By Joseph Otis Minott
The U.S. Environmental Protection Agency’s (EPA) recently proposed supplemental methane pollution standards for new and existing oil and gas facilities are among the most efficient environmental rules ever drafted, both in terms of the public health benefits achieved and the methods by which harmful air pollution will be reduced.
For multiple reasons, Pennsylvanians truly have the most to benefit from this federal rule-making. More Pennsylvanians are exposed to increased cancer risks caused by the oil and gas industry than residents in any other state in the country. Pennsylvania is the second-largest gas producing state, and our gas industry emits upwards of 1.1 million tons of methane annually.
The federal standards would not exempt so-called low-producing wells from leak inspection requirements, as Pennsylvania’s recently finalized state-level volatile organic compound (VOC) rule does.
In fact, EPA stated it no longer believed the amount of oil or gas produced by a well is an appropriate metric to exempt it from inspections. Low-producing wells are collectively responsible for half the methane pollution from the industry. EPA is currently proposing to require quarterly inspections at small well sites with increased inspections at larger sites.
This draft rule will significantly reduce climate-changing methane pollution, smog-causing VOCs and carcinogens like benzene while conserving gas and advancing technical careers through increased inspection or monitoring requirements.
The rule also extends monitoring requirements for oil and gas wells until they are successfully plugged, which will help address the pervasive crisis of unplugged abandoned wells. Pennsylvania has more such wells than any other state, with estimates ranging as high as 560,000.
The proposed rule must still be strengthened, but because of the Methane Emissions Reduction Program (MERP) included within the Inflation Reduction Act (signed into law by President Biden in August 2022), federal funds will soon be allocated to programs that will support necessary technology improvements and pollution reduction.
The EPA’s proposed rule is out for public comment until February 13, 2023, and there are several areas where the rule could be improved.
Most important is that, in the current draft, EPA would continue to allow unnecessary gas flaring and venting if a company claims it is unable to capture and repurpose gas that is released during oil drilling or liquids unloading. Liquids unloading activities are commonly referred to as “blowdowns” and are a significant source of air pollution in Pennsylvania.
Their frequency is also routinely underestimated by the Pennsylvania Department of Environmental Protection (DEP) in air pollution permits.
Most industrial rules are focused on annual pollution levels at a specific facility, but concentrated pollution events like blowdowns result in acute exposures to air pollution that increase the likelihood of respiratory damage or other health effects. EPA has advocated for equipment that would reduce air pollution from blowdowns since 2012 and must take an active role in the application of these pollution reduction technologies, specifically with the $1.55 billion allocated to EPA in the MERP.
EPA also needs to clarify how the agency will evaluate and approve/deny venting and flaring applications from operators, including what role states will have. Rather than applying for an exception to create air pollution, companies could instead apply for assistance in avoiding concentrated, high-emission pollution incidents.
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Reducing venting and flaring will significantly decrease methane, an extremely potent greenhouse gas, as well as smog-causing VOC emissions and carcinogens.
This will conserve gas, fight climate change, and protect local public health. This is a major reason why this rule is so impactful. Addressing air pollution from oil and gas facilities will reduce multiple pollutants and create multiple benefits in a way that is unlike regulation of other industrial sources.
For the same reasons, EPA must not allow gas companies to apply for exceptions that will undo the potential benefits of this rule. We must not miss this opportunity. The rule’s potential to empower frontline communities with resident-led monitoring projects will be another massive step forward in terms of how the public is able to engage with neighboring industry.
Moreover, MERP funds should be used to train and compensate residents who wish to participate in the EPA’s proposed “Super-Emitter Response Program,” which will require gas companies to remedy pollution incidents recorded by third-parties, including public notification of repairs at oil and gas facilities.
EPA must specify that participation in this training program will be a central element of the community outreach that EPA is requiring of states while they design their own plans to implement the rule. Section 111(d) of the Clean Air Act authorizes EPA to set “emissions guidelines” for existing pollution sources, and the states are then required to draft their own rules to implement those guidelines while achieving the same or greater emissions reductions.
Requiring that states conduct community outreach while designing their pollution standards is another step toward progress. Nevertheless, it is concerning that EPA is currently proposing a four-and-a-half year timeline between the rule’s ultimate finalization and the deadline for industry’s compliance.
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EPA must take steps to prevent this lengthy process from creating unintended consequences, such as the mass abandoning of gas wells before regulations are in place to require their continued monitoring.
EPA could offer states and gas companies incentives for the early adoption of these necessary public health standards while also increasing air monitoring at oil and gas facilities to identify malfunctioning equipment prior to enforcement deadlines.
Pennsylvanians should be eager to support and strengthen this proposed methane pollution standard because of this rule’s immense potential to protect public health, empower impacted communities, and advance new technologies.
We must show the EPA that we need to finalize strong, comprehensive methane standards and modernize an industry that has polluted the Commonwealth for too long.
Joseph Otis Minott is the executive director and chief counsel at Clean Air Council. His work appears frequently on the Capital-Star’s Commentary Page. He writes from Philadelphia.
Originally published at www.penncapital-star.com,by Capital-Star Guest Contributor
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