Yesterday at COP27 in Sharm el Sheikh, Egypt, the U.S. Environmental Protection Agency (EPA) announced it is strengthening its proposed standards to cut methane and other harmful air pollution. If finalized, these critical, commonsense standards will protect workers and communities, maintain and create high-quality, union-friendly jobs, and promote U.S. innovation and manufacturing of critical new technologies, all while delivering significant economic benefits through increased recovery of wasted gas.
The updates, which supplement proposed standards EPA released in November 2021, reflect input and feedback from a broad range of stakeholders and nearly half a million public comments. The updates would provide more comprehensive requirements to reduce climate and health-harming air pollution, including from hundreds of thousands of existing oil and gas sources nationwide. It would promote the use of innovative methane detection technologies and other cutting-edge solutions, many of which are being developed and deployed by small businesses providing good-paying jobs across the United States.
The new proposal also includes a ground-breaking “Super-Emitter Response Program” that would require operators to respond to credible third-party reports of high-volume methane leaks. The agency estimates that in 2030, the proposal would reduce methane from covered sources by 87 percent below 2005 levels.
Oil and natural gas operations are the nation’s largest industrial source of methane. Methane is a potent greenhouse gas that traps about 80 times as much heat as carbon dioxide, on average, over the first 20 years after it reaches the atmosphere and is responsible for approximately one third of the warming from greenhouse gases occurring today. Sharp cuts in methane emissions are among the most critical actions the U.S. can take in the short term to slow the rate of climate change. Oil and natural gas operations are also significant sources of other health-harming air pollutants, including smog-forming volatile organic compounds (VOCs) and toxic air pollutants such as benzene.
The Clean Air Act standards in the supplemental proposal will complement President Biden’s Inflation Reduction Act, which provides resources for financial and technical assistance and a waste emissions charge for applicable oil and gas facilities that exceed statutorily specified waste emissions thresholds. The Inflation Reduction Act incentivizes early implementation of innovative methane reduction technologies and supports methane mitigation and monitoring activities, allowing the United States to achieve greater methane emissions reductions more quickly.
Taking into account both the supplemental proposal and other measures in the November 2021 proposal, EPA projects that the proposed standards would reduce an estimated 36 million tons of methane emissions from 2023 to 2035, the equivalent of 810 million metric tons of carbon dioxide. That’s nearly the same as all greenhouse gases emitted from coal-fired electricity generation in the U.S. in 2020. EPA’s estimates also show the updated proposal would reduce VOC emissions by 9.7 million tons from 2023 to 2035, and air toxics emissions, including chemicals such as benzene and toluene, by 390,000 tons. These projections reflect new analysis of the costs and benefits of the proposed standards, which incorporates an improved modeling approach as well as updated estimates of the number of facilities covered by the supplemental proposal and the amount of methane and VOCs they emit.
The supplemental proposal reflects public input on the November proposal and new information and analyses, which helped the EPA determine comprehensive and cost-effective approaches to reduce pollution from oil and natural gas facilities. Key features of the supplemental proposal would:
- Ensure that all well sites are routinely monitored for leaks at less cost, and until they are closed properly;
- Provide industry flexibility to use innovative and cost-effective methane detection technologies, and a streamlined process for approving new detection methods as they become available;
- Leverage data from remote sensing technology to quickly identify and fix large methane leaks;
- Require that flares are properly operated to reduce emissions, and revise requirements for associated gas flaring;
- Establish emission standards for dry seal compressors, which are currently unregulated;
- Set a zero-emissions standard for pneumatic controllers and pneumatic pumps at affected facilities in all segments of the industry.
- Increase recovery of natural gas that otherwise would go to waste – enough gas from 2023 to 2035 to heat an estimated 3.5 million homes for the winter.
Proposal includes super-emitter response program
The supplemental proposal would also establish a super-emitter response program that would leverage data from regulatory agencies or approved third parties with expertise in remote methane detection technology to quickly identify these large-scale emissions for prompt control. Studies show that large leaks from a small number of sources are responsible for as much as half of the methane emissions from the oil and natural gas industry, along with significant amounts of smog-forming VOCs. While many requirements of EPA’s combined proposals would reduce common sources of super emitters, EPA is proposing the response program to address super emitters’ significant pollution and impact on communities where they are located. To ensure that the super-emitter response program operates transparently, notices sent to oil and natural gas owners and operators, along with their response and any corrective actions, would be available on a website for easy access.
In addition to making EPA’s proposal more comprehensive, the supplemental proposal includes requirements for states to develop plans to limit methane emissions from hundreds of thousands of existing sources nationwide. EPA is proposing to require states to submit those plans within 18 months after the final rule is issued, and to establish compliance deadlines for existing sources that are no later than three years after the submission deadline. The supplemental proposal includes requirements for considering the communities most affected by and vulnerable to oil and gas emissions, along with a demonstration of meaningful community engagement as states develop their plans.
EPA estimates that the supplemental proposal will yield total net climate benefits valued at $34 to 36 billion from 2023 to 2035 (the equivalent of about $3.1 to $3.2 billion per year), after taking into account the costs of compliance and savings from recovered natural gas. The climate benefits are estimated using the social cost of greenhouse gases, a metric that represents the monetary value of avoided climate damages associated with a decrease in emissions of a greenhouse gas. While EPA’s estimates are based on the interim social cost of greenhouse gases recommended by an interagency working group in February 2021, EPA also is including a separate analysis that is based on updated social cost of greenhouse gases estimates that address recommendations of the National Academies of Science, Engineering, and Medicine. The additional analysis and accompanying EPA draft technical report will be available in the rulemaking docket for public comment. EPA is also seeking peer review of the report.
EPA will take comment on the supplemental proposal until February 13, 2023. The agency will host virtual trainings to provide communities, Tribes and small businesses information about the supplemental proposal and about participating in the public comment process. Those trainings will be November 17 and 30, 2022 and registration information is available on EPA’s website. EPA will hold a virtual public hearing January 10 and 11, 2023. Registration for the public hearing will open after the supplemental proposal is published in the Federal Register. EPA intends to issue a final rule in 2023.