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Dear Friend, The U.S. Environmental Protection Agency (EPA) has updated methane and volatile organic compound (VOC) pollution control standards for new oil and gas sites and formally proposed the first-ever federal methane control standards for all existing oil and gas sites. According to the EPA, methane pollution contributes to a full third of the climate chaos we’re currently experiencing, and the oil and gas industry is the single largest source of methane pollution in the U.S. Methane is up to 87 times more potent at trapping heat in the atmosphere than carbon dioxide over a 20-year period. The EPA has even concluded that, while carbon dioxide emissions have decreased because of lifestyle changes during the ongoing COVID-19 pandemic, methane pollution from the oil and gas industry has still steadily increased. The EPA is projecting that its pollution standard will create $4.5 billion in climate benefits annually while reducing 41 million tons of methane pollution by 2035. Even so, Clean Air Council believes this rule could be significantly improved, and EPA is specifically requesting comment on a few key areas of the rule. Beyond methane, this rule will also reduce smog-causing VOC emissions, as well as hazardous air pollutants (HAPs) like the known carcinogen benzene. Decreasing pollution from oil and gas sites offers a unique opportunity to tackle greenhouse gases, asthma-causing ground-level-ozone (smog), and dangerous HAPs all at once. Arguably the most important topic in the proposed rule is the method of measuring air pollution levels from individual well sites. To date, air pollution accounting has been based on formulas related to technology and processes being used at individual well sites, but now EPA is requiring regular onsite pollution monitoring that will more accurately account for aging or malfunctioning equipment. EPA has created three categories from “low” to “high” polluting wells and is now proposing to require more direct pollution monitoring at sites with higher levels of air pollution. This is a great step, but EPA must go further to ensure the most accurate measurements of air pollution from all well sites. Because baseline air quality measurements have never been established, the EPA must take great care in properly identifying “low-emitting” wells before exempting them from follow-up air monitoring. EPA clearly states that a significant portion of air pollution from gas well sites is generated from aging equipment, which could potentially be present at all oil and gas wells. Another key request for more information relates to the proposed requirement that drillers have pipelines available on-site to collect fracked gas using control devices. A variety of equipment at oil and gas sites intentionally emit methane when the pressure in drilling or processing lines becomes too great. This gas is directly emitted to the atmosphere or flared onsite, creating additional unnecessary air pollution. In the newly proposed rule, the EPA is considering a requirement that if a sales gas line is reasonably close to a well site, then the drilling operation would have to collect all of its methane pollution and reintroduce it into a pipeline. This will drastically reduce air pollution from oil and gas facilities and should be required at all gas well sites. EPA has not proposed specific terms regarding what will be considered a “reasonable” proximity of a sales gas line or if other storage equipment could receive this potential air pollution. Clean Air Council urges you to tell the EPA that it should require the gas industry to contain as much methane, VOC and HAP emissions as possible. The EPA is also requesting comments on a potential community air monitoring system that would notify nearby residents of air pollution incidents and require drilling companies to immediately fix malfunctioning equipment. Local residents now have a voice in gas drilling in their region and we must demand that EPA finalize the most protective, environmentally just rule possible. | |
Joseph Otis Minott, Esq.
Executive Director and Chief Counsel | |
