In December, the Pennsylvania Dept. of Environmental Protection (DEP) released a draft of onerous new regulations that focus on reducing volatile organic compound (VOC) emissions and so-called fugitive methane (see Pa. DEP Jumps the Gun with Proposed New Emissions Regs). The new regs will force drillers and pipeline companies to spend big bucks to produce a teeny tiny improvement in emissions. The DEP is back, once again pushing its bad plan.
Here’s the thing that really rankles us: Most of PA’s conventional wells (80% or more) will be exempt from these new rules. And PA’s conventional wells reportedly account for more than 50% of supposed methane emissions. There are approximately 80,000 active conventional oil and gas wells in PA, and about 10,600 active shale gas wells in PA. So how are these rules in any sense “fair” to the shale industry?
The DEP has, for some time, considered requiring new regulations to further reduce volatile organic compound (VOC) emissions at existing oil and gas sites. The question is, since the federal EPA is “relaxing” the regulations on which these onerous new PA regulations are based, will PA, by adopting these new regulations, make itself uncompetitive against other shale drilling states? PA DEP Sec. Pat McDonnell seems to think so.
McDonnell opposed the EPA’s move to change the extreme overregulation of the Obama era, because it means other states (like Texas, Louisiana, Oklahoma) won’t adopt crazy new regulations like those PA is about to adopt, disadvantaging PA against those other states. Libs always want to see misery distributed equally, which they prefer to do via federal regulation.
The Marcellus Shale Coalition said last December, “Rather than creating more regulatory uncertainty [with these new regs at this time], it would be prudent for DEP to delay any regulatory proposals until federal rules are finalized,” pointing out the fact that federal rules are not yet finalized. Wolf’s DEP is jumping the gun.
Makes no difference. The DEP is hellbent for leather to get this done, even if it hurts the shale industry and is unnecessary. The DEP’s Oil and Gas Technical Advisory Board (TAB) is meeting a week from today to “discuss” (i.e. try to ram through) these new regs.
On March 21, DEP’s Oil and Gas Technical Advisory Board is scheduled to meet to discuss draft proposed RACT regulations covering volatile organic compound emissions with a “co-benefit” of reducing methane emissions from existing oil and gas operations.
In December, DEP discussed its proposed approach to the regulation with the Air Quality Technical Advisory Committee outlining many of the same points it plans to make in the March 21 presentation.
The approach used in the regulation is based on a federal Control Technique Guideline for oil and gas facilities which will be used to develop a RACT standard. RACT is defined as the lowest emission limitation that a particular source is capable of meeting with economically feasible, reasonably available emissions control technology.
DEP acknowledged at the Air Quality Advisory Committee meeting EPA is now considering changes to its CTG requirement, but said they intend to move ahead with a proposed rule in any event because of regional commitments to meet federal ozone standards.
While the draft regulation technically proposes to regulate VOC emissions, these controls will in turn reduce methane emissions because both volatile organic compounds and methane are found in many oil and gas operations.
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.
At the Air Quality meeting, 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.
These estimates are rough because DEP staff said they have not yet done firm calculations to estimate how many wells may be exempt.
There are now about 80,000 conventional oil and gas wells and about 10,651 active unconventional gas wells in Pennsylvania.
A report by the Environmental Defense Fund in February of 2018 on methane emissions from oil and gas wells in Pennsylvania found about 50 percent of those emissions come from conventional oil and gas wells (268,900 tons) and about 50 percent from unconventional gas wells (253,500 tons).
The higher conventional gas well methane emissions cannot be accounted for by natural gas production.
In fact, conventional gas wells account for only about 5 percent of natural gas production in the state, while 95 percent of the production comes from unconventional (shale) gas wells.
Another difference in the way conventional gas wells are treated is in reporting methane emissions. Conventional oil and gas wells are not required to report their methane emissions to DEP, while unconventional wells are, even though they make up about half the methane emissions.
Marcellus Shale Coalition President David Spigelmyer issued a statement in December about the draft regulation saying, “While we’re still reviewing the proposal, we do have initial concerns about potential costs as well as DEP’s timing given ongoing federal regulatory activity associated with existing source emissions.
“That said, Pennsylvania’s continued success in enhancing air quality, as reflected by DEP’s own data, is occurring alongside and largely due to the Commonwealth’s leading natural gas production position. Again, rather than creating more regulatory uncertainty, it would be prudent for DEP to delay any regulatory proposals until federal rules are finalized.”*
A copy of the draft regs released last November:
*PA Environment Digest Blog (Mar 14, 2019) – DEP To Discuss Draft Regs Controlling VOC [Methane] Emissions From Existing Oil & Gas Operations At March 21 Advisory Board Meeting
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