Pennsylvania's Smart Move on Methane

Switchboard: Natural Resources Defense Council Staff Blog

By Mark Szybist

January 19, 2016

Today, Pennsylvania Governor Wolf announced a four-part plan to address emissions of methane from Pennsylvania's expanding oil and gas sector. The goal, DEP Secretary John Quigley said, is for Pennsylvania to have the best state-level methane standards in the nation. That's a noble goal, and we look forward to working with the administration to make sure it becomes a reality. If the state can achieve it, it will be a big deal for two main reasons:

1. Methane pollution from oil and gas production activities packs a serious climate punch

Methane is a highly potent greenhouse gas, with 36 times more heat-trapping impact than carbon dioxide on a 100-year time-scale and 87 times more on a 20-year scale. And through leaks, venting, and flaring, the oil and gas industry emits huge amounts of methane (yes, one of its main products) into the atmosphere. In fact, even by conservative EPA estimates, the oil and gas industry is the single largest source of methane pollution in the U.S. and the nation's second-largest industrial contributor to climate change, after only power plants.

According to the EPA's most recent Inventory of U.S. Greenhouse Gas Emissions and Sinks (2015), natural gas systems emitted 157.4 million metric tons of carbon dioxide-equivalent of methane in 2013. As my colleague Meleah Geertsma has noted, that's enough methane waste each year to power nearly 6 million American homes. In Pennsylvania, shale gas drillers self-reported emitting a mere 2.70 million metric tons of carbon dioxide-equivalent of methane that year.

But as explained in a 2014 report that NRDC released along with our colleagues at the Clean Air Task Force and Sierra Club, "Waste Not: Common Sense Ways to Reduce Methane Pollution from the Oil and Gas Industry," recent studies indicate that EPA's numbers likely understate total emissions by at least two times. And the more the issue is studied and debated, the more evidence emerges that the industry's methane emissions are far greater than it would like to admit.

The good news is that this pollution does not need to be a fact of life. According to "Waste Not", this pollution can be cut in half if companies are required to use low-cost existing technologies, perform better maintenance, and conduct more frequent inspections.

Recognizing this fact, President Obama last year announced a goal of reducing methane pollution from the oil and gas sector 40 to 45 percent from 2012 levels by 2025. In August, 2015 the EPA took a major step towards that goal by proposing standards to reduce methane emissions from some oil and gas wells and equipment - specifically new and modified sources.

The EPA is expected to finalize these standards this summer. As proposed, they are projected to reduce methane emissions by 340,000 - 400,000 short tons per year. If the EPA implements NRDC's and our colleagues' recommendations for making these standards stronger (you can read NRDC's comments here), the reductions will be even greater. But they won't reach what is the greatest source of methane pollution by far - existing oil and gas infrastructure and operations that are already up and running.

In order to meet the President's goal and make meaningful progress against methane pollution, we must address these existing operations. Pennsylvania can help lead the way by issuing state-level standards.

2. In Pennsylvania, existing sources of methane in the oil and gas sector are either under-regulated or entirely unregulated.

To understand why methane standards for existing oil and gas sources are needed in Pennsylvania, it's necessary to understand how those sources are regulated - and not - now.

Before unconventional gas drilling (mostly from the Marcellus and Utica Shale formations) started in the Commonwealth some 10 years ago, oil and gas well pads were unconditionally categorized as sources "of minor significance" under the state Air Pollution Control Act. This, despite the fact that until 2012, the federal rules establishing minimum technologies for these sources were very weak. As a result, these sources enjoyed a complete exemption from air quality permitting requirements that ensure the use of appropriate emissions control technologies and practices.

As early as 2008, the state Department of Environmental Protection recognized that hydraulic fracturing and other shale gas drilling activities were emitting significant amounts of air pollution - not just methane, but also hazardous air pollutants like benzene and smog-forming nitrogen oxides and volatile organic compounds.

As a result, the DEP proposed - first in 2008, then in 2010, and then again in 2011 - to revise the "minor significance" exemption for oil and gas well pad sources (also known as "Exemption 38," because it's the number 38 on a longer DEP list of exemptions.

In August, 2013, the DEP revised the law to make the exemption for unconventional well pads conditional upon companies' showing that operators have met certain criteria, including the implementation of a minimal leak detection and repair (LDAR) program. While this revised exemption is better than the original one, the demonstrations it requires are weak - and in any case, it still does not apply to the more than 5,000 unconventional wells and associated equipment constructed in Pennsylvania before August 10, 2013, the date the revised exemption took effect. These sources continue to be classified as sources of "minor significance," and are not subject to any leak detection and repair requirements.

As for compressor stations, which push natural gas through Pennsylvania's thousands of miles (so far) of pipelines - they too can emit large amounts of methane, and are typically regulated under a general permit, GP-5, that also contains minimal leak detection and repair provisions - again falling far short of what is actually needed to address the problem.

Since shale gas drilling started, Pennsylvania has made only marginal improvements to its air pollution standards for oil and gas equipment. Emissions are going up - and many existing sources are unregulated. With hope, Governor Wolf's announcement will signal a real change on Pennsylvania's approach that protects both the health of the Commonwealth's citizens and its climate - and speeds the momentum toward nationwide action.

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