Statement from Center for Methane Emissions Solutions Executive Director Isaac Brown
Regarding Comments Submitted in Opposition to BLM’s Proposed Revision of the Methane Rule
April 23rd, 2018
Today, the Center for Methane Emissions Solutions (CMES), a business coalition representing companies in the methane mitigation industry in the United States, specifically in the leak detection and repair (LDAR) space, submitted public comments opposing BLM’s proposal to revise the methane rule.
CMES is disappointed by BLM’s decision revise the methane waste prevention rule and opposes the proposal set forth by the Trump Administration. As an active participant in the 2016 rulemaking process, CMES can attest to the fact that the guidelines were promulgated with considerable input from industry and devised reasonably achievable compliance requirements on industry.
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. 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.
CMES’s support for the underlying rule is reinforced 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.