Testimony on Proposed RACT for Existing Natural Gas Facilities
Air Quality Technical Advisory Council Meeting

December 13, 2018

By Isaac Brown, Executive Director, Center for Methane Emissions Solutions

Good morning and thank you for the opportunity to provide comments on proposed regulations for existing natural gas facilities in Pennsylvania. My name is Isaac Brown and I am the Executive Director of Center for Methane Emissions Solutions (CMES), a national coalition that represents the views of companies in the methane mitigation industry in the United States, specifically in the leak detection and repair (LDAR) space.

The methane mitigation industry is a robust and growing American industry. 130 companies have headquarters in the U.S., and there are approximately 570 methane mitigation facilities located across the country. These facilities are manufacturing plants, assembly facilities, service centers, service provider offices, and administrative offices.

CMES represents a range of companies within the industry and was founded to provide a voice for American businesses that develop and deliver innovative solutions to significantly cut methane waste on a cost-effective basis across the oil and gas supply chain.

Pennsylvania is the second-largest natural gas producer in the United States. Unfortunately, alongside that development comes the needless waste of Pennsylvania’s natural gas resources through leaky equipment and infrastructure and the deliberate release of methane. Industry-reported data shows that methane emissions from unconventional natural gas development is over 115,000 tons per year – enough energy to power 49,000 homes for one month.

Fortunately, these emissions can be addressed quickly and effectively and at a low cost. There’s a burgeoning job market in Pennsylvania focused on reducing methane emissions – nearly 40 businesses and rising – generating millions in revenue for the state’s economy.

We appreciate the thoughtful, deliberative approach, Governor Wolf and his Administration have undertaken to address methane waste in a practical manner. The rules we are discussing today represent an important step forward, to address pollution from existing natural gas sources in Pennsylvania. The current policy for existing sources in the state, Exemption 38, leaves many sources uncovered and does not constitute leading control technology for many others.

In reviewing the proposal there are opportunities to further enhance the rule to achieve the Governor’s stated goal of reducing harmful pollution and reducing waste for businesses. They are:

1. Explicitly apply each control to both VOCs and Methane;
2. Eliminate the variable frequency provision in the leak detection and repair (LDAR) section while retaining the quarterly inspection provision;
3. Amend the definition of Fugitive Emissions Components to include intermittent vent controllers;
4. Require that an alternative method must achieve equivalent emissions reductions as the required OGI or M21 devices;
5. Include methane controls for existing liquid unloading, glycol dehydrators, and pigging operations;

Implementing these proposed changes would have positive outcomes for Pennsylvania. Similar standards have already been instituted, successfully, in other states, including Colorado, where studies show that oil and gas development is increasing, all while harmful methane waste is being reduced. We expect similar success here and appreciate the opportunity to provide these comments.