In testimony at an EPA public hearing this week, Wes Wilson of Be The Change USA urged regulators to tighten control over methane emissions from oil and gas wells. Below is Wes’s complete testimony at the hearing.
“I worked here — at EPA’s Regional Office in Denver — as an environmental engineer for over 35 years. I represent BE THE CHANGE, a Colorado non-profit organization dedicated to better government.
I’m here today as a concerned citizen to testify that these rules are inadequate as a remedy and not in time to be effective.
EPA plans to use its Clean Air Act authority to compel the industry to reduce methane and toxic air emissions coming from oil and gas industry exploration and production facilities.
Reducing methane and VOCs could aid climate stability and reduce ozone and health effects resulting from fracking for oil. But these rules would only reduce methane and VOCs emissions by EPA’s own estimate by about 20 to 25% — less than 1/4th of the toxic gases emitted during drilling and initial production would be captured under this rule making.
Is 25% less enough to matter?
Climate stability: Today EPA is to a large extent mimicking Colorado’s experiment under its 2010 Clean Air, Clean Jobs Act — which cuts coal-fired power plants that are replaced with natural gas-fired plants.
Both the President and industry representatives consistently allege that natural gas-fired plants compared to coal will improve climate stability due to reduced greenhouse gas emissions. This claim is conclusively false.
Here in Colorado, ambient air analyses by CU and NOAA show more than 4% of the of the methane produced by the industry escapes. In Utah ambient measurements show up to 9% methane leakage rates. 4% to 9% leak rates are consistent with the 2012 studies by Professors Ingraffea and Howarth of the University of Cornell who calculated a fugitive emission rate of 3.9% to 7.8%. In contrast EPA’s bottom’s up method claims only 2.4% of the methane produced escapes.
The critical question that EPA must answer: What amount of methane leakage would assure that substituting natural gas for coal aids climate stability? And how does the nation assure that minimal leakage rate?
EPA’s fact sheet on these rules cites now dated information that methane’s GWP — it’s global warming potential – is 25 times that of CO2 over a century. The IPCC’s 5th assessment updated that to 34-36 times over a century, but since methane has a short atmospheric life of 12 years, the IPCC warned then that there is no scientific basis for comparing GWP over a 100 year time-frame. Over 20-years, methane is 86 times more heat trapping than CO2. Critically, methane has a GWP of 125 times over 10 years considering feedback mechanisms. A threatening 125 times more solar radiant heat is retained by a pound of methane than a pound of CO2 in the critical decade after methane escapes.
EPA should adopt a 125 GWP for methane because that is, in fact, the amount of heat retained on the globe.
Therefore unless the fugitive leak rate is less than 1%, then the claim that natural gas is better for the climate than coal is false. Indeed, if the industry’s leak rate turns out to be 4%-9% as observed by NOAA, then natural gas is 4-9 times more harmful to climate stability than burning coal.
So if these rules result in 25% reduction of methane, there could remain unacceptable high of between 3%-7% leakage rate. Even if EPA’s 2.4% were to prove accurate, the remaining methane leakage rate after these rules of 1.8% would exceed the GWP of coal.
Initial studies in Utah in 2013 by EDF appeared to show EPA’s bottoms up method to be accurate. Later, EDF found methane releases from uncontrolled oil well completions to be thousands of times more than EPA’s inventory estimates. Just last month, the inventor of EPA’s approved methane measuring devise reported that this field instrument may underestimate methane releases by a factor of 10 to 100. Perhaps that explains why ambient measurements show consistently higher leak rates than EPA and EDF’s bottom up approach.
VOC reduction and health benefits: In Colorado, epidemiological studies show a 30% increase in birth defects for residents within 10 miles of an oil or gas well. NOAA’s ambient air studies show 55% of VOCs emissions along Colorado’s Front Range originate from the oil and gas industry. Colorado’s rules require a bit more, however, Colorado’s regulations only reduce VOCs and methane emissions by one-third. The remaining 2/3rd is not captured due to exemptions that apply to existing and stripper wells and the key fact that even 95%-effective flares still release both VOCs and methane. Neither the state’s nor EPA’s plan would reduce the cumulative gas emissions when expected industry growth occurs. EPA’s plan to capture just 1/4th of the methane and VOCs is neither based on climate nor health protection.0
As the inventor of the Peter Principle recognized: “Bureaucracy defends the status quo long past the time when the quo has lost its status.” EPA – don’t defend the fossil fuel industry by issuing these weak and minimal rules.
The nation needs to achieve substantial reductions, near zero, in the industry’s emissions of methane and VOCs to protect the climate and public health. Allowing the industry to release these toxic gases is harmful to children today and children of the future.
Thank you for your attention.”
– Weston W. Wilson