In the words of the great mid-20th century philosopher, Yogi Berra, "It's like déjà vu all over again." To me it truly seems like déjà vu all over again as on September 29, 2015, I gave similar testimony at the William S. Moorhead Federal Building in Pittsburgh, PA in support of what was then the New Source Performance Standard for Methane.
Since then, it’s been six long years of leaking methane continuing to spew; six more years of toxic air threatening the life and health our unborn children, children in general, pregnant women, and in fact all of us; and six more years of a greenhouse gas 86-times more potent than CO2 in the first twenty years, the associated VOC’s, and additional cancer-causing chemicals accumulating at higher and higher levels in our air.
During the past six years, one of my most fervent prayers, taken directly from the Bible has been:
How long will you defend the unjust
and show partiality to the wicked?
Defend the weak and the fatherless;
uphold the cause of the poor and the oppressed.
Rescue the weak and the needy;
deliver them from the hand of the wicked. – Psalm 89:2-4 (NIV)
Clearly oil/gas companies may not be wicked. In fact leading oil/gas corporations and organizations like Shell, Equinor, BP, EQT, Jonah Energy, Equitrans Midstream, and the Interstate Natural Gas Association of America all support methane leak standards. However, many firms and trade associations have put profit over defending the lives and health of our children. It’s time to put our children first and especially for United States Environmental Protection Agency (EPA) to live up to its mission to Protect Human Health and The Environment.
Now is time to fix these leaks that spew dangerous pollution at a rate most likely 60% greater than current EPA estimates. We must go beyond a New Source Standard and implement a new rule for both an existing and new sources that reduces methane levels by at least 65% below 2012 levels and addresses the complete production, transportation, and distribution systems for gas industry.
As pro-life evangelicals, we have a special concern for the unborn. We want children to be born healthy and unhindered by the ravages of pollution even before they take their first breath. The medical community has long known pollution and other environmental impacts harm our unborn children, and we know that fossil fuels are the most serious threat to children’s health worldwide. It was once thought expectant mothers provide a shield of protection to their developing unborn child by filtering out pollutants – medical research repeatedly shows that this is untrue. Studies show that smog, VOCs, and air toxics have a disproportionate impact upon life in the womb. Research by Dr. Shaina L. Stacy and others at the University of Pittsburgh found evidence that the low birth weights in babies in Butler County, PA is associated with how close their families live to unconventional gas wells. Dr. Lisa M. McKenzie with the Colorado School of Public Health published peer-reviewed research linking birth defects to methane production. Casey J.A., et al further find that simply living within a half-mile radius of natural gas development leads to increased brain, spine, or spinal cord birth defects in children. This isn’t a small or isolated problem - 2.9 million children attend a school located within with 0.5 miles of an oil/gas facility and 12.6 million Americans households are also withing that radius. Over 85% of the medical studies that have studied the gas industry’s impact on health find that that emissions from oil and gas facilities and infrastructure is highly detrimental to the health of both children and adults – this includes heart failure, asthma, and the exposure to known carcinogens.
The Evangelical Environmental Network strongly recommends that any promulgated methane standard address all leaks and fugitive emissions and include the following measures:
Frequent Leak Detection and Repair (LDAR). Leak detection programs can be used to find and fix everything from simple leaking components, such as valves, to super-emitters – the infrequent but exceptionally large emission events that arise from some improper conditions at oil and gas sites. Super-emitters can be caused by valves and hatches that are stuck open, flares that are blown out, or many other types of abnormal operating conditions at a site.
Replacement of gas-driven pneumatic equipment. Traditionally, oil and gas operations in North America have relied heavily upon automated equipment which uses pressurized natural gas to pump liquids or open and shut valves. This was particularly convenient at isolated sites which did not have electric power from the grid available. Since the equipment is using the pressure of the gas to do work, it is designed to release the gas into the air as it operates. Across the industry, pneumatic equipment emits a huge amount of methane pollution – over two million metric tons per year.
Reducing venting from storage tanks. At most oil production well sites, oil is separated from gas and collected in tanks, where it is stored until it is trucked away. During this process, the oil releases methane and other pollutants dissolved in it; without controls to limit emissions, these pollutants are released into the air. These emissions can be controlled by capturing the methane and other hydrocarbon pollutants and using specialized compressors to inject the hydrocarbons into the natural gas pipelines at the wellsites. Alternatively, if this approach is not workable, gas can be incinerated (flared), largely preventing release of methane. Since incinerators emit CO2 and other pollutants, and they waste the energy contained in the gas that they destroy, incineration is clearly not as good a choice as capturing gas, but it is far better than venting the gas.
Minimizing emissions from well completions. When oil and gas wells are hydraulically fractured, large volumes of water, sand, and chemicals are pumped into the well at high pressure, fracturing the rocks holding the oil and gas. The next step is to allow this liquid to flow back to the surface. However, the liquid is mixed with significant amounts of natural gas, which was typically vented to the atmosphere before states and U.S. EPA put in place rules requiring operators to control emissions of this gas by capturing it or flaring it. These rules have reduced emissions, but the rules give industry a great deal of flexibility in the way they are applied, and there is reason to believe industry is abusing this flexibility in some cases. Future regulations should ensure that operators diligently apply emissions controls to truly minimize emissions. Measurements have confirmed when operators carefully work to limit emissions from well completions, emissions will be quite low – almost 99% below EPA’s current estimate of emissions per completion.
Compressors and dehydrators. In general, this equipment is designed to release some of the methane and hydrocarbons it handles. Compressors vent gas that passes through seals for moving parts (which are not designed to be hermetic) and dehydrators release methane and other hydrocarbon pollutants as they vent the water vapor that they remove from natural gas. These emission points can be effectively controlled, and rules in several jurisdictions require operators to do so, for many compressors and certain dehydrators. However, EPA’s nationwide standards exempt thousands of older compressors and only cover larger dehydrators at a limited number of large sites.
Reducing venting and flaring of gas from oil wells. As oil production has boomed in the Permian Basin in Texas and New Mexico and in the Bakken formation in North Dakota, wells have been drilled and completed so rapidly that the gas these wells co-produce overwhelms the pipelines and other infrastructure needed to handle and transport it. In some cases, new oil wells are drilled without any gas infrastructure. And many regulators allow oil producers to simply flare off this gas, rather than requiring operators to plan oil development so that gas infrastructure keeps pace with well drilling or use alternative approaches when pipelines are not available.
The U.S., together with many other countries, has committed to cutting routine flaring by 2030, and many international oil producers have endorsed this pledge.24 In order to meet that goal, federal regulations will be needed. An interim goal will be important to ensure near-term progress to eliminate flaring; an 80% reduction in flaring emissions is a proper interim target for 2025
Reducing venting during maintenance operations. Natural gas operators routinely vent wells and equipment before performing maintenance work. Wells are vented primarily to make it quicker and easier to get water out of wells in a process referred to as “wellbore liquids unloading”. Numerous technologies and management practices have been found to reduce, or eliminate, emissions from this practice. We recommend clear guidelines and performance standards be developed to insure maximum reductions and benefits.
The Evangelical Environmental Network and our community have always supported strong standards to defend our children and their health. In closing, I would like to share the words of 92,000 prolife Christians primarily from Pennsylvania, Colorado, and New Mexico to the EPA back in 2015. Their request states:
As pro-life Christians, we want the air that we breathe to be safe for our children. Leaks in our natural gas infrastructure spew out toxic pollutants, cancer-causing agents and climate pollution that place God's creation and our families - especially children, pregnant mothers, and the unborn - in harm's way. That's why we call on The Environmental Protection Agency and all our policy makers to support strong regulations to cut this pollution from both new and existing leaks from our natural gas infrastructure. Our children deserve nothing less.
There will be industry groups here today and at other hearings yelling foul at another EPA regulation. They say voluntary guidelines are enough. For the responsible firms that is probably true. However standards are not enacted for the good players, but the poor reformers.
Research states that approximately 80% of the natural gas leaks result from just 30% of the facilities. That suggests that many producers already see the value in minimizing leaks and production losses. Escaping natural gas can’t make a profit, but it can be extremely toxic and of immeasurable value to our children’s health.
However, it also indicates that lower cost operators without proper care or without sound capitalization operate on the margins. While being sympathetic to the small business person, the current threats to children’s health demand proper accountability. Supporting a new standard creates, in effect, a police force to insure our kids’ health.
If we care for our children, now and in the future, let’s work together to develop a strong methane standard to protect all of God’s creation.
