(WASHINGTON) As the public comment period for proposed oil and gas methane rules from the Environmental Protection Agency closes, significant public support alongside new data and cost-effectiveness analyses highlight the importance and feasibility of strong rules that comprehensively cut pollution from the oil and gas industry, including addressing pollution from smaller, leak-prone wells and ending routine flaring.
A diverse range of frontline and tribal community members, climate and public health advocates, and others from across the country submitted over 450,000 public comments to EPA in support of rules that fully safeguard public health and the climate. EDF, along with 17 other environmental and public health organizations, summited comments detailing the strong legal and scientific foundation for protective EPA standards.
“Hundreds of thousands of people from communities across the country support strong EPA rules to slash methane from oil and gas production,” said Jon Goldstein, senior director of regulatory & legislative affairs at EDF. “This proposal is an important step and both the public and the latest science are unequivocal that EPA will need to further strengthen it by tackling methane pollution from smaller, leak-prone wells and ending the practice of routine flaring to fully protect communities and our climate.”
- Download EDF comments here
Meanwhile, new data and analysis submitted along with the comments underscores the feasibility and cost effectiveness of protective standards EPA has proposed for equipment like pneumatic controllers and the importance of rigorous community-based monitoring solutions.
These analyses also show the critical importance of further strengthening the standards, including by identifying solutions to end routine flaring that are overwhelmingly cost-effective and the importance of extending emissions monitoring safeguards across well sites – including smaller, leak-prone ones (failure to do so could reduce the amount of fugitive methane pollution EPA rules could cut by up to 50%).
With fully comprehensive rules that include regular monitoring across facilities, EDF analysis finds EPA could reduce oil and gas methane pollution by nearly 7 million tons in 2026 alone.
Tackling smaller, leak-prone wells
EDF’s comments to EPA note the importance of final rules that address leak emissions from all wells – including smaller, leak-prone ones. Under EPA’s current proposal, operators of smaller leak-prone facilities with estimated emissions under 3 tons of methane per year would only be required to conduct a one-time inspection of their sites. EDF analysis finds that exempting these smaller sites from regular monitoring could reduce the amount of leaked methane cut by EPA’s rule by up to half.
“While EPA’s proposal is an important step, final rules must comprehensively address methane pollution from smaller, leak-prone wells,” said Rosalie Winn, EDF director and senior attorney. “We have a chance to make urgently-needed progress for public health and the climate, but can’t afford to let millions of tons of pollution go unchecked in the process.”
Smaller well sites like those EPA’s proposal would exempt have been shown to be major sources of pollution. Recent surveys from the Permian Basin found that one third of smaller well sites had large emissions that persisted for days, while the latest peer-reviewed science shows these sites to be outsized sources of methane and air pollution relative to the amount of oil and gas they produce.
Furthermore, an EDF analysis of U.S. Census Bureau data included in today’s comments reveals that these provisions must be strengthened to ensure all communities are protected from pollution. For instance, Native Americans live near wells at rates more than 30% higher than would be expected based on nationwide statistics (and almost 90% higher near new low-producing wells).
New analysis on solutions to end routine flaring
New analysis from Rystad, submitted as part of EDF’s comments to EPA, reveals that solutions to end routine flaring of associate gas at oil wells are not only broadly available, but overwhelmingly cost-effective to implement. These solutions can frequently turn a profit for operators who, in 2019, vented and flared approximately 1.48 billion cubic feet (bcf) per day of gas – enough to meet 25% of the country’s home heating needs for a year.
To curb the massive amounts of gas flared – and methane emitted in the process – EPA’s final rules should direct operators to capture and sell, productively use or reinject the gas, and the agency should prohibit venting and flaring except in case of emergency.
- Download Rystad analysis here
“Routine flaring is more than a blatant waste of resources. It’s a major driver of methane and air pollution that undercuts communities’ health and the stability of our climate,” said Goldstein. “This analysis makes clear that ending routine flaring is possible and even profitable, and that EPA has the opportunity to ensure solutions are deployed to stop needless waste and pollution.”
Finalizing critical solutions for pneumatics and community monitoring
EDF’s comments also urge EPA to finalize a community-based monitoring program, building from EPA’s proposal. EPA can ensure reported data submitted as part of such a program is accurate, that the program helps to empower communities to use different technologies and methods, and that technologies are used safely and properly. Such a program will foster public trust and accountability, while increasing knowledge on leaks and helping to further reduce emissions.
In addition, EPA’s proposal stands to deliver important progress on major pollution sources, such as pneumatic controllers – which are the industry’s second-largest source of methane pollution. As detailed in EDF’s comments, transitioning to zero-emitting alternatives cost-effectively cuts pollution.
“EPA has proposed landmark standards to transition away from intentionally-pollution equipment like pneumatic controllers,” added Winn. “It’s critical that the agency finalize protective standards to cut pollution from this equipment while delivering a final rule that that fully protects and empowers our communities while safeguarding our climate.”
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