Four Facts to Know about CAP’s Flawed Methane Report

The Center for American Progress (CAP) released a new report yesterday, which makes the bizarre claim that methane emissions from venting and flaring on federal lands “have significantly increased over the past five years” and that fugitive methane emissions from production “surpass even the highest estimates of methane emitted from venting and flaring.”

CAP, a left-leaning organization that receives funding from anti-fracking foundations like Rockefeller and Tides, did not collect any new data, but rather relied on a report from Status Consulting. That report was commissioned by the Wilderness Society, an environmental group that has been critical of fracking, including a blog post entitled, “Fracking dangers: 7 ugly reasons why wilderness lovers should be worried.” The post contains a picture of an anti-fracking sign depicting a bottle of water with a skull and cross bones and the word “poison.”

Stratus, as many will remember, has been in the news quite a bit over the past several years, most prominently for the work it did to support an extortion campaign targeting Chevron in connection with the Lago Agrio case in Ecuador. When the facts finally came to light about Stratus’s (possible criminal) complicity in preparing bogus technical reports for the litigants, the firm was forced to publicly recant its work and offer an apology. The Boulder, Colo.-based company has become a go-to firm for environmental groups over the years, especially when activists’ litigation strategies call for manufactured data sets and inflated damage estimates.

Nonetheless, here are a few important things to know about CAP’s methane report.

Fact #1: Claims methane emissions are increasing even though production on federal lands has dramatically decreased

The first red flag in the report is the fact that CAP claims methane emissions have “significantly increased over the past five years” on federal lands – but in that same time period, production has fallen considerably on federal lands.

According to a recent report by the Congressional Research Service (CRS), natural gas production on federal lands has declined in recent years:

“U.S. natural gas production rose by four trillion cubic feet (tcf) or 20% since 2007, while production on federal lands (onshore and offshore) fell by about 33% and production on non-federal lands grew by 40%.” (p. 1; emphasis added)

CRS also found that because of significant declines in oil production on federal lands from 2011 to 2012, oil production is now below 2007 levels.  From CRS:

“Oil production has fluctuated widely between FY2007 and FY2012, yielding different results when comparing various years. For example, when comparing fiscal year 2010 with 2007, growth in the federal share of production was about 82% of the total.  On federal lands, there was an increase in production from FY2008-FY2009 and another increase in FY2010, but then declines in FY2011 and FY2012, which brought production below FY2007 production levels.” (p. 1; emphasis added)

In order for CAP’s claim to be correct, the wells on federal lands would have to be emitting methane orders of magnitude larger than was ever imagined to produce such results.  That leads us to our next point.

Fact #2: Ignores analyses and peer-reviewed studies showing low or declining methane leakage

CAP’s claim becomes even more bizarre when you consider that methane emissions have been dramatically reduced in recent years, owing to the same technological advancements that have allowed the United States to experience its current energy boom.

The Environmental Protection Agency (EPA) released its latest Greenhouse Gas Inventory earlier this year, which found that methane emissions from natural gas systems fell 16.9 percent since 1990, with field production emissions falling more than 40 percent since 2006.  In the report, EPA is very clear that the decrease in methane emissions is “due to increased voluntary reductions” by oil and gas producers.

Just last week, EPA released the latest data from its annual Greenhouse Gas Reporting Program and, once again, the agency found significant methane reductions. In fact, oil and gas producers reduced emissions of methane 12 percent from 2011 to 2013, and methane emissions from hydraulic fracturing specifically decreased by an amazing 73 percent.  From EPA’s report:

“{In 2013} reported methane emissions from petroleum and natural gas systems sector have decreased by 12 percent since 2011, with the largest reductions coming from hydraulically fractured natural gas wells, which have decreased by 73 percent during that period. EPA expects to see further emission reductions as the agency’s 2012 standards for the oil and gas industry become fully implemented.”

Last year, a landmark study by the University of Texas and the Environmental Defense Fund (EDF) was published in the Proceedings of the National Academy of Sciences, which was the first study to take direct measurements of methane from 190 well pads.  It found very low methane emissions rates that were in line with EPA’s findings.

Finally, the U.N. Intergovernmental Panel on Climate Change addressed the issue of methane emissions in its latest climate report, finding that even taking into account methane leakage during production, natural gas still maintains its climate benefits. From the IPCC:

“Taking into account revised estimates for fugitive methane emissions, recent lifecycle assessments indicate that specific GHG emissions are reduced by one half (on a per‐kWh basis) when shifting from the current world‐average coal‐fired power plant to a modern natural gas combined‐cycle (NGCC) power plant, evaluated using the 100‐year global warming potentials (GWP) (Burnham et al., 2012), as indicated in Figure 7.6 (Section 7.8).”

Interestingly, while the Stratus Consulting report (from which CAP took its data) cites EPA’s latest (2014) Greenhouse Gas Inventory, it only does so with regard to the total GHG emissions related to energy consumption. Stratus completely omitted that oil and gas producers have dramatically reduced methane emissions. The model from which its methane emissions estimates are pulled relies on several studies, including the infamously flawed Howarth study from Cornell University, but bizarrely it does not incorporate the University of Texas/EDF study.

Fact #3: Uses data from avid anti-fracking researchers to make claims on high methane emissions rates

CAP claims in the report:

“Based on a review of recent literature by Stratus Consulting, it is estimated that fugitive methane emissions from conventional and unconventional natural gas production on federal lands and waters may have been as high as 8 million metric tons in 2012, which is the equivalent of annual emissions from 42 million cars. (see Table 1)

“As seen in Table 1, unconventional natural gas production and processing on federal lands and waters may have generated as much as 3.7 million metric tons of methane in 2012. Conventional natural gas production and processing could have released more than 225,000 additional metric tons of methane into the atmosphere. Downstream emissions resulting from the storage, transmission, and distribution of natural gas contributed up to 4.2 million metric tons of methane.” (p. 2-3)

Stratus Consulting’s estimates were gleaned from a number of calculations, based primarily on data from highly flawed studies.  They attempt to harmonize the results of these studies to come up with a high end and low end estimate.

As mentioned above, the University of Texas/EDF report – written by researchers whom the president of the National Academy of Sciences called “some of the very best experts around the country” – was completely ignored.

For their “low” estimates, the researchers used data from EPA. The only problem is that they pulled those data from the pages of a deeply-flawed study written by anti-fracking activists Tony Ingraffea and Robert Howarth. Although they had EPA’s latest methane emissions data – and we know this because they cite EPA’s 2014 report on overall emissions when it suited their purpose – they decided instead to use methane estimates from an EPA report that’s three years old. That’s important, because in subsequent reports the EPA revised downward its estimates of methane considerably. In other words, the Stratus researchers deliberately relied on outdated information that suggested methane “leaks” are higher than they actually are.

The other studies that the researchers use for the “harmonization” include the infamous Ingraffea and Howarth methane study, which has been thoroughly debunked, receiving wide criticism from the scientific community.  Even President Obama’s former Secretary of Energy, Steven Chu (a Nobel Prize-winning physicist), said of the Ingraffea/Howarth study: “we didn’t think it was credible.”

That’s not the only flawed Ingraffea/Howarth study the researchers consult, either.  The highest leakage rates come from a report led by Dana R. Caulton in conjunction with Ingraffea and Howarth.  In that report, the researchers relied on data from four flights over southwestern Pennsylvania and ran modeling exercises on the data to determine the source.  Their highest methane readings were over Greene County, an area that also happens to be the largest coal producing region in the entire state.  A number of state laws require that coal mines must have methane ventilation systems to prevent explosions and to protect workers.  The researchers noted the presence of coal mines, albeit stuffed away in the supplemental information section.

A National Oceanic and Atmospheric Administration (NOAA) report led by Gabrielle Petron, which found a leakage rate of 7.7 percent, also from highly uncertain flyovers in the Denver-Julesburg Basin, received a lot of pushback from the scientific community.   In a paper in the Journal of Geophysical Research, Michael Levi, energy and environment fellow at the Council on Foreign relations, said that the study’s findings were “unsupportable” based on what he terms the “wrong interpretation” of the data. Levi argues that the emissions rate is a fraction of what Petron and her fellow researchers found.  Among NOAA’s errors of analysis, according to Levi, is that “Colorado has imposed tough rules on methane emissions since the NOAA data was collected in 2008.”  Later, the Environmental Defense Fund said “conclusions should not be drawn about total leakage based on these preliminary, localized reports.”

Finally, Stratus Consulting cites another NOAA report led by Anna Karion, which found leakage rates as high as 11.7 percent.  While EID has the full story on this study here, suffice it to say that among the study’s chief shortcomings is the fact that it measured methane from only one day of data from a three hour flight over only one oil and gas field in the Uintah Basin in Utah with absolutely no way to determine where the methane is coming from.

In other words, Stratus Consulting – and thereby CAP’s conclusions – are drawn primarily from studies finding high emissions, which have been widely criticized for their dubious methodologies, while ignoring the best available data on methane emissions, notably EPA’s latest data and the University of Texas/EDF’s direct measurements.

Fact #4: Inflates venting and flaring numbers by evaluating highly unlikely scenarios

CAP makes this claim about venting and flaring:

“Data compiled by the Office of Natural Resources Revenue for their Oil and Gas Operations Reports, or OGORs—in which federal leaseholders report production information to the agency—show that emissions from venting and flaring have increased significantly since 2008. (see Figure 2) However, because some federal leases are managed as part of communitization agreements, which are collections of leases for federal and some nonfederal production that draw from the same reservoir, OGOR data also includes some portion of production from state, tribal, and private lands. As a result, there is some uncertainty regarding the exact amount of vented and flared gas coming from federal lands. However, assuming that the ratio of federal and nonfederal production reflected in the OGOR data remained steady over time, it is estimated that methane emissions from venting and flaring on federal lands rose approximately 135 percent between 2008 and 2013. Significantly, it is also estimated that between 2010 and 2013, emissions from venting and flaring on federal lands rose approximately 61 percent.” (p. 3-4; emphasis added)

As this passage clearly states, the estimates on federal leases are inflated due to the fact that that data may include nonfederal flaring as well.  But that’s just the beginning. From the Stratus Consulting report’s appendix:

“ONRR collects data on royalties reported for natural gas venting and flaring on public lands. These data do not separate venting and flaring quantities nor do they differentiate between conventional and unconventional natural gas production. Because we do not know the fraction of natural gas that producers vent versus flare, we present two emissions scenarios for the ONRR royalties reported for venting and flaring data: a scenario that assumes 100% venting and a scenario that assumes 100% flaring. We also assume that the venting is occurring in the production, rather than the pipeline, stage.” (p. 19; emphasis added)

In other words, not only are the numbers likely already inflated, the researchers also gain their estimates from scenarios of 100 percent flaring and venting, which are not even within the realms of reality.

That said, even if there were more venting and flaring happening on federal lands, the prescription that CAP would no doubt support – increased federal rules – would likely be counterproductive. Kathleen Sgamma of the Western Energy Alliance explained the reason to E&E News, which summarized her remarks:

Sgamma said there is generally more venting and flaring on federal and Indian lands compared with private and state lands due to the difficulties in obtaining rights of way across the federal estate to capture and transport the natural gas. (emphasis added)

The role that federal rules play in preventing flaring reductions was also covered by Reuters just last week:

“North Dakota’s oil producers will struggle to comply with aggressive rules taking effect on Wednesday designed to curb the wasteful burning of natural gas, hindered by lengthy federal reviews of crucial pipelines.

The No. 2 U.S. oil state is pushing to resolve a problem commonly known as flaring, an environmental and economic squandering akin to burning cash.

Energy companies have been preparing since June for the deadline requiring them to capture 74 percent of natural gas extracted alongside crude oil from thousands of wells. The standards get tougher in January.

But the energy industry and state officials say they are bound to fall short of the goal through 2015, flaring gas in excess of targets and consequently having to trim oil production to comply with penalties built into the new standards.

The main reason, according to Reuters interviews and reviews of regulations, is simple: a Byzantine web of state and federal agencies who must sign off on new pipelines. (emphasis added)


Although CAP and the Wilderness Society may claim methane emissions from natural gas development are out of control, it’s instructive that so many needles had to be threaded for them to support that conclusion. Paying for a report that omits some of the best data available on methane emissions was, unfortunately, the best they could do.

It’s likely that this report was designed as a support mechanism for EPA’s dabbling in whether to regulate methane emissions from oil and gas production. CAP has a history of coordinating policy decisions with the White House, and its founder, John Podesta, is now a close adviser to President Obama. Hopefully as the EPA and the White House consider the costs and benefits of new rulemakings, they’ll stick to the science – and leave the “impractical” claims of activists on the fringe where they belong.


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