Ask the EPA not to eliminate regulations for methane leaks from natural gas transmission pipelines and storage facilities. Ask the EPA to regulate oil and gas extraction and gas processing for methane emissions rather than VOC emissions. Tell the EPA that we need higher standards for eliminating methane leaks in the oil and gas industry.
(1) Submit your Comment to EPA. By November 25th, click here to submit your comment at the federal register.
(2) Share your comment with your members of congress.
- Senator Dianne Feinstein: (415) 393-0707, (310) 914-7300, (202) 224-3841, or email.
- Senator Kamala Harris: (415) 355-9041, (213) 894-5000, (202) 224-3553, or email.
Find your Representative:
- Rep. Mark DeSaulnier - 11th district: (510) 620-1000, (202) 225-2095, or email.
- Rep. Nancy Pelosi - 12th district: (415) 556-4862, (202) 225-4965, or email.
- Rep. Barbara Lee - 13th district: (510) 763-0370, (202) 225-2661, or email.
- Rep. Jackie Speier - 14th district: (650) 342-0300, (202) 225-3531, or email.
- Rep. Eric Swalwell - 15th district: 510-370-3322, 202-225-5065, or email.
—The purpose of the 2016 New Source Performance Standards (NSPS) for new facilities in the oil and gas industry was to reduce methane emissions (leaks) by setting clear requirements for the frequency and methodology of leak monitoring and by requiring leak repair within 30 days. The EPA’s intention was to follow up with a similar proposal for reducing methane leaks from existing oil and gas facilities (infrastructure).
—The current EPA proposal ( Docket # EPA-HQ-OAR-2017-0757) would eliminate methane leak standards for the transmission and storage of natural gas. It would also eliminate methane leak regs for the extraction of oil and gas and the processing of natural gas but keep the VOC (volatile organic compound) leak regs. The justification for this is that procedures for implementing the methane and VOC regs are essentially identical and therefore duplicates.
—Last year we commented on the EPA proposal (Docket # EPA-HQ-OAR-2017-0483) to weaken methane leak protection by reducing monitoring requirements and doubling the time allowed for leak repairs.
—Note: It is best to personalize or modify the wording. You do not need to be a scientist or expert to submit your comments. Add any personal experience you, your family or friends are having with the effects of climate change. You may also create your own comments using information from the references below. The EPA is required to read and address all comments on its proposed rule changes. Environmental groups that sue the EPA when it adopts changes that they regard as illegal may also be able to use your comments in their court cases.
We in California are already experiencing the effects of global warming. I lost power on two separate occasions last month because of wild fires made worse by global warming and another power shutoff is threatened for my area this week. I am against the EPA proposals (Docket # EPA-HQ-OAR-2017-0757) to eliminate the direct regulation of methane leaks from new oil and gas extraction and gas processing facilities and to eliminate all methane leak regulation in the transmission and storage of natural gas. At a time when global warming is proceeding faster than the IPCC expected we need to increase the monitoring and repair of methane leaks in the entire oil and gas infrastructure of this country. The proposed changes would take us in the wrong direction.
The EPA claims their proposed changes are justified because they will reduce compliance costs and thus boost economic growth. The EPA estimates that the oil and gas industry will save $17-19 million per year, an insignificant percentage of the $100-150 billion annual revenue of the industry. These savings will go to inefficient small producers with leaky wells that can not afford new equipment to reduce methane leaks, not to the large producers responsible for growth.
In fact, the major producers of natural gas have not only asked the EPA to tighten methane leak regs for new facilities they have asked that all existing oil and gas facilities be regulated as well. These large producers plan to expand their investment in shale fracturing and realize that future demand for their natural gas will be greater if natural gas is cleaner (provided with fewer methane leaks). While these large producers have vowed to reduce methane emissions they do not want the industry to have a tarnished image because other companies are allowed to produce “dirtier” natural gas.
Many scientists believe that new methane leak-detecting technology and better emissions control engineering are necessary if natural gas is to be included in the future energy mix. Venting of methane needs to be reduced.
The 2018 National Climate Assessment warned that global warming could be responsible for reducing the size of the US economy by 10% by the end of the century if greenhouse gas emissions are not reduced more quickly.
The cost benefit analysis that was used to justify the proposed weakening of methane leak standards is inaccurate, outdated and incomplete. The climate benefits from reducing methane emissions are undervalued and total methane emissions are underestimated. A 6 year Environmental Defense Fund (EDF) study of methane leaks by 140 scientists concluded recently that methane emissions in the US oil and gas industry are 60% greater than those reported by the EPA.
Many scientists have said that reducing methane emissions in the oil and gas sector is one of the easiest ways to reduce climate change. Methane emissions only remain in the atmosphere for around 12 years yet they have over 80 times as much warming effect as carbon dioxide during that period. About 25% of the global warming we are experiencing today is due to methane. The NRDC estimates that the EPA could cut methane leakage by more than half in only a few years if it issued methane standards under the Clean Air Act. This would have a large impact on the global warming that we will experience in our lifetime.
The International Energy Agency (IEA) estimates that 50% of methane leaks in the oil and gas industry could be fixed in a few years at zero net cost because the value of the methane saved would cover the increased cost of monitoring and repair.
The emission of concern in the oil and gas industry is methane. Emissions of the other VOCs (volatile organic compounds) are very small. VOC standards not methane standards should have been rescinded to correct EPA reporting duplication problems. Also the rescission of methane standards might prevent the EPA from developing much needed guidelines for emissions reductions in the industry. A best practices guide could highlight some stricter state standards. For example, California does not allow pneumatic pumps to vent methane into the atmosphere and Pennsylvania put limits on methane emissions from dehydrators, storage vessels and tanker truck loading operations.
In summary the EPA needs to do more to protect us from the methane emissions of the oil and gas industry. The proposed changes do less and should be withdrawn. Scientists agree that methane emissions from the US oil and gas industry are much greater than reported. Less venting and flaring should be allowed and more frequent and thorough leak detection of all equipment should be required. The EPA should issue methane standards under the Clean Air Act and it should develop best practice guidelines for eliminating methane leaks in the natural gas industry.
Natural gas at the well pad is primarily methane (70-90%) but usually also contains water, sand and small amounts of ethane, butane and propane. After the refining process, natural gas is almost entirely methane.
Natural gas has been touted as a much cleaner source of energy than coal because its use in power plants produces only 44-50% of the greenhouse gas emissions of coal. But the production of natural gas produces more emissions of methane and carbon dioxide than the production of coal and the transport of natural gas to power plants is also subject to methane leaks. Natural gas only provides climate benefits over coal if the methane rate of leakage from its production at the well to its final user is sufficiently limited. The amount of leaking that occurs varies tremendously and is difficult to measure making it unclear how much cleaner natural gas actually is. Some groups even argue that it is not cleaner. Leaks occur when wells are drilled or fracked, during the unloading of liquids from wells, when gas is dehydrated, when pneumatic devices regulate gas pressure, when gas is transported by pipeline and passes through compression stations, when gas is stored and after wells are plugged/abandoned. At least forty separate types of equipment are known to be potential sources of methane leaks during the production and processing stages of fracking for oil and gas.
As part of a 6 year research study (begun in 2012) on methane emissions from the US oil and gas industry the Environmental Defense Fund (EDF) based on observations from aircraft and on the ground measurements downwind from oil and gas facilities in Pennsylvania concluded that on average methane emissions were 60% greater than the levels reported by the EPA whose estimates are based on industry reported numbers. They found that leaks could be as much as 5 times greater than what was reported by industry. Outdated monitoring equipment failed to measure many emissions and faulty equipment was responsible for most emissions. The recent EDF study concluded that methane leaked at a rate of 2.3%. Many scientists feel that a leak rate of 4% cancels out any benefit from burning gas instead of coal in power plants.
A group of scientists at Cornell has been arguing for years that methane emissions from the production of natural gas are much higher than government estimates that rely on industry reports. According to one “The amount of methane added to the atmosphere in the past decade corresponds to studies that show fracking operations leak, vent, or flare between 2 and 6 percent of the gas produced,”The Union of Concerned Scientists estimates that the rate of methane emissions in the oil and gas industry typically varies from 1 to 9 %. In summary, while scientists don’t agree on how much methane the oil and gas industry is emitting, they do seem to agree that the methane leak problem in the oil and gas industry has been underestimated and as a result the benefits of natural gas have been overstated.
The oil and gas industry accounts for about 40% of annual methane emissions in the US according to the EPA.
Currently the EPA limits methane emissions through its Leak Detection and Repair (LDAR) program. This program was weakened recently by the EPA when the frequency of monitoring for equipment leaks was reduced, the allotted time for repairs was lengthened, less stringent methods to detect and limit emissions were permitted and certification by a professional engineer that methane emissions requirements were being met was eliminated. Environmental groups have sued the EPA to rescind this weakening of the methane regs.
The EPA’s current proposal to eliminate all monitoring of methane emissions when natural gas is in storage or in transmission pipelines makes no sense as the IPCC recently declared that global warming is increasing more rapidly than expected. Should this proposed rule be finalized the EPA will be sued by various environmental groups.
In an attempt to eliminate duplicate efforts the EPA proposal requests that methane specific standards for the oil and gas industry be rescinded and VOC (volatile organic compound) standards be kept. The choice to keep the VOC requirements rather than the methane requirements was based on the fact that the VOC requirements were established prior to the methane standards and storage vessels are currently regulated for VOC emissions but not methane emissions. This really makes little sense since methane is the only real gas of concern in the oil and gas industry and when the VOC requirements were established in 1985 the dangers of global warming were relatively unrecognized.
Because methane mostly breaks down through chemical reactions in the atmosphere after only 12 years while CO2 remains in the atmosphere for over 1000 years, CO2 is a much bigger problem for global warming than methane in the long run. However, in the short run we can reduce the effects of global warming most easily by reducing methane emissions from the oil and gas industry as well as those from landfills and livestock because methane has over 80 times as much warming potential as CO2.
The Administrator of the EPA recently stated that there was no need to regulate methane leaks in the oil and gas industry because it was financially advantageous for the industry to reduce its methane emissions. But this is not accurate. The amount of methane leak reduction that would be financially advantageous to the industry is less than the amount that would be advantageous for all Americans. Furthermore without regulations there is no sense of urgency for the industry to address the issue even if it would be financially advantageous. Many producers will not adopt more methane leak reduction unless it is mandated. If mandated they will do so or exit the industry. This is best for the health of the industry and the health of our population.
- Doniger, D., “EPA’s Free Pass for Oil and Gas: Another Climate Surrender”, NRDC.org, 8/29/19.
- EPA, “Executive Summary, Oil and Natural Gas Sector: Emissions Standards for New, Reconstructed and Modified Sources Review, Proposed Rule ID: EPA-HQ-OAR-2017-0757-0002”, Docket Folder Summary, regulations.gov, 9/24/19.
- Friedman, L. and Davenport, C., “Curbs on Methane to Be Relaxed in US”, New York Times, 8/30/19.
- Fuller, G.,”How fracking can contribute to climate change “, The Guardian, 5/29/16.
- Mandel,J. and Zou, J, “Leaks Threaten Safety and Success of America’s Top Natural Gas Exporter”, publicintegrity.org, 5/31/19.
- Mingle, J., “Atmosphere Methane Levels Are Going Up And No one Knows Why”, wired.com, 5/16/19.
- Nuccitelli, D., “Key facts about the new EPA plan to reverse the Obama-era methane leaks rule”, yaleclimateconnections.org, 9/9/19.
- Schwartz, J. and Plummer, B., “The Natural Gas Industry has a Leak Problem”, New York Times, 6/21/18.
- Turpentine,J., “The Natural Gas Industry Has a Methane Problem”, NRDC.onEarth, 6/7/19.
- Wihbey, J., “Pros and Cons of fracking:5 key issues”, yaleclimateconnections, 5/27/15.