Jacob Schlesinger, Center for Methane Emissions Solutions
November 14, 2018
EPA Methane Rollback Hearing
Docket Identification Nos. [EPA-HQ-OAR-2017-0483, FRL-9984-38-OAR]
EPA Region 8 Office
1595 Wynkoop Street
Denver, Colorado 80202
Public Hearing Testimony
Hello, my name is Jacob Schlesinger and I’m from Denver, Colorado, representing the Center for Methane Emissions Solutions. Thank you for this opportunity to offer comment. The Center is 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.
We represent 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.
We are deeply disappointed that the Environmental Protection Agency is undergoing a rulemaking process to roll back common-sense standards to regulate methane emissions from oil and gas operations. These rules were developed with considerable input from industry and set an important signal to markets across the country that methane waste should be monitored and repaired.
In the United States, the oil and gas sector is the largest industrial source of methane emissions. These emissions represent a significant economic challenge: every year, America loses nearly $2 billion worth of methane due to inefficiencies at oil and gas well sites including faulty equipment and venting and flaring practices.
Responding to this market challenge, companies have developed effective, low-cost LDAR services and technologies that reduce wasteful methane emissions. Indeed, several firms provide LDAR surveys at well sites for as low as $250 dollars. While most American LDAR firms are small businesses the growing methane mitigation industry has created thousands of high-skill, high-pay, and geographically-diverse jobs that cannot be offshored.
Our support for the existing rule is supported by several factual premises. First, leaks are caused both by equipment failure and by operator error. In an exhaustive study of super-emitting leaks in the Barnett Shale region, the authors concluded that “equipment malfunctions and error-inducing workforce conditions are the most common causes of excess emissions related to avoidable operating conditions.”
This point is critical, because it demonstrates that monitoring based on the age or quality of the equipment, is not sufficient and that regular monitoring as the rule requires is necessary.
Another important point is that, once detected, it is almost always cost efficient for the producer to repair these leaks. In fact, in a study we conducted of oil and gas companies complying with Regulation 7 in Colorado, a stricter approach than the one we are discussing today, the respondents found, overwhelmingly, that by complying with the rule, they were either breaking even or saving money as a result.
I urge the Environmental Protection Agency to consider the views of CMES and, most importantly, our members, American small businesses that have a distinguished track record in working with oil and gas companies to devise common-sense solutions that address methane waste in an efficient manner. It is our view that the existing rule meets that threshold and urge the Administration to allow it to stand.