Industry Weighs in on EPA Proposed Methane Regulations
Methane Targeted by EPA
In late 2021 the U.S. Environmental Protection Agency (EPA) proposed comprehensive rules targeting methane emissions in the O&G industry. A growing body of research indicates that methane is not only one of the most powerful climate pollutants, but also that its short-term potency makes cutting methane the best way to reduce warming quickly. Research also shows that the oil and gas industry, which is responsible for 25% of global human-made methane emissions, offers the most affordable reduction opportunities.
The EPA’s public comment period recently closed with hundreds of thousands of individual submissions received from the public, environmental groups, industry, and industry associations. With all of these comments, we started to wonder how industry feels about the proposed methane rules. To find out, we reviewed 35 comments from U.S. producers and industry groups.*
*Comments available for public viewing can be accessed at Regulations.gov
O&G Companies Weigh In
Comments from integrated oil and gas companies, independent producers, and producer trade organizations indicated a high level of consensus on the importance of methane emissions reduction to reduce global warming, and highlighted significant achievements already made and the important role of emerging technologies.
Although most responders agreed with the need for federal regulations, a majority expressed concern with costs and logistics associated with the proposed fugitive leak detection requirements which rely upon legacy Optical Gas Imaging (OGI) technology. The effect of the requirements on economics of mature production was repeatedly brought up, as well as the resources required to fulfil the quality assurance and administrative aspects of the OGI surveys, as proposed in the regulations.
New Ways to Monitor
A significant number of responders provided further comments on the role of emerging Alternative Leak Detection and Repair (Alt-LDAR) technologies, which could provide equivalent reductions in methane emissions with lower costs and higher efficiencies. Emerging technologies include satellite, aircraft, drones, or ground-based mobile surveying, as well as fixed continuous monitoring (CM) systems.
Many responses advocated for a matrixed approach to the regulations, recognizing that equivalent or higher net methane reduction can be achieved using various technologies with differing minimum detection limit (MDL) capabilities and employed at varying frequencies. Several responders noted the synergistic effect of combined technologies to be able to detect larger leaks quickly.
Continuous Measurement
Several responders further highlighted the merits of CM systems as part of an effective and efficient fugitive management system. The American Petroleum Institute wrote “the framework should also support the use of continuous monitoring technologies. Continuous monitoring technologies can detect large leaks in real-time. API members see great promise in continuous/near-continuous methane monitoring technologies and encourage EPA to work with stakeholders to develop a framework that allows for usage of such technologies.”
BP America stated that “owners and operators should have the ability to choose technologies and approaches that when combined in complementary ways result in robust and cost-effective methane emission reductions. These types of innovative technologies may include fixed wing aerial surveys, drone aerial surveys, satellites and various continuous monitoring solutions.”
They added that “with technology for methane leak detection evolving at a rapid pace, and major strides being made in methane measurement and quantification, a flexible approach is paramount to capture these advancements and shift towards increased use of continuous site level measurement systems,” and further spoke of “the fundamental paradigm shift represented by, and the significant methane leak detection and mitigation potential of, continuous monitoring.”
Devon Energy said “the benefits of continuous or near-continuous methane detection technologies are clear. These technologies provide for the quickest potential detection and mitigation of significant emission events.”
Leading the Way
Qube Technologies has worked with many of the producers that submitted feedback to the EPA, and offers the first Continuous Monitoring technology to be regulatory approved. Qube believes the best solution can be achieved when industry, associations and regulators work together to create effective regulations. Qube provides regulatory approved, low cost, and robust continuous monitoring solutions enhanced by artificial intelligence technology to effectively enhance LDAR programs. We have the solutions today to lead organizations on the path to reducing methane emissions and maintaining regulatory compliance.