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Close the Loophole in PA DEP’s Proposed Rulemaking for Control of Methane and VOC Emissions from Oil and Natural Gas Operations

Pennsylvania is in the final stages of a new rule to reduce air pollution from existing oil and gas operations. This is a move in the right direction, but the rule has a serious loophole: it would allow more than half of methane pollution to go unchecked. Governor Wolf’s administration must act now to close this loophole.

As written, the proposed rule excludes all of the state’s low-producing oil and gas wells—and the pollution that comes with them. Any well that produces less than 15 barrels of oil per day is considered  “low-producing.” However, do not mistake low-producing for low-polluting. Studies have found that emissions from conventional wells – the vast majority of which are low-producing – can be disproportionately high relative to production. This loophole gives many operators a free pass to pollute and avoid common sense reforms that are critical to reducing methane emissions, protecting public health, and combating climate change.

In my work as an ITC-certified thermographer and field advocate with Earthworks, I got a taste for just how pervasive these emissions are in Pennsylvania communities. Last month, I took a trip to the Allegheny National Forest and surrounding towns with a state-of-the-art, independently verified optical gas imaging (OGI) camera capable of detecting volatile organic compounds, including known carcinogens, and greenhouse gases. What I found was public and private land littered with leaking, low-producing wells. While the emissions were invisible to the naked eye, they were clearly visible with my OGI camera, and their stench could be smelled throughout the region. The odor was a musty and distinctly artificial version of rotten eggs, and it interrupted the refreshing scent of pine trees nearly everywhere I encountered oil and gas equipment in the forest. Unfortunately, the smell of harmful pollutants leaking from these wells has become an unpleasant but familiar part of the landscape for residents.

 What’s so harmful about the pollutants seen in this video of leaking Pennsylvania gas wells?

Over the next two decades, methane will trap more than 80 times more heat than the same amount of carbon dioxide in the atmosphere. It is responsible for about a quarter of the global warming we are already experiencing, and the oil and gas industry is one of the largest sources of methane waste. 

Methane is the main component of natural gas, and it leaks from equipment across the entire oil and gas system. Leaks can occur any time and from any well. About 60% of the oil and gas produced in Pennsylvania from low-producing wells is extracted by just ten companies that earned from $5 million to $47.9 million in revenue last year. These companies can afford to inspect facilities for leaks and cut harmful pollution and slow the rate of warming. 

Instead, the oil and gas industry continues to wreak havoc in Pennsylvania, and strong state action is needed now more than ever. Oil and gas companies have already emitted over 1 million tons of methane into the air, endangering our climate and the health of more than 1.5 million Pennsylvanians. When methane escapes, so do other toxic chemicals including hydrogen sulfide, toluene, xylene, and benzene. People exposed to toxic air pollutants like these have a higher risk of developing cancer or experiencing other serious health impacts, including damage to the immune system, and neurological, reproductive, developmental, respiratory and other health problems. This pollution, and its resulting health impacts, can be prevented.

Recent studies also confirmed that the shale gas boom of the last decade has significantly worsened Pennsylvania’s’s air quality, while the industry’s emissions appear to be nearly 16 times higher than what operators report to the state.

Governor Wolf and Pennsylvania cannot achieve its climate goals without strengthening the proposed existing source rule. DEP should making the following improvements: 

  1. Close the loophole in the proposed rulemaking that exempts low-producing oil and gas wells from leak detection and repair (LDAR) requirements. Low-producing wells are responsible for more than half of the methane pollution from oil and gas sources in Pennsylvania, and all wells, regardless of production, need routine inspections.
  2. Eliminate the part of the draft rule that allows operators to reduce the frequency of inspections if previous inspections do not reveal significant methane leaks. Research shows that large, uncontrolled leaks are random and can only be detected with frequent and regular inspections.
  3. The rule should mirror requirements for air pollution sources that were covered in DEP’s standards for new oil and gas sources adopted in 2018.

Eliminating the low-producing well loophole and strengthening the oil and gas existing source air and methane pollution rule is necessary if Pennsylvania wants to follow through on its climate commitments. No polluter should get a free pass to harm our health and environment.  Pennsylvanians deserve a higher standard.