Yesterday the Pennsylvania Dept. of Environmental Protection’s (DEP) Air Quality Technical Advisory Committee voted to recommend the DEP move forward with a proposed new regulation to control volatile organic compound (VOC) emissions, with a side benefit of reducing methane emissions, from existing oil and gas operations. It was a split vote, but it propels the regs to the next level.
In December, the DEP released a draft of the onerous new regulations, which will force drillers and pipeline companies to spend big bucks to produce a teeny tiny improvement in emissions. The DEP followed up with a revised version of the regs just a few weeks ago (see PA DEP Releases Onerous New Air Regulations, Again).
The regs focus on VOCs, not directly on methane emissions. But the DEP maintains by controlling VOCs a side benefit will be to control methane emissions. The shale industry doesn’t like it anyway, because it will require extraordinary measures costing big bucks for a very tiny benefit.
Turns out lefty environmentalists don’t like the new regs either–but for a different reason (see Enviros Don’t Like Gov. Wolf’s Onerous New Air Regs Either). The new regs, according to environuts, don’t go nearly far enough to kill off shale drilling. Therefore they are “sounding the alarm” about the new regs.
The environuts sounded the alarm following yesterday’s committee meeting:
On April 11, DEP’s Air Quality Technical Advisory Committee voted to recommend DEP move ahead with a proposed regulation to control volatile organic compound emissions, with a “co-benefit” of reducing methane emissions from existing oil and gas operations.It was the first time the full text of the proposal was discussed and the recommendation was made in a split vote by the Committee after a lively conversation during which environmental group representatives questioned whether the scope of the regulation was adequate to the task.Generally, the draft regulation outline calls for a 95 percent reduction in VOC emissions, however, some equipment-specific requirements call for less or more. For example, natural gas processing plants are required to have zero VOC emissions.DEP said the regulation, as drafted, would exempt the “lion’s share” of conventional oil and gas wells (perhaps 80 percent or more) and roughly 6 percent of unconventional gas wells in Pennsylvania from the leak detection and repair requirements due to the threshold emission limits.There are now about 80,000 conventional oil and gas wells and about 10,651 active unconventional gas wells in Pennsylvania.“The rule as currently drafted would capture only 21 percent of methane emissions. A 2018 report by Environmental Defense Fund estimated that emissions of methane, a potent climate forcing agent, from Pennsylvania’s oil and gas industry are up to five times higher than what is reported to DEP, or potentially 520,000 tons per year. DEP’s current draft focuses almost entirely on volatile organic compounds (VOCs), not methane.“The scope of DEP’s air emissions rule needs to be expanded – capturing only 21 percent of methane emissions leaves far too much pollution on the table and in our air. Simply removing the threshold for low-producing wells will allow for much more methane capture. DEP has got to get this right if Pennsylvania is to meaningfully reduce greenhouse gas emissions and tackle climate change as directed by Gov. Wolf in his executive order earlier this year.”DEP already had meetings with the Oil and Gas Technical Advisory Board on March 21 and a prior meeting with the Air Quality Technical Advisory Committee on December 13 to discuss the content of the regulation.After these initial reviews are completed, DEP will prepare the regulation to go before the Environmental Quality Board for consideration as a proposed regulation.*
Although the fact that the environuts don’t like the new regs gives us some solace, it’s not much solace. Because we think the new regs are not necessary and will end up costing the industry–for no appreciable result. Typical political “cure” to a disease that doesn’t exist.
The next stop along the way to implementing these onerous new regs is a Small Business Compliance Advisory Committee meeting next week. Stay tuned.
*PA Environment Digest Blog (Apr 12, 2019) – DEP Advisory Committee Recommends Moving Ahead With Reg To Control VOC/Methane Emissions From Existing Oil & Gas Operations
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