Clean Air Task Force experts gave the following testimony at the June 15th EPA listening session on regulating methane emissions from the U.S. oil and gas sector.
Sarah Smith, Program Director, Super Pollutants:
Good afternoon. My name is Sarah Smith, and I appreciate the opportunity to speak on behalf of Clean Air Task Force, where I am the director of our Super Pollutants Program. Clean Air Task Force appreciates the hard work of the many EPA experts working to swiftly advance this rulemaking, and we thank you for the opportunity to convey why it’s so critical that the standards be as protective as possible.
CATF recognized the need for a focus on methane and other short-lived climate super pollutants in 2003 as the pace of global warming demanded a close look at all measures. The situation today has only grown more dire, with atmospheric concentrations of methane surging alongside rapidly rising CO2. In fact, NOAA analysis showed that methane levels rose a record amount in 2020. Climate scientists are now warning that we may have vanishingly little time left – perhaps as little as a decade or two – before feedbacks take over and produce irreversible and catastrophic impacts. One feedback and tipping point of particular concern is the continuing loss of the Arctic’s reflective sea ice; when we lose the remaining ice—which could be within 10 to 15 years—we will add the equivalent of one trillion tonnes of carbon dioxide, on top of the 2.4 billion we’ve added since the Industrial Revolution, and this could set off a cascade of other tipping points we are ill prepared to deal with.
Methane has clearly emerged as the most powerful lever to help slow down the pace of warming during the next two critical decades. Methane is the single biggest and fastest mitigation opportunity. By fastest, I mean that you see the cooling benefits in the first decade or two after you make the pollution cuts, because methane doesn’t last long in the atmosphere.
Clean Air Task Force celebrates the Biden-Harris Administration’s goal of keeping 1.5C in sight, and EPA’s renewed focus on reining in methane – a vital objective if we are to reach that goal. The standards that EPA is currently developing for the oil and gas sector must be best-in-class. EPA has an enormous opportunity – and solemn obligation – to use its authority under the Clean Air Act to rein in methane to the maximum extent possible. In doing so, EPA can prevent a substantial chunk of emissions, take a key step toward meeting our Nationally Determined Contribution to the Paris Agreement, provide a blueprint for other countries looking to address oil and gas sector emissions, and show the world that the United States is serious about addressing the climate crisis.
Methane emissions from the oil and gas sector are some of the easiest and cheapest greenhouse gas reductions available, and reducing this pollution comes with numerous benefits – not only for our changing climate, but for oil and gas workers and for communities living near these polluting facilities.
Through strong rules for new and existing sources built on existing policy precedents and off-the-shelf technologies, Clean Air Task Force and our partner NGOs have found that the Agency could cut methane pollution from the oil and gas sector by 65 percent by 2025. This is the level of reductions that we will be looking for from EPA’s forthcoming proposal.
Thank you again for the opportunity to speak with you today.
Darin Schroeder, Attorney, Clean Air Task Force:
My name is Darin Schroeder, and I’m an attorney with Clean Air Task Force. At the outset, I want to thank you for the opportunity to comment on this rulemaking, and thank you especially for engaging all of us stakeholders so early in the process. This is an important piece of the climate puzzle and we welcome the leadership on the issue.
But leadership now is important. Though EPA finalized its first methane regulations in 2016, the agency never issued existing source regulations so it is encouraging that existing source regulations and guidelines were included within the scope of actions President Biden’s Executive Order tasks EPA with looking at. We strongly support the proposal and finalization of existing source regulations.
But simply extending what was done in 2016 to existing sources is not enough. CATF estimates that simply extending the 2016 standards to existing sources would only reduce the sector’s emissions by roughly 22% by 2025 relative to 2012 levels.
In fact, CATF has estimated that using a few established technologies EPA can reduce the sector’s methane emissions by 65% by 2025 relative to 2012 levels. CATF found that such deep reductions can be made by requiring reasonably cost effective measures such as monthly LDAR and zero-bleed pneumatic equipment across the production, processing, and transmission and storage segments. Notably, all of these practices or requirements are in place in at least one jurisdiction either here or abroad.
But EPA’s opportunity to achieve meaningful reductions does not stop there. By banning the routine venting or flaring of associated gas from oil wells, EPA would not only reduce the methane that gets emitted from inefficient combustion of natural gas at the flare, but also reduce the emissions of pollutants that are released from flaring—namely carbon dioxide. Importantly, both New Mexico and Colorado have done this.
There are a number of practices that allow an operator to avoid venting or flaring of associated gas, including: capture and introduction to a gas flow line or collection system to allow it to be sold, with or without additional compression to overcome pipeline pressure restrictions; reinjection for storage or EOR; onsite combustion to produce electricity for onsite or offsite use; compression of the gas into compressed natural gas that is then trucked to a gas processing plant; stripping natural gas liquids;, and shut-in of the well. By designating the affected facility as a non-exploratory oil well and regulating the practice of routine disposal of associated gas, EPA could develop a section 111 standard that effectively prohibits the routine venting or flaring of associated gas (with narrow exceptions, such as safety or emergency events).
Thank you for your time, and I’d be happy to follow-up to answer any questions you have.