Thursday, September 28, 2023

Guest Essay: DEP Should Invest $33.6 Million In New Federal Funding Wisely To Plug Conventional Oil & Gas Wells And Not Reward The Industry For Bad Behavior

By Russell Zerbo,
Clean Air Council

This guest essay first appeared on the website September 22, 2023-- 

Pennsylvania has an opportunity to receive $33,695,097 from the U.S. Environmental Protection Agency (EPA) and the Department of Energy (DOE) to plug small, conventionally drilled oil and gas wells with known owners. 

This federal funding could significantly reduce climate-changing methane pollution as well as smog-causing volatile organic compounds (VOC) and carcinogens like benzene.

Officially called “marginal conventional wells” (MCWs), these wells produce 0.4% of the gas drilled in the United States, but generate 11% of the nation’s methane pollution from oil and gas drilling. 

Safely plugging them will prevent long-term methane pollution while creating family-sustaining jobs safely retiring gas infrastructure.

Unfortunately, these wells are at risk of being abandoned by their owners without being plugged, which could potentially cause decades of continued gas pollution.

This is the first of several grant opportunities aimed at reducing methane pollution from the oil and gas industry within the [federal] Inflation Reduction Act. 

The opportunity is also intended to help companies comply with the EPA’s upcoming methane pollution standard for existing gas wells and compressor stations. That rule, which will be finalized later this year, currently proposes a requirement that gas companies regularly monitor pollution from all gas wells until they are successfully plugged. 

This funding gives gas drilling companies the opportunity to plug wells before they are required to monitor their air pollution.

DEP Must Apply By Oct. 10

The Pennsylvania Department of Environmental Protection (DEP) must submit its application to use this funding by October 10, and extreme care must be used in establishing the process to identify the MCWs that will be plugged. 

If DEP does not create an appropriate process and criteria to identify wells to be plugged, this significant federal funding could become a massive giveaway to the gas industry, which is already damaging the public health of Pennsylvanians.

EPA and DOE have specified that the funds associated with this grant opportunity must be used to plug MCWs that have current known owners. However, the cost of plugging individual wells widely varies. 

In order to most efficiently use the available funding, DEP should identify the wells that can be most easily plugged while demanding that individual gas companies plug wells that are costlier.

In general, DEP estimates that plugging an individual well costs around $33,000, while mentioning that certain wells can cost up to $800,000. DEP could plug close to 1,000 MCWs if the available funds are focused on wells that are less expensive to plug. 

If the money was spent on individual wells that have high plugging costs, there is a significant risk that Pennsylvania could plug far less wells with this funding, which would undermine the ability to achieve more reductions in air pollution that harms our health and the climate. 

With over 200,000 estimated orphaned and abandoned wells, Pennsylvania cannot afford to waste any funding associated with well plugging.

Not An Reward For Conventional Industry

DEP should not reward gas-drilling companies that have previously accrued environmental violations. 

DEP should create criteria specifying that it will only allocate this funding to companies that receive minimal violations, for example those that did not result in environmental degradation, and have operated in accordance with state and federal regulations.

Likewise, DEP should prioritize supporting gas companies that have diverse, unionized labor forces, specifically stipulated in the grant opportunity. DEP should also disqualify gas companies from receiving this funding if they have a history of abandoning gas wells.

Require Use Of Latest Technology

Most importantly, DEP should restrict this funding to gas companies that use the most up-to-date pollution control technologies at their functioning gas wells and compressor stations, such as those that will be required in EPA’s forthcoming rules.

In addition to requiring that well owners inspect their wells for methane pollution until they are successfully plugged, the EPA has also proposed to require zero-emitting pneumatic pressure control devices at all well sites and compressor stations in its rule to reduce methane pollution from existing oil and gas sources. 

Traditionally, gas companies have used pneumatic devices where gas itself controls the pressure in drilling infrastructure, but recently those devices have been found to release far more air pollution than previously estimated.

Electric and compressed air devices that control pressure without venting gas have been available for decades and EPA plans to finalize its proposal to require the use of these non-emitting pneumatic devices later this year. 

This upcoming requirement and the availability of these devices should spur DEP to only allow gas companies that use or commit to use the latest pollution reduction technologies at their operating well sites and compressor stations to receive this federal funding.

We should not be spending taxpayer money to assist the oil and gas industry. 

Since this money has already been allocated, there is an opportunity, if done with the proper criteria in place, to reduce emissions and save larger amounts of taxpayer money from being needed to plug abandoned wells in the future. 

This funding provides an immense opportunity to permanently plug aging gas wells while incentivizing technology upgrades at gas infrastructure that will continue operating.

This is a noncompetitive grant, and Pennsylvania’s funding has already been allocated, but it is up to DEP to draft a strong plan that will prioritize reducing emissions to better protect the health of impacted residents and reduce climate pollution.

Russell Zerbo is an advocate with the non-profit Clean Air Council.

{Note: The Clean Air Council and the FracTracker Alliance held a webinar on this and related issues on September 28.  Click Here to view a recording.

PA Oil & Gas Industry Public Notice Dashboards:

-- Pennsylvania Oil & Gas Weekly Compliance Dashboard - Sept. 23 to 29; More Abandoned Wells; Oil & Gas Doesn’t Typically Issue NOVs For ‘Routine’ Venting Of Natural Gas, Will Air Quality Under New Regs?  [PaEN] 

-- PA Oil & Gas Industrial Facilities: Permit Notices/Opportunities To Comment - September 30   [PaEN] 

-- DEP Invites Comments On Title V Air Quality Permit For Eastern Gas Transmission Compressor Station In Westmoreland County At Oct. 31 Hearing  [PaEN]

-- DEP Posted 54 Pages Of Permit-Related Notices In September 30 PA Bulletin  [PaEN] 

NewsClips This Week:

-- PennLive Guest Essay: Gov. Shapiro, The Fracking Clock Is Ticking - By Megan McDonough, Food & Water Watch

-- AP: Gov. Shapiro Noncommittal On Greenhouse Gas Strategy As Climate Task Force Finishes Work

-- The Allegheny Front: EPA’s Approval Of 2nd Plum Boro Oil/Gas Wastewater Injection Well In  Allegheny County Raises Fears That More Are On The Way

-- Grist - Will Peischel: Inside The Rough-And-Tumble Race To Clean Up America’s Abandoned Oil & Gas Wells [PA Highlighted]

-- Planet Philadelphia Radio: Cleaning Up Our Energy Systems, Oct. 5 At 4:00 p.m.

-- Observer-Reporter: Pipeline Operator Faces $100,000 PUC Penalty For 2020 House Explosion In Greene County

-- WTAE: Natural Gas Pipeline Leak In Collier Twp., Allegheny County Forces People Out Of Their Homes

-- PUC Commissioner Kathryn Zerfuss Appointed To Presidential Task Force On Evolving Natural Gas Infrastructure Planning

-- Utility Dive: PJM Board Calls For Capacity Market Changes To Bolster Grid Reliability, Resource Adequacy

-- Guest Essay: EPA Further Threatens Grid Reliability By Reducing Carbon Pollution From Power Plants, Including Natural Gas-Fired Power Plants - By Sen. Gene Yaw (R-Lycoming), Majority Chair of the PA Senate Environmental Committee

-- Pittsburgh Business Times: Marcellus Shale Gas Industry Coalition Highlights Natural Gas Industry’s Economic Impact In PA; Faces Bills Extending Safety Zones

-- Marcellus Shale Gas Industry Coalition: Natural Gas Generates $41 Billion In Economic Activity, Supports 123,000 Jobs, Produced $6.3 Billion In Landowner Royalties 

-- Erie Times Guest Essay: Marcellus Shale Gas Coalition Wraps Up Conference In Erie - Natural Gas Delivers For All Pennsylvanians

-- JDSupra: Federal Court In Ohio Makes Important Ruling On Post-Production Costs For Oil & Gas Leaseholders Under ‘Market Enhancement’ Clause

Related Articles This Week:

-- Environmental Health Project: How DEP Issues Permits For Shale Gas Facilities Without Considering Cumulative Impacts - How New Facilities Will Add To Existing Pollution Loads And Impact The Area  [PaEN]

-- Member Of Pine Creek Headwaters Protection Group Briefs DCNR Advisory Council On Siting Of Shale Gas Well Pad On State Forest Land To Accommodate Taking Gas From Private Land In Tioga County  [PaEN]

-- Gov. Shapiro’s Work Group Concludes A Cap-And-Invest Carbon Pollution Regulation Program Would Be Optimal Approach To Reducing Greenhouse Emissions From Power Plants; Scale Up Solar Energy  [PaEN]

-- On Sept. 27 Families Will Hold Town Hall Meeting In Washington County Seeking Policy Changes After Pitt Studies Link Natural Gas Development And Negative Health Outcomes  [PaEN]

-- Guest Essay: DEP Should Invest $33.6 Million In New Federal Funding Wisely To Plug  Conventional Oil & Gas Wells And Not Reward The Industry For Bad Behavior  - By  Russell Zerbo, Clean Air Council  [PaEN] 

-- DEP Updates Times Of 2 Hearings On Interim Final Environmental Justice Policy To Accept Comments In Erie, Philadelphia  [PaEN] 

-- PJM Interconnection Board Proposes Market Reforms Based Largely On Unreliability Of Natural Gas-Fired Power Plants During Winter Storm Elliot  [PaEN] 

-- PJM Interconnection Files Proposed Winter Storm Elliot Settlement With Non-Performing Electric Generators With FERC, Requests Final Action By Dec. 29  [PaEN]  

[Posted: September 28, 2023]  PA Environment Digest

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