Call for Methane Regulations Is a Solution in Search of a Problem

The Clean Air Task Force, NRDC, and the Sierra Club recently released the summary of a report called “Waste Not,” which suggests a pressing need for stringent new regulations on methane for U.S. oil and gas systems from the well head to the meter.  In reality, methane from petroleum and natural gas systems has already been greatly diminished across the natural gas value chain, a fact that has been confirmed by the EPA and independent scientific studies.

We’ve addressed this issue many times before, but it’s worth revisiting some points by looking at the claims in the report’s summary (the full report apparently won’t be released until December).

Waste Not Report:In this report, we show how the U.S. Environmental Protection Agency (EPA) can fulfill the agency’s duty under the Clean Air Act to cut in half dangerous, wasteful methane pollution from the largest industrial source—the oil and gas industry—in just a few years, using common sense standards based on available, low-cost control measures for a targeted set of pollution sources.”

FACT: Contrary to what the environmental groups are suggesting, the Environmental Protection Agency (EPA) recently released its Greenhouse Gas Reporting Program data, which showed that methane emissions from oil and gas development are already declining. Earlier this year, EPA also published its Greenhouse Gas Inventory, which showed that methane emissions from natural gas systems fell 16.9 percent since 1990, with field production emissions falling more than 40 percent since 2006.

How were these massive reductions achieved?  As the EPA explains in its inventory:

The decrease in production emissions is due to increased voluntary reductions, from activities such as replacing high bleed pneumatic devices, regulatory reductions, and the increased use of plunger lifts for liquids unloading. The decrease in distribution emissions is due to a decrease in cast iron and unprotected steel pipelines. Emissions from field production accounted for 30.7 percent of CH4 emissions from natural gas systems in 2012. CH4 emissions from field production decreased by 25.6 percent from 1990 through 2012; however, the trend was not stable over the time series-emissions from this source increased by 24.9 percent from 1990 through 2006 due primarily to increases in hydraulically fractured well completions and workovers, and then declined by 40.4 percent from 2006 to 2012.” (ES-14)

The reduction in methane emission is also something that the Department of Energy has acknowledged.  As U.S. Energy Department Secretary Ernest Moniz said, “More than half I believe now of the current frack jobs are so-called green completions, where the methane is captured and is for economic benefit.”

Waste Not Report:EPA recently reported that emissions from natural gas well “completions” have decreased 73 percent since 2011. The standard, however, covers only fractured gas wells and not fractured oil wells, which often produce methane pollution during completion.”

FACT: It’s good to see the report acknowledge the enormous decrease in methane emissions from natural gas systems.  However, it’s important to note that methane from oil wells makes up much less of a percentage when you look at the entire petroleum system, and the overall trend for methane emissions from both oil and natural gas systems on a downward trajectory.  That’s actually something that the Environmental Defense Fund, which “reviewed this report,” has acknowledged.  While EDF still supports methane regulations, EDF research analyst David Lyon did point out recently,

“The Environmental Protection Agency recently released its draft inventory of annual U.S. greenhouse gas emissions. Reporting 2012 data, the inventory estimates methane emissions coming from natural gas and petroleum systems at around 7.6 million metric tons – that’s enough natural gas to provide energy to over 7 million homes annually. This new estimate when compared with last year’s report, which estimates emissions for the 2011 calendar year, shows overall methane emissions from natural gas and petroleum systems are 1.2 percent lower.” (emphasis added)

It’s clear that overall emissions from oil and natural gas systems have significantly declined – and Lyon’s call not to be “complacent” about this drop in emissions is a worthy one.  As the dramatic reductions show, it’s clear that producers are actively building upon the progress to date of reducing emissions.

Waste Not Report: As we describe below, methane is not the only pollutant in natural gas, and the measures we recommend in this report would reduce emissions of those other pollutants, too, benefiting air quality.”

FACT: Regulatory agencies in some of the most prolific oil and gas states – such as TexasColorado, Pennsylvania – have conducted air monitoring and found no cause for concern for public health.  In fact, the American Lung Associated recently gave “A” grades for air quality to several of the largest oil producing counties in North Dakota.

What’s more important for air quality is the fact that, thanks to the increased use of natural gas, air pollution is being dramatically reduced across the United States.  That’s something that University of California-Berkeley physics professor Richard Muller explained in a report, which finds “both global warming and air pollution can be mitigated by the development and utilization of shale gas.”  Therefore, Muller states, “Environmentalists who oppose the development of shale gas and fracking are making a tragic mistake.” In fact, Muller’s report focused specifically on particulate matter, and explains how shale gas is reducing air pollution in the United States and could be employed in other countries to do the same.

Muller’s observations can be seen clearly in shale developing states. The Pennsylvania Department of Environmental Protection (DEP) recently released its emissions inventory and found that reductions in air pollution, thanks to the increase in natural gas use, are providing “between $14 billion and $37 billion of annual public health benefit.”  According to the National Oceanic and Atmospheric Administration (NOAA), the increased use of natural gas has helped slash emissions of NOx and SO2 by more than 40 percent.

Waste Not Report: “The case for taking action on climate change has never been clearer: as the third National Climate Assessment states, the U.S. is already experiencing the effects of climate change, from increasing heat across the country to more extreme weather events totaling billions of  dollars in damage. Given these impacts, and much worse to come, the cost of inaction to our health, environment, and economy is far too great, especially when effective and low-cost means for reducing climate-warming pollution are available now.”

FACT: The same National Climate Assessment also concluded that “an increase in natural gas consumption could lead to a reduction in U.S. greenhouse gas emissions,” and that the decline in carbon dioxide emissions in the United States from 2008 to 2012 was “largely due” to natural gas.

Groups like the Sierra Club and NRDC have long contended that climate change is the greatest threat to mankind; therefore, one would think that they would be supportive of the fuel that is actually reducing greenhouse gas emissions.  As the Intergovernmental Panel on Climate Change (IPCC) explained, the decrease in carbon emissions in the United States has a lot to do with shale gas:

“A key development since AR4 is the rapid deployment of hydraulic fracturing and horizontal drilling technologies, which has increased and diversified the gas supply… this is an important reason for a reduction of GHG emissions in the United States.”

Here are a few other pieces of notable research:

  • The Energy Information Administration (EIA) found  that the “increase in natural gas-fired generation…substantially reduced the carbon intensity of electricity generation in 2012.” In its latest report, despite a slight increase in 2013, energy related carbon dioxide emissions remain 10 percent below 2005 levels.
  • The International Energy Agency reported that the “decline in energy-related CO2 emissions in the United States in recent years has been one of the bright spots in the global picture. One of the key reasons has been the increased availability of natural gas, linked to the shale gas revolution.”
  • The National Oceanic and Atmospheric Administration (NOAA) has credited the increased use of natural gas as the primary reason why CO2 emissions from U.S. power plants “were 23 percent lower in 2012.”

The Environmental Protection Agency (EPA) found in its latest Greenhouse Gas Inventory not only that methane emissions from natural gas production had dramatically fallen, but that natural gas was responsible for major greenhouse gas reductions. As the EPA puts it,

“In 2012, total U.S. greenhouse gas emissions were 6,501.5 Tg or million metric tons CO2 Eq. Total U.S. emissions have increased by 4.4 percent from 1990 to 2012, andemissions decreased from 2011 to 2012 by 3.3 percent (225.0 6 Tg CO2 Eq.). The decrease from 2011 to 2012 was due to a decrease in the carbon intensity of fuels consumed to generate electricity […] with increased natural gas consumption.”

It’s important to note that while the Sierra Club and NRDC (as well as Earthjustice and Earthworks, who were also involved in the review of this report) may be purporting to stand for “strong regulations,” they certainly make no effort to hide what they really want: a ban on fracking everywhere.

EPA’s own data show that voluntary industry efforts are achieving huge results. The best thing the administration could do is ignore the clever talking points and allow the real reductions in emissions that they’ve already acknowledged to continue, or work with industry to support and sustain such initiatives through private-public partnerships. The latest science that involves direct measurements at sites continues to show that emission concerns are not widespread and a majority of the emissions are from a handful of sources.  EPA should therefore avoid overwhelming the industry with burdensome regulations on all sources and rather work with industry and other agencies to develop innovative tools and share best practices.  That would be a far better course than looking for solutions in search of a problem, such as this latest attempt to impose new methane regulations on the job-creating oil and gas industry.

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