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Memo: Modeled impacts from EPA methane rollbacks

November 14, 2019 Category: Policy Work Area: Methane

In 2016, U.S. EPA issued landmark standards for new and modified facilities in the oil production and natural gas production, process, and transmission and storage industries. These standards reduce methane and other harmful air pollutants from facilities they cover in several key ways. Furthermore, the promulgation of methane pollution standards from these new and modified sites (in addition to standards for ozone-smog precursors), triggered an obligation for EPA to issue corresponding standards for existing facilities – the vast fleet of oil and gas sites that were in place before the 2016 standards were first proposed.

In 2018 and 2019, EPA issued two proposals to weaken the 2016 standards. These proposals were designed to weaken the 2016 standards in several ways. First, they would revise the 2016 rules to weaken the standards, so that the oil and gas industry would need to perform less inspections to reduce leaks and other emissions of methane and other pollutants from their sites. Additionally, EPA is proposing to carve out the transmission and storage segment, removing all sources in that segment from applicability to the 2016 standards. EPA is also proposing to remove the standards for methane emissions from these sites from the rules (so that the standards would only apply to ozone-smog precursors), because doing so will remove EPA’s obligation to issue standards to reduce methane pollution from existing facilities.

These two rollback proposals, if finalized and implemented (surviving legal challenges), would vastly increase climate pollution from the U.S. oil and gas industry. Together, the impacts from these two proposals will increase 2025 emissions by 4.3 million metric tons, VOC emissions by 1 million metric tons and HAP emissions by 38,000 metric tons. These estimates include the additional emissions that will occur if EPA does not issue standards for existing oil and gas sites, since EPA is obligated to do so under the current rules but will not be if the current rollback proposals are finalized and implemented. The additional oil and gas methane pollution emitted because of these rollbacks would, over the near-term, warm the climate as much as the carbon dioxide emissions of nearly 100 coal-fired power plants.

This memo provides a summary description of the rollback proposals and the increases in emissions that would result from them, and it describes how Clean Air Task Force has estimated these emission increases.