that high CO2 concentrations were from the CCS project, PTRC noted that natural soil biological processes were likely responsible for the observed patterns.  Where Petro-Find said it was practically irrefutable that Weyburn was leaking, PTRC found problems with the analysis and suggested that the conclusions were flawed, questionable at best, with little evidence that anything was happening.

So, what’s the truth?  Is this a case of whistle blowing, exposing problems with decades of international scientific research corroborated by the International Energy Agency, or is it, in the words of one skeptic, a hoax involving a dead cat?  Well, the truth has to be based on where good science leads us, and something that both CCS supporters and opponents need to focus on: the science, not the rhetoric.

In the rush to find the silver bullet to solve climate change, there will be some good ideas that work, and there will be some ideas that remind us of the early reports of cold fusion from the 1990s.  While we aggressively work on real solutions, it is important to remain outcome neutral and let the science do the talking.  If the science shows that the solution works, great.  If the science shows that we have a busted hand, let’s ask the hard questions and be open to exploring other ideas.

CCS is a solution that has been corroborated several times by science.  Yet science tells us that you can’t just dig a hole, stick a pipe in and expect it to work.  The trick is following the correct procedures, choosing an appropriate location and performing rigorous monitoring to make sure everything is going according to plan.  Weyburn, by all reports, seems to have been doing things right for years. 

Of course, the reports of oil sheens on surface ponds and bubbling soil pits near Weyburn are concerning– especially if people or animals have been affected.  The Canadian research institution IPAC-CO2 is said to be looking into the Weyburn situation and doing more scientific measurements at the site. This sounds like the right way to go to me.

Posted in General / Read 1 Response