In partnership with the Environmental Defense Fund (EDF), PEC submitted the attached comments to the Pennsylvania Department of Environmental Protection on their proposed rulemaking to control emissions of VOCs and Methane from existing natural gas operations and equipment.
Reducing methane emissions has long been a priority for PEC. With Pennsylvania being the second leading producer of natural gas in the country, and with natural gas continuing to displace coal in the electric generation sector, the control of methane emissions is of critical importance for addressing climate change and the reduction of greenhouse gas emissions.
A recent EDF analysis shows that Pennsylvania operators emit over 1 million tons of methane annually — 16 times what is currently reported — and underscores the considerable need for rules to properly address this climate and public health risk.
While EDF and PEC’s comments address a number of topics, the two central recommendations for improving the proposed rulemaking are:
- Closing a loophole that excludes low-producing wells, which account for more than half of Pennsylvania’s oil and gas-related methane emissions.
- Removing a step-down provision that allows operators to skip leak detection and repair inspections simply because previous checks did not reveal significant leaks. Research and experience show that large, uncontrolled leaks can happen at any time and can only be detected with frequent, regular inspections.
Strengthening the proposed rule is a win-win-win for consumers, businesses, and the environment. Because methane is the primary constituent of natural gas, capturing emissions and preventing leaks means that oil and gas companies can bring more saleable product to market. Solutions to cutting methane emissions are cost-effective, with the International Energy Agency reporting that, even in today’s low-cost environment, one-third of emissions can be reduced at no net cost.
On top of that, industry and business investors believe stronger controls on unwanted emissions is important and there are numerous businesses located here in Pennsylvania providing the technologies and services to reduce methane leakage.
The public comment period on the proposed rulemaking is now closed. Consistent with the state’s Regulatory Review Act, the Department of Environmental Protection will review public comments and make changes to the proposed rule, with publication of the rule as final in 2021.
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