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Memo To EPA: Stay Strong On Oil and Gas Standards

April 11, 2012

Next week, EPA will issue final New Source Performance Standards (NSPS) for conventional air emissions from the oil and natural gas industry. The standards must require the capture of hundreds of thousands of tons of smog-forming emissions emitted annually by this industry, along with millions of tons of methane.

Methane – the primary component of natural gas – is both a valuable fuel and a potent pollutant, 25 times more potent than carbon dioxide as a driver of climate change over a 100-year period. The methane emissions from U.S. oil and gas operations warm global climate as much as 16% of all the CO2 from U.S. coal-fired power plants. With a strong rule, those emissions will be cut by a quarter, so EPA clearly has an excellent opportunity to begin to address this dangerous climate pollutant.

Moreover, because all government and private forecasters project an increase in natural gas use for generating electricity, demand for natural gas will continue to increase, including natural gas produced from hydraulically-fractured (“fracked”) wells. Using “green completions” or “reduced emission completions” (RECs) on fracked wells can help avoid release of both conventional and methane pollution that otherwise will skyrocket as fracking booms all over the country. So at the heart of the final standards must be the requirement to capture the burst of pollution from newly fracked and refracked natural gas wells using “green completion” technology.

Yet, even though EPA has shown that green completions could actually make money for the gas industry, as they can ultimately sell the captured natural gas from a green completion, industry lobbyists are claiming that the cost of green completion is too high. Industry further claims that gas streams containing less than 10% volatile organic compounds (“VOCs,” pollutants which pose significant health risks to the public) are insignificant and should not be regulated. And, they advocate for flaring, saying that simply burning the methane and VOCs released upon fracking would be sufficient.

All of these assertions are false – and alarming for those who care about the climate and health impacts of this industry. Gas releases containing less than 10% VOCs are, in fact, quite significant when hundreds of tons of gas are being released into the air in a short time. And VOC tonnage from these sources is very substantial, and capturing it also captures quite a lot of climate-damaging methane. Flaring is a very crude and ineffective solution when green completion is a readily available and inexpensive technology. Flaring is certainly not the “best system of emissions reduction” as required by law.

Moreover, the methane emitted to the air during the fracking process is so damaging to the environment that it should be regulated on its own. EPA’s proposed rule does not do that – but at the very least, the methane co-benefits of regulating conventional smog-causing pollution must not be lost through a weakened rule.

This week, CATF and others sent a letter to the White House insisting that the Administration stand firm in issuing strong performance standards for the oil and gas industry — the first federal limits on air pollution from fracked natural gas wells. All of the measures required under these standards are common sense, in use already in states like Colorado and Wyoming, and they are cost-effective. Weakening the standards, as industry advocates, will allow the release of very large amounts of dangerous air pollution – pollutants that form ozone smog, and that contribute to climate change. This pollution is a threat to our children, our communities and our planet.

EPA must resist the calls by industry lobbyists to weaken the oil and gas performance standards. If the Agency does not, public health and climate threats will dramatically increase as the natural gas drilling boom expands into new shale gas regions of our country. Now more than ever, we need a strong NSPS rule.

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