By John McFerrin
My mother hated waste. In a household headed by Depression era babies, we did it all: reusing wrapping paper, turning off the lights when leaving the room, rinsing out the Kool-Aid package to get every last speck of powder, everything.
She would be appalled that the oil and gas industry is letting perfectly usable gas, gas that could keep someone warm, just drift away.
Now the United States Environmental Protection Agency is doing something about it. It has proposed a regulation that would limit leaks of natural gas.
As worthwhile a goal as satisfying my mother’s sensibilities might be, that is not why the EPA is doing it.
The gas that the industry is allowing to just drift away is mostly methane. Emissions of methane matter because methane is a potent greenhouse gas. While carbon dioxide is the greenhouse gas that is talked about the most, in the short-term methane is much more potent. According to the Intergovernmental Panel on Climate Change, over 20 years methane warms the planet 86 times as much as carbon dioxide.
Methane differs from carbon dioxide as an agent of climate change in how long it lasts. Methane degrades in the atmosphere over about 20 years. Carbon dioxide lasts at least for centuries.
When the proposed standards go into effect, the same actions that prevent methane leaks also prevent leaks of other health-harming air pollutants, including smog-forming volatile organic compounds (VOCs) and toxic air pollutants such as benzene.
In a nutshell, the oil and gas operations would be required to tighten the valves, plug the leaks, etc., all in an effort to keep gas from escaping. The rule also recognizes that more sensing technologies are becoming available all the time. The rule is designed to encourage companies to adopt those technologies.
More specifically, according to the Environmental Protection Agency, companies would be required to:
- Ensure that all well sites are routinely monitored for leaks, with requirements based on the type and amount of equipment on site;
- Encourage the deployment of innovative and advanced monitoring technologies by establishing performance requirements that can be met by a broader array of technologies;
- Prevent leaks from abandoned and unplugged wells by requiring documentation that well sites are properly closed and plugged before monitoring is allowed to end;
- Leverage qualified expert monitoring to identify “super-emitters” for prompt mitigation;
- Strengthen requirements for flares to ensure they are properly operated to reduce emissions;
- Set a zero-emissions standard for pneumatic pumps at affected facilities in all segments of the industry, with exceptions limited to sites without access to electricity;
- Establish emission standards for dry seal compressors, which are currently unregulated;
- Require owners/operators of oil wells with associated gas to implement alternatives to flaring the gas, unless they submit a certified demonstration that all alternatives are not feasible for technical or safety reasons.
Fixing leaks does not sound dramatic. A little leak here, a little leak there, a bigger leak there, etc., does not sound like much. It adds up. EPA estimates that between 2023 and 2035 the standards would reduce methane emissions by 36 million tons, the equivalent of 810 million metric tons of carbon dioxide. That’s nearly the same as all greenhouse gases emitted from coal-fired electricity generation in the U.S. in 2020. In addition, the standards will reduce volatile organic carbon emissions by 9.7 million tons during the same period.
The existence of these leaks also affects other public policy discussions. Natural gas routinely brags about being a “clean” fuel. It is only “clean” compared to coal. It is true that, measured by carbon dioxide released at the power plant, natural gas is twice as clean as coal. Even at present levels of methane leaks, it is still cleaner. The presence of these leaks, however, diminishes the advantage. Instead of thinking of a choice between “clean” natural gas and “dirty” coal, the leaks suggest it is more like “dirty” coal and “not quite so dirty” natural gas.
In addition to helping save the planet (a worthwhile goal in its own right) the new rules will preserve a valuable resource. It would increase recovery of natural gas that otherwise would go to waste – saving enough gas from 2023 to 2035 to heat an estimated 3.5 million homes for the winter.
That the leaking methane is valuable changes how to evaluate the burden of compliance upon the industry. In other industries, the waste that rules prohibit an industry from releasing into the atmosphere is just that—waste. It is just something that has to be gotten rid of. Here, the methane is not useless waste. It is the product that the industry sells. Preventing it from leaking has a financial benefit for the company as well.
As with all environmental laws, the devil is in the implementation. Even when they become final, the proposed rules will not impose these requirements upon oil and gas operations directly. Instead, the rules contemplate what EPA describes as a federal-state partnership. States will have 18 months from the time the rule is final to submit a plan on how it intends to implement the standards. The standards would have to actually apply within 36 months of the time the rule is final.
The Environmental Protection Agency is accepting comments on the proposed rule until February 13, 2023. You also may send your comments the following ways:
- Email: email@example.com. Include Docket ID No. EPA-HQ-OAR-2021-0317 in the subject line of the message.
- Mail: U.S. Environmental Protection Agency, EPA Docket Center, Docket ID No. EPA HQ-OAR-2021-0317, Mail Code 28221T, 1200 Pennsylvania Avenue, NW, Washington, DC 20460.
The West Virginia Highlands Conservancy will also be commenting.