EPA’s proposal would substantially reduce methane pollution and includes important provisions related to advanced monitoring for methane leaks, solicits comment on community-based monitoring solutions, and would require broad-based deployment of certain zero-emitting devices.
EPA has also committed to further strengthening its current proposal with a supplemental proposal addressing additional key issues to be issued early next year.
“EPA has an unparalleled opportunity to lead the world in addressing climate change and seize on available, cost-effective solutions to achieve deep reductions in methane emissions and local air pollution in all communities across the country,” said EDF attorney, Grace Smith in her testimony.
Smith commended EPA’s strong proposed standards for replacing intentionally polluting equipment with zero-emitting alternatives.
“Final standards must be further strengthened to require monitoring across smaller, leak-prone wells and address the wasteful practice of flaring,” said Smith. “EDF supports EPA’s plan to further address these issues in a supplemental proposal.”
The U.S. oil and gas industry emitted 16 million metric tons of methane in 2019, with a near-term climate impact of 350 coal-fired power plants.
Reducing these emissions is the fastest, most cost-effective way to slow the rate of global warming while reducing harmful co-pollutants such as volatile organic compounds and toxic pollution like benzene that threaten the health of the over 9 million people in the U.S. living within a half-mile of an existing oil or gas well.
“By taking bold action on methane and other harmful pollutants from the oil and gas sector, EPA can begin to reduce pollution in communities that have long borne disproportionate health burdens and show them that it listened to community concerns,” added Smith.
Comprehensive methane rules that address emissions from all sources – including smaller, leak-prone wells – are critical to achieving the Biden administration’s climate goals and commitments under the Global Methane Pledge.
“Hundreds of thousands of wells across the country generate just a trickle of usable product but are large and disproportionate emitters of methane,” testified EDF legal fellow Edwin LaMair. “Nationwide, pollution from these low-producing wells destabilizes the climate and harms the health of the more than seven million people that live nearby, including nearly half a million children and roughly two million people of color.”
EDF analysis shows the vast majority of these smaller oil and gas sites are owned by companies that operate more than one hundred wells each and generate hundreds of millions in gross revenue every year.
“Because large emission events are intermittent and difficult to predict, a one-time survey for smaller sites with high-emitting equipment will likely miss significant sources of pollution,” said LaMair. “To remedy these issues, EPA should account for equipment failures and super-emitters in site-level estimates and require routine monitoring at all sites with potentially significant emissions.”
Legal fellow Grace Weatherall added in her testimony the importance of EPA building on its proposed steps to address emissions from flaring – a major source of methane pollution – by following the lead of states like Colorado and New Mexico, which have moved to end routine flaring.
“EDF urges EPA to finalize a standard for associated gas methane emissions from new and existing oil wells which would require capture of associated gas and enable a diverse array of solutions to do so,” noted Weatherall. “In many cases, well operators capturing and selling associated gas can be expected to break even, if not earn money on the captured gas, because they will be able to sell the gas at a profit, rather than burning it as waste.”
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[Posted: December 2, 2021] PA Environment Digest
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