Last Monday, the members of the IPANM Air Quality Committee and I submitted comments to the EPA, Office of Planning, on the five whitepapers issued by that Agency. The whitepapers, which came about at the request of the President in his March 2014 Climate Change: Strategy to Reduce Methane Emissions Report, sought to create a technical basis for reducing methane emissions in the oil patch from compressors, pneumatic devices, completions from hydraulically fractured oil wells, and during the liquids offloading process. The final whitepaper sought to review the “science” on methane leaks at oil and gas facilities.
The EPA whitepapers were meant to be a technical review of the existing studies in order to give EPA a “robust understanding” of the issues, but in reality it was nothing more than a data dump from carefully selected studies that used mostly modeling and not actual measurement from the field. The one study that did use some measurements was completed by UT professors, but it only looked at oil and gas facilities in shale plays. The main point raised by IPANM in our responses to the EPA was that the studies on methane emissions were flawed as they had very small samples, huge and extremely flawed extrapolation methodology and the whitepapers relied on studies completed by biased entities. In every whitepaper, there was heavy reliance on a study of 22 locations that was commissioned by the Environmental Defense Fund. On every panel doing a “peer review” of the whitepapers, there was a person from the Environmental Defense Fund. A second point made by IPANM was that the EPA should not rush this process and should learn from the data submitted by industry to the recent NSPS OOOO regulations.
On June 2nd, IPANM also submitted lengthy comments to the BLM Venting & Flaring Public Outreach Powerpoint presentation. This initiative, also the result of the President’s March Climate Change Report, was intended as a first step towards developing regulations on reducing methane emissions from compressors, liquid unloading, hydraulically fractured natural gas wells, leaks and pneumatic devices. Note that the subject matter of these regulations are nearly identical to the issues reviewed by the EPA in their whitepapers, but the BLM claims it has the authority to force regulations on methane emissions under a legal theory of prevention of waste and royalty collections. IPANM strongly contested this assertion in our comments.
According to the President’s Climate Change Strategy to Reduce Methane Emissions Report, both the EPA and the BLM are to have all rules and regulations on these issues completed by the end of 2016.
All of the comments submitted to the EPA are available below:
IPANM Leaks Comments to EPA
IPANM Compressors Comments to EPA
IPANM Completions Hydraulically Fractured Oil Wells Comments to EPA
IPANM Unloading Comments to EPA
IPANM Pneumatic Devices Comments to EPA
