On Thursday, December 3, CATF joined dozens of environmental, health, business, labor and Latino organizations to deliver over 775,000 public comments to EPA on the proposed NSPS rule for methane emissions from new and modified sources in the oil and gas industry. Boxes containing the comments (pictured below) were received by Micah Ragland, Associate Administrator for Public Engagement and Environmental Education on the steps of EPA headquarters in Washington, DC.
When the Administration first announced these draft standards last August, we posted this piece by CATF experts Darin Schroeder and David McCabe, essentially characterizing the proposal as “a good first step.” Now, as we submit our written comments to EPA, the gist of those comments will remain the same – we find good news and bad news in the proposal. There’s a lot to like in the plan, but we strongly recommend to EPA that they tighten up the proposal in several key areas.
First, the good news. We are highly encouraged that EPA has chosen to reduce methane emissions from the largest industrial source – the oil and gas industry. Methane is a highly potent greenhouse gas, and for the first time it will be directly regulated under the Clean Air Act. Furthermore, the draft standards will also reduce the pollution that causes ozone smog and emissions of toxic pollutants like benzene and hexane. How do they propose to do this? First, by creating and implementing broadly applicable methane leak detection and repair requirements across many locations in the gas production process. Second, by proposing methane emission standards for most of the same sources included in the 2012 final standards for volatile organic compounds (VOCs). Third, by extending those standards to many downstream sources in the transmission and storage segment. And fourth, by setting limits on previously unaddressed sources, such as methane venting during oil well completions.
So far, so good, right? Yes, but if the Administration is serious about attaining its greenhouse gas emissions reduction targets that it has presented to the global community, there are numerous opportunities to strengthen these draft standards to more closely approach our international pledges. For new and modified sources, we will be recommending in our comments the following:
- The Administration has omitted the following key pieces of equipment and practices from its proposal – liquids unloading operations, intermittent pneumatic controllers, compressors at well sites, and storage vessels. Low cost controls exist for all of these and should be mandated as part of a stronger final standard.
- While we are pleased that methane-based leak detection and repair (LDAR) standards have been proposed for well sites and compressor stations, the rule needs to be tightened to require inspections on a more regular – monthly or quarterly – basis. By pressing for more stringent LDAR methods, EPA can help advance the current LDAR technology that will lead to greater emissions reductions over time.
- EPA must clarify when flaring could be allowed, and show that the availability of other technologies should make the flaring option very limited.
- Most importantly, methane emissions from existing sources are unaddressed in the draft rule, and there is no way the Administration will meet its national emissions goal of a 45% reduction by 2025 without an existing source rule. By 2018, 90 percent of methane emissions will be from oil and gas facilities sources that were in operation in 2011, equipment that is exempt from EPA’s 2012 standards, and will be exempt from the new standards as well. We will continue to call upon the Administration to deliver strong action on existing sources of methane pollution.
By taking these additional measures in crafting the final rule, EPA will be making significant progress in curbing methane emissions from an industry that is expected to grow by 25% between now and 2025. According to our calculations, the draft standards as currently written will make a significant dent in projected emissions growth, but not nearly enough to meet the Administration GHG reduction targets. So, to quote a familiar line: “The journey of a thousand miles begins with a single step.” That’s right about where EPA is right now on methane. CATF stands ready to help and encourage them along that path. Because the climate can’t wait.