American Oil and Gas Reporter - July 2019 - 25

Regulations Meant To Limit
Methane Emissions
Go Beyond The Practical
Greenhouse gas emissions are the subject of increasing
scrutiny from state and federal regulatory agencies, environmental
groups, and the oil and natural gas industry. But regulatory
agencies and environmental groups have narrowed their attention
to methane emissions, arguing that methane is more prevalent
and more dangerous than emissions of carbon dioxide. The
natural gas industry also focuses on methane emissions, since
methane is the primary component of natural gas and producers
are reluctant to lose their product. Methane emissions are very
much a matter of perspective.
The most comprehensive accounting of GHG-related emissions
is the annual Inventory of U.S. Greenhouse Gas Emissions and
Sinks compiled by the Environmental Protection Agency. This
inventory calculates emissions based on both reported emissions
and estimates of emissions from smaller sources. The inventory
presents these results using the international standard as CO2
equivalents-converting all greenhouse gases to this 100-year
time horizon basis.
Using the 2019 inventory, which reports emissions through
2017, natural gas- and oil-production methane emissions are
1.2% of the inventory. The Environmental Defense Fund acknowledges, "Methane can come from many sources, both
natural and man-made."
EDF goes on to point to the oil and gas industry as the "largest
source of industrial emissions." However, targeting the production
sector does not consider the costs nor the incremental reduction
that can be achieved. The zeal with which oil and natural gas production is targeted prompts the question of whether the goal is to
reduce methane emissions or shut down production.
It is essential to understand that the Independent Petroleum
Association of America does not oppose all the elements of
regulations promulgated during the Obama administration. Its
issues relate to elements that are not cost-effective, and are
partly related to the nature of the Clean Air Act.
The first Obama regulation in 2012-Subpart OOOO-addressed
the largest emission sources (e.g., storage tanks, pneumatic controllers, natural gas well completions). Subpart OOOO targeted
these predominant production emissions by regulating volatile
organic compounds, which captures methane emissions as well.
While there are always some issues in interpreting requirements,
the 2012 regulations largely were based on known technology.
However, EPA continued with its regulation of the oil and
natural gas industry by proposing Subpart OOOOa regulations,
which shifted to methane as the target of emissions reduction.
These requirements present significant problems because they
rely on questionable technologies, principally regarding fugitive
emissions.
The issues here are twofold. First, the regulations use a costly,
cumbersome and questionable optical gas imaging leak detection
and repair (LDAR) technology. Second, because of the structure
of the CAA, as a methane regulation, the requirements expand
from new sources to existing sources. Instead of regulating
25,000-45,000 facilities a year, it expands to 1 million sources, of

"The question is whether the goal is
to reduce methane emissions or shut
down production."
which 770,000 are low-production, small business operations.
While the cost-effectiveness of these LDAR requirements is
questionable for the large, new wells that are developed, the
regulations clearly present a different challenge when applied
to low-production wells. According to the Energy Information
Administration, the average new natural gas well produces 4
million cubic feet a day while the average new oil well produces
700 barrels a day. These are vastly different from low production
wells that average 24 Mcf a day for natural gas wells and 2.5
bbl/d for oil wells.
Given that the emissions from these small wells are low and,
over time, the Subpart OOOO requirements will be embedded
in their operations, IPAA opposes the Subpart OOOOa regulations
because they threaten all these low production wells with costly
requirements that do not create environmental benefits.
In keeping with the strategy of putting low production wells in
their regulatory cross hairs, environmental groups also are targeting
small-diameter, low-pressure gathering lines in their mission to
reduce methane emissions. EDF managed to leverage its position
as a member of the Gas Pipeline Advisory Committee-an advisory
group to the Department of Transportation's Pipeline and Hazardous
Materials Safety Administration. In arguing that PHMSA's mandate
is to protect the environment as well as public safety, EDF lobbied
for LDAR technology to be applied to 55,000 miles of natural gas
gathering lines as small as eight inches in diameter.
Despite the absence of a cost/benefit analysis, and despite
information from experienced industry-sector members that
rural gathering is not the source of methane leaks, GPAC voted
11-1 to recommend LDAR technology for these low-risk rural
gathering lines-all in the name of reducing methane emissions
that are unquantified for volume or cost.
Environmental activists with their "keep-it-in-the-ground"
goal for fossil fuel development are so targeted on the minor
methane emissions from natural gas production that they fail to
understand that natural gas is a key part of any realistic strategy
to reduce GHG emissions. This strategy cannot be implemented
without natural gas production.
r

SUSAN GINSBERG is vice

president of crude oil and natural gas regulatory affairs for
the Independent Petroleum Association of America. She covers legislation and regulation,
focusing on the CFTC and
FERC. Her experience in natural gas regulatory affairs spans
more than three decades.
JULY 2019 25

American Oil and Gas Reporter - July 2019

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