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Authors: Raphael Breit & Nadia Steinzor

In the last few years, some states have tried to get serious about climate change by setting pollution reduction goals in line with international agreements. But these goals were designed using an incomplete picture of statewide greenhouse gas (GHG) emissions levels. Unfortunately, just because emissions aren’t tracked doesn’t make them harmless.

The logical outcome of this situation is that states are likely undercounting their GHGs and underestimating the scope of the problem. 

In fact, without a full accounting of GHGs, it is impossible to know how much pollution is actually harming communities and the environment, accurately measure progress on state or federal climate plans, or develop emissions reduction policies that reflect the realities on the ground and the true impact of polluters.

Most troubling of all, even though current emission reduction plans are based on lower levels of pollution than actually exist, many states such as Colorado and New Mexico are already on track to miss the mark on their climate targets.


Fuzzy data

Studies on oil and gas industry pollution increasingly demonstrate that undercounting and not comprehensively measuring GHGs are persistent problems. As the New York Times recently reported, even cities are undercounting their GHG emissions.

Studies on oil and gas industry pollution increasingly demonstrate that undercounting and not comprehensively measuring GHGs are persistent problems.

A closer look at how programs to track emissions work reveals several problems that help explain this shortcoming. Until these problems are addressed, many emissions sources will continue to be ignored, reporting will remain inconsistent, and most if not all emissions inventories will likely continue to undercount GHGs.

Since 2010, federal standards require that certain larger facilities report their annual emissions to the EPA through the Greenhouse Gas Reporting Program (GHGRP). Some states have also created their own emissions tracking programs, on which regulators rely to track whether polluters are complying with their permits and air quality and climate policies are making a difference.

But there are several problems with this approach. 

  • The first is that these reporting programs track self-reported industry data based on mathematical calculations and engineering calculations that assume equipment is functioning perfectly–something that Earthworks’ extensive field investigations of oil and gas operations show isn’t the case and may even lead to low-balling projected emissions to avoid certain regulatory requirements. 
  • The second problem is that many emissions sources are exempt from reporting their emissions. Most of these tend to be smaller sources such as individual well pad or compressor stations whose annual emissions do not exceed 25,000 metric tons of carbon dioxide equivalent (CO2e) per year. But thousands of small polluters add up to create a big problem – a large but unknown volume of pollution is released every year without being tracked.
  • The third problem is that not all greenhouse gases are tracked. The GHGRP tracks all GHGs, including methane. But some state inventories do not track methane, and others, such as Ohio’s State Emissions Inventory System (EIS) only track the criteria pollutants related to overall air quality and do not track greenhouse gases at all.
  • The fourth problem is the lack of consistent reporting guidelines. Every reporting program has its own emissions estimation methodology and reporting criteria, meaning that an oil and gas facility could use one calculation method to report to EPA and another to report to a state program, resulting in two different numbers. This makes it difficult for the public and policymakers to know which data are most accurate.

Earthworks encountered this problem when comparing the GHGRP to Pennsylvania’s oil and gas inventory. Even when comparing data for the same facilities in the same years, Earthworks discovered massive discrepancies and inconsistencies in reported numbers to EPA and the state.

Despite being trained researchers, there was no way for us to determine what the actual estimated emissions were–a situation that would be even more frustrating for a resident being harmed by pollution from a nearby well site or facility.


Attempts to bridge the gap

In recent years there have been a few attempts, mostly in the Texas Permian, to provide high-level looks at methane emissions, and quantify the gap between measured and estimated emissions without relying on industry self-reported numbers. NASA tracks methane emissions at major facilities, including those in the oil and gas industry.

The Environmental Defense Fund (EDF) has tracked greenhouse gas emissions using a combination of flyover observations and ground monitoring stations in their Permian Methane Analysis Project. EDF is also involved in the methane satellite project, MethaneSAT, scheduled to launch in 2022. EDF claims that their findings suggest that Permian companies emit nearly three times more methane than EPA estimates.

The New Mexico Environment Department (NMED) is currently conducting helicopter flyovers of the Permian Basin with EPA to measure oil and gas methane emissions. NMED recorded an increase in methane leaks from 2019 to 2020, and admitted that the voluntary emissions reductions measures undertaken by some operators are not enough to reduce methane emissions on their own.

At the end of the day, there is no substitute for accurate, comprehensive statewide emissions tracking programs.

These projects have provided a hint as to the real scale of the emissions problem and the gap between how much pollution operators create versus report. But they are not able to provide the type of data needed to track emissions from specific facilities. At the end of the day, there is no substitute for accurate, comprehensive statewide emissions tracking programs. 

This is why Earthworks has recommended that states must expand the scope of their emissions tracking programs to cover all GHGs, have regulatory agencies conduct direct site-level emissions monitoring to confirm that industry-submitted emissions estimates are correct, and make all data publicly available. 

Until then, the haphazard systems currently in place will continue to fail the states that rely on them by hampering their ability to achieve climate goals. We’ll talk more about how–and why it matters–in our next blog post on how the oil and gas production gap is showing up in key US states.