American Oil and Gas Reporter - June 2016 - 39

that whether this definition applies now
will depend on exactly how each state or
local agency has adopted the Title V and
prevention of significant deterioration
rules and definitions into their state implementation plans. Some states have delegated authority and incorporate definitions
and rules by reference-for example, if the
federal rule changes, their rules automatically change-but other states do not, in
which case they will need to start the administrative process to change their rules
in their respective state implementation
plans. The latter group leaves open the
possibility that some states may deliberately opt not to adopt these definitions and
continue business as usual."
Existing Sources
Although the final rules apply to new
sources, the ICR for emissions data from
existing sources seems to be associated
with an early March agreement between
U.S. President Barack Obama and Canadian Prime Minister Justin Trudeau (see
"Initiative Aimed At Stopping Oil &
Gas," AOGR, April 2016, pg. 31).
"Clearly it did with regard to the
pace," Fuller suggests. "Right after the
Trudeau summit, EPA announced its intention to develop a national existingsource regulatory system, the first piece of
which would be the information collection
request.
"Our conversations with EPA suggest
(the agency) has a great deal to learn about
the breadth, scope and nature of the industry," he continues. "It may well have
written a very different ICR if it had more
time. It might have benefitted from utilizing existing, publicly-available information such as state permits before asking industry to provide what is essentially identical information. Instead, I suspect pressures from the White House to move
quickly . . . were driven directly by the
meeting with Canada."
As with OOOOa, Reeves emphasizes
that EPA wants plenty of information.
"There is going to be some pretty heavy
lifting on the paperwork from the ICR,"
she says. "A lot of data will have to be collected that operators likely will not have
already. One thing that leapt out at me was
component counts."
Ulterior Motive
Ultimately, a number of industry advocates suggest, the methane rules are more
about suppressing an industry than one of
its minor emissions. Fuller notes that
many who portray the "methane pollution"
associated with oil and gas operations as
a crisis fail to mention that the industry accounts for only 30 percent of such emissions. "Agriculture and landfills are each

within a couple percentage points of upstream oil and gas," he observes. "If EPA
has any programs over them at all, they are
voluntary. A lot of the dynamic is driven
at oil and gas production by the intensity
of the environmental community to shift
the debate from managing the emissions
to 'keeping it in the ground.'"
Similarly, Heartland Institute environment and energy policy research fellow H.
Sterling Burnett says, "Nothing good
comes from these new rules, which are unnecessary and counterproductive-unless
the true aim is not to protect human
health, but rather further restrict fossil fuel
use in the inane effort to control the climate. Even the EPA acknowledges natural sources-or other sources, such as
livestock or landfills-account for the vast
majority of methane emissions, not natural gas production or transport. Despite a
tremendous increase in natural gas since
1990 because of the fracturing revolution,
methane emissions in the United States
have fallen. That is because natural gas
producers and pipeline operators already
have a financial incentive to capture every
bit of it they can and not lose it to leaks.
As a result, less than 1.5 percent of all natural gas produced is lost."
Ultimately, suggests Texas Independent Producers & Royalty Owners Association President Ed Longanecker, the regulation is unwarranted and will hamper an
industry that is helping the United States
trim its GHG emissions. "Even with the
significant rise in oil and natural gas production, methane emissions have fallen,
thanks to ongoing innovation and improvements in exploration and production
methods," he points out.
He continues, "EPA's own data show
methane emissions from hydraulically
fractured gas wells have fallen 79 percent
since 2005. The rapid deployment of hydraulic fracturing and horizontal drilling
technologies is a key reason for the reduction in GHG emissions in the United
States. Further, between 2006 and 2014,
61.4 percent of carbon dioxide emission
reductions in the U.S. electric power sector came from fuel shifting toward natural gas. Onerous and unnecessary regulations only cause more strain on our economy, and increased expense to consumers
and the companies that employ American
workers, with little or no true environmental benefit."
❒

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