January 31, 2022
FILED ELECTRONICALLY
RE: Comments on EPA’s Proposed Standards of Performance for New, Reconstructed and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review
Docket ID No. EPA-HQ-OAR-2021-0317
Thank you for the opportunity to present comments related to the Environmental Protection Agency’s proposed rule to limit methane emissions at oil and gas operation sites.
CMES is a national business coalition that represents the views of companies in the methane mitigation industry across the United States. The methane mitigation industry is a robust and growing American industry. More than 130 companies have headquarters in the U.S., and there are more than 570 methane mitigation facilities located across the country, in 46 states.
We appreciate the Administration’s careful consideration of this issue. In addition to the real environmental costs associated with these emissions, there is also a tremendous economic cost. Methane is the primary component of natural gas. Oil and gas operations lose millions dollars-worth of product each year due to methane emissions from inefficiencies at oil and gas well sites. If those issues were addressed, it would mean more product could be brought to market and more revenue for companies and for the state.
Fortunately, this is a problem with a clear solution. Responding to this market concern, our member companies have developed a range of effective, innovative, and low-cost services and technologies that reduce wasteful methane emissions. But you don’t have to take our word for it. In their March 2020 report entitled “Global methane emissions from oil and gas”, the International Energy Agency found that “While natural gas prices today are relatively low, we estimate that around one-third of our latest estimate of methane emissions from oil and gas operations could still be avoided at no net cost.” These results reflect our experience in a diverse range of states including Colorado, New Mexico, and Pennsylvania, all of whom have either implemented or are close to finalizing proposals like the one under consideration in this rulemaking.
As a result, EPA need not make a difficult choice between protecting public health and supporting the economy. In reviewing this initial proposal, it is our view that some critical changes should be made to ensure that the policy we are considering strikes this important balance:
Revise Camera Operator Criteria
The proposal sets a qualification threshold for a Senior OGI Camera Operator to be someone who has attended “at least 20 sites in the past 12 months…” We appreciate the intended goal of this provision. For this policy to succeed, highly trained technicians are critical. However, our members experience in the field confirms that using a site-based calculation, as suggested, is a mistake because sites, and the complexity involved in surveying them, can vary widely. Depending on the factors involved, our members advise that an inspection can take anywhere from 30 minutes to nearly 24 hours. As a result, we encourage EPA to adopt a standard that considers hours of service, rather than sites inspected. Montrose Environmental Group puts forth a proposal of 160 hours in their comment, and our organization thinks that is appropriate.
Miscalculates LDAR Costs
As the leading organization of methane mitigation companies in the United States, CMES is uniquely suited to convey to the Administration an accurate accounting of the true costs associated with implementing an OGI LDAR program. In reviewing the proposal, it is our view that EPA has miscalculated. For example, EPA has significantly increased cost estimates of “annual recordkeeping database maintenance and license fee” and “additional recordkeeping/data management costs.” According to assumptions provided to the Agency, EPA suggests that costs associated with record keeping is responsible for an increase of $700 in monitoring costs since 2020. We are pleased to convey that these assumptions are inaccurate. Many methane mitigation service providers offer such services as part of their contract. Separate contracts for such services are highly unusual. Further, one nationally recognized member of our organization provides recordkeeping to its customers as part of their standard agreement and estimates the cost at about $50. We encourage EPA to revise this estimate because record keeping is likely already included in service contracts, and that readily available technology makes such a task cost-effective.
Minimum Detection Level for New Technologies
Our organization believes that it is vital that the resulting rulemaking encourages innovation. Technology provides clearest pathway to sustainability in the oil and gas industry. Likewise, it is also important to provide clear standards for the adoption of such methods. Therefore, we appreciate that EPA includes a proposed minimum detection level for the adoption of new technologies. The proposal sets the level at 10kg/hour which is 96 tons/year. We are very concerned by this threshold, as our experience in the field indicates that if implemented more than many leaks (more than 90 percent of all leaks) would be missed. We believe a gap of this size is unnecessary and EPA should consider revising it.
Again, we want to thank EPA for the opportunity to comment on this proposal. The Center for Methane Emissions and its member stand prepared to provide solutions that will help our oil and gas partners address methane waste in a cost-effective manner.
Isaac Brown
Executive Director
Center for Methane Emissions Solutions