Most of the oil and gas sector's methane emissions would fall outside of regulation if EPA carries out plans to weaken Obama-era rules for the sector.
Observers expect EPA will soon propose regulations for the industry that won't target methane directly and that will cover new upstream facilities only. The rules would set EPA up to ignore existing oil and gas operations, which contribute the vast majority of the sector's methane emissions (Climatewire, Aug. 12).
As a result, at least 84% of the petroleum sector's emissions wouldn't be covered, according to data drawn from six years of peer-reviewed research by the Environmental Defense Fund and 140 lead authors at universities and institutions across the country.
A synthesis report in Science last year spearheaded by EDF scientist Ramón Alvarez built on 16 prior studies to estimate that the petroleum sector leaked 13 million metric tons (MMT) of the potent greenhouse gas in 2015.
Using those peer-reviewed figures, new and modified production covered by the rule accounted for about 1.4 MMT of methane in 2015, and gathering and processing facilities that might be included in the rule would bring the covered total up to about 2.1 MMT — or 16% of the sector's total methane output.
"We now know that that number is probably low," said David Lyon, an EDF scientist who worked on the project culminating in the Science report.
When wells drilled since 2015 and new emissions projections from Texas' Permian Basin are added to that tally, the sector's true methane footprint was likely at least 15.6 MMT two years ago, according to EDF's production data.
EPA's own figures for oil and gas methane are significantly lower. The agency's April 2017 inventory estimates the oil and gas sector was responsible for 8.1 MMT through 2015.
But EPA uses a methodology that EDF and other experts say systematically undercounts oil and gas methane (Climatewire, Aug. 7). Between EPA's lowball estimate and its leaders' decision to propose two separate rules to replace a single Obama-era methane standard for new sources — with costs and benefits for that swap split between those two rulemakings — experts in the environmental field fear the agency's regulatory impact analysis will hide the true consequences for the climate.
The costs of warming from increased methane emissions could be compounded, experts say, if the Trump administration manages to prevent the regulation of existing oil and gas sources.
"I think that really the biggest issue is that they're going to be underestimating the avoided losses and potential benefits of having a strong regulation," Lyon said.
EPA is expected to propose rules for new and modified sources that center not on methane but on volatile organic compounds, or VOCs. The ozone precursor is leaked during the production, processing and gathering of natural gas. Capturing it could have the co-benefit of limiting methane emissions at those stages of the oil and gas supply chain.
But VOCs are barely present further downstream. While the Obama-era rule directly covered methane leaked by oil and gas transmission and storage, observers expect the new rules to ignore those emissions.
The Science study found that in 2015, the U.S. oil and gas industry leaked 1.8 MMT of methane during transmission and storage.
Excluding those stages in the new source regulations won't in and of itself make much of a difference in methane emissions. That's because the overwhelming majority of oil and gas infrastructure from well pad to storage tank to pipeline is deemed "existing" by EPA. Only about 0.2% of oil and gas transmission and storage infrastructure would be touched by a new source rule, based on criteria laid out in the Obama-era rule.
During the Obama administration, EPA had been eyeing regulations for existing oil and gas operations across the supply chain. But by tailoring its new rule to VOCs, EPA may now be able to skirt a regulatory "trigger" to consider whether existing sources' methane emissions merit limits.
The Science report estimates that existing production operations released 6.2 MMT in 2015. EDF's more recent figures for the Permian and post-2015 production expands that number to 8.4 MMT. At least 80% of U.S. processing and gathering infrastructure would be considered existing sources, as well.
So the climate impact would be substantial if EPA skips an existing-source rule for oil and gas methane. Consider that a metric ton of methane contributes at least 25 times as much to climate change in the first century after its release as a metric ton of carbon dioxide.
The cost to society and the economy from those unregulated emissions could be large, too: $11.7 billion, based on the Obama administration's final social cost of methane estimate of $1,400 per metric ton.
'License to operate'
Many U.S. oil and gas producers have long opposed existing-source rules, and the American Petroleum Institute made that a top request early in the Trump administration.
In a February 2017 email to Associate Deputy Secretary of the Interior James Cason, API senior policy adviser Holly Hopkins included a wish list of rules and rollbacks for agencies across the federal government. The second item was EPA's methane standard.
"Regulation of existing sources should be avoided," stated the wish list, which EDF obtained through a Freedom of Information Act request to DOI.
The trade group proposed that EPA revisit the Obama-era determination that existing source methane represents a "significant contribution" to the finding that greenhouse gases endanger public health and welfare, a precondition for regulating it. In remarks to a U.S. Energy Association gathering in May, EPA Administrator Andrew Wheeler indicated that the agency is reconsidering that determination in its new oil and gas proposal.
API continues to press for a VOC-only standard for new and modified sources and for no existing-source standard. It did not respond to requests to comment. But some large multinational petroleum companies have taken more progressive stances on regulation, calling for EPA to keep in place many of the Obama-era methane capture requirements, including green completions to control methane at the wellhead (Energywire, March 13).
In comments submitted to EPA last year for a related proposal on leak monitoring and record-keeping requirements, Exxon Mobil Corp. expressed support for both new and existing methane regulations.
"In that regard we support retaining the key elements of the underlying regulation, such as leak detection and repair programs, control requirements on regulated storage tanks and reduced emission completion on new wells," the company stated.
And Susan Dio, chairwoman and president of BP America, said in a March op-ed in the Houston Chronicle that EPA must regulate methane.
"[W]e need to protect natural gas' license to operate," she wrote. "When used in electricity generation, natural gas has less than half the CO2 emissions of coal, and it also can be a vital backup to renewables. But to maximize the climate benefits of gas — and meet the dual challenge of producing more energy with fewer emissions — we need to address its Achilles' heel and eliminate methane emissions."
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