On Friday, Nov. 11, the U.S. Environmental Protection Agency took an important step toward protecting public health and reducing greenhouse gas emissions that contribute to climate change by strengthening proposed rules that will reduce wasteful methane emissions from the oil and gas industry.
If enacted, these common-sense rules would be the first action by the EPA to regulate methane emissions from the thousands of existing oil and gas wells in Wyoming, not just future development. The rules are expected to promote new cost-effective technologies to prevent waste, and make natural gas more competitive as consumers demand cleaner sources of energy.
The announcement of new measures to cut methane and other harmful pollutants from oil and gas operations is welcome news, and builds off of Wyoming’s own successes in reducing harmful emissions and will limit wasted methane from leak-prone equipment.
The updated proposal would require routine and cost-effective monitoring of well sites, encourage the development and use of new leak detection technologies, and set higher standards for flaring — a practice by which methane is burned as a waste product rather than captured and sold.
The Wyoming Outdoor Council sees these rules as essential to spurring future innovation around leak detection and repair and to creating a level playing field for methane regulation across the oil and gas industry. We’re encouraged by the efforts to address routine flaring, and hope that the final rule fully eliminates this wasteful practice.
Methane emissions from human activities are responsible for about 30 percent of global warming since the industrial revolution.
The case for cutting methane emissions
Methane regulation is supported widely by leading industry and conservation groups. Many oil and gas operators, including major Wyoming producers like Jonah Energy and Purewest Energy, are already working to reduce sources of wasted methane as consumers demand cleaner sources of energy.
The Inflation Reduction Act, which passed into law in August 2022, set aside roughly $1.5 billion to help operators to comply with new methane emissions rules.
Capturing methane is very cost effective. In many cases wasted natural gas can be captured and sold, paying for most, if not all, of the additional work needed to capture it. Recent data from the International Energy Agency suggest that up to 45 percent of wasted methane emissions can be prevented at no net cost.
Reducing methane leaks saves taxpayer dollars and stewards valuable resources for the future. In 2018, the Wyoming Outdoor Council and its partners estimated that between $51 million and $96 million of methane was vented and flared annually in Wyoming. This translated to $9-16 million lost in annual royalty payments to the state.
Reducing methane emissions from oil and gas production is widely regarded by scientists and policy makers as a critical first step to mitigate the worst impacts of climate change in the future. Methane is a powerful greenhouse gas responsible for about 30 percent of global warming since the industrial revolution. However, methane also leaves the atmosphere quickly compared to other greenhouse gases like carbon dioxide. Reducing wasted methane emissions now is one of the best opportunities to buy time to implement other climate solutions.
Reducing methane emissions has significant air quality and human health benefits. The same leak detection and repair practices used to reduce methane will also reduce harmful air pollutants such as volatile organic compounds (VOCs) that cause respiratory damage and contribute to poor air quality.
Most policy experts agree that, along the long road to combating climate change and reducing greenhouse gas emissions, reducing wasted methane from oil and gas operations is “low-hanging fruit.”
In 2020 alone, wasted methane gas from oil and gas operations made up roughly one-third of all methane emissions from human activity. The obvious need to address this problem is why there are two proposed regulatory changes involving methane that could have major impacts on lowering greenhouse gas emissions from our country’s oil and gas sector. The rules — one from the Environmental Protection Agency and the other from the Bureau of Land Management — would seek to reduce methane waste, and their success is important for Wyoming’s environment and taxpayers alike.
Methane is the second-most significant greenhouse gas in terms of impact on global warming. It is responsible for approximately a quarter of the Earth’s warming since the Industrial Revolution and, when compared to carbon dioxide, it has roughly 80 times the global warming potential over a 20-year period (International Energy Agency). However, despite how methane’s potency, it cycles out of the atmosphere much quicker than carbon dioxide: This means methane emission reductions now can help lower greenhouse gas concentrations and buy time to make the necessary societal changes we need to achieve net zero emissions over the coming decades.
But putting aside the many climate and environmental benefits of reducing wasted methane, it also just makes sense as a cost-effective policy solution. Wasted methane, after all, is essentially natural gas that can be captured and brought to market. As a quick comparison, in 2019 alone, oil and gas operators wasted enough methane from venting and flaring (common ways operators manage methane waste) to power 2.1 million U.S. homes (Environmental Defense Fund).
In fact, the International Energy Agency estimates nearly 50 percent of wasted methane can be captured with no net cost to producers (IEA). This is because investments made in reducing methane emissions pay for themselves over the long term by keeping more natural gas in route to energy consumers and out of the atmosphere.
Which brings us to the new EPA and BLM methane rules — federal efforts the Wyoming Outdoor Council supports to help curb this wasteful practice. Last November, the EPA released new draft rules that would regulate wasted methane emissions for both new and existing sources for the first time. (Historically, in most cases, methane has only been regulated from “new and modified” emissions sources, and older “existing sources” of wasted methane have largely been left alone). The EPA rules would apply under the authority of the Clean Air Act, treating methane as an air pollutant. Importantly, the rules would regulate methane emissions from oil and gas facilities across all jurisdictions and land ownerships (including private, federal, and tribal lands) and, if they go into effect, could dramatically cut emissions and uniformly raise the bar for responsible energy development. The EPA’s rules are widely supported by both environmental and industry groups alike, because they are good for the environment, create an equal playing field for businesses by setting uniform standards, and establish regulatory certainty under which companies can predictably operate and plan.
Separately, the Department of the Interior is also considering a BLM methane waste rule that would apply more narrowly to oil and gas production on federal and tribal lands. The BLM’s rules take their authority from the waste prevention mandate in the Mineral Leasing Act of 1920. This mandate allows the Secretary of the Interior to “use all reasonable precautions to prevent waste of oil or gas developed on the land.” In states like Wyoming, where the majority of oil and gas development occurs on public lands, the application of this rule could help the public realize higher returns on the development of natural resources by charging royalties for wasted natural gas.
In 2018, the Outdoor Council estimated that Wyoming lost as much as $96 million worth of natural gas in a single year due to intentional flaring, venting, and careless leaks. This translates into roughly $16.1 million lost in annual royalty payments to the state. These are critical revenue streams that taxpayers and budget-strapped Wyoming communities deserve to see for the depletion of natural resources (WOC Oil and Gas Waste Report). And of course, the rule would provide further incentive for producers to keep methane in the pipeline and out of the atmosphere.
Both the BLM’s authority under its waste prevention mandate and the EPA’s authority under the Clean Air Act to regulate air pollutants are needed to address climate concerns and ensure that Wyomingites receive a fair value for the one-time use of their non-renewable resources. While some leading companies like Jonah Energy, Occidental, and Devon Energy are taking action to cut methane and support federal methane regulation, that simply isn’t enough. Most oil and gas operators are not doing frequent, thorough inspections for leaks and we need stronger state leadership to support these common sense federal rules that will benefit our environment and our pocketbooks.
Looking forward, both the EPA and BLM rules have procedural and administrative hurdles to clear before they go into effect, hopefully later this year. Our commitment is to continue tracking and advocating strong methane rules as well as keeping you informed of the opportunities to get these policies over the finish line in 2022. The long-term outlook of Wyoming’s climate, budget and residents depends on it.
Advocating for conservation in Wyoming is demanding work, both for the Wyoming Outdoor Council’s staff and for passionate members like you. Not only are there more issues than we can possibly address as a small organization in a geographically large state, but for people with big hearts and a love for the wild, open spaces of Wyoming, the outcomes are personal.
We don’t always win. When we do find success, as frequent as it may be, it’s often in the form of a quiet victory or incremental change. The forces working against us — whether it’s government inertia or downright hostile opposition from other stakeholders — can often feel overwhelming.
But we aren’t in this alone. After all, we have each other.
Poll after poll shows that the vast majority of our fellow Wyomingites — even if they don’t consider themselves “conservationists” — value public lands, wide open spaces, wildlife, clean air, and clean water. Our challenge is to meet people where they are and attempt to find common ground. The more we make these connections, value multiple perspectives, and seek input from a diversity of people outside of our organization in Wyoming and beyond, the more likely we are to succeed in our mission.
However difficult it may be, an honest and respectful conversation with a person who disagrees with our position does more good than assuming we have all the answers.
Everything we hope to accomplish depends on relationships. Wyoming is a state where a small group of thoughtful, committed citizens can seek creative solutions to tough problems and make a difference. And, as you’ll read in the coming pages, positive things can happen when a group of people with diverse perspectives put their heads together around an issue of mutual concern instead of staying in their own camps.
Everything we hope to accomplish depends on relationships. Wyoming is a state where a small group of thoughtful, committed citizens can seek creative solutions to tough problems and make a difference.
Thank you for being part of the Outdoor Council community in 2022. I take comfort in knowing, despite the obstacles and the slow pace of change, we’re all in this together. I hope you’ll remember that as well.
How do we make sure the coming boom in renewable energy isn’t a bust for our wildlife and public lands?
This story, like much of the good work that happens in Lander, began as a meeting over coffee at the Lander Bake Shop. Staff from several conservation groups, including the Wyoming Outdoor Council, had gathered to look at GPS tracking collar data from pronghorn around Sweetwater Solar, Wyoming’s first large-scale solar project on public land.
The map of the pronghorn’s movement was infuriating — the 700-acre solar development had been placed right in the middle of crucial winter habitat. Fences surrounding the project had funneled many of the animals onto Highway 372 north of the city of Green River, creating hazards for both wildlife and drivers. The impacts of the Sweetwater Solar project on pronghorn were completely predictable and avoidable. But aside from a brief Environmental Assessment required by the Bureau of Land Management, there was little in the existing permitting process to direct the developers to a better location where wildlife conflicts could have been avoided.
What became clear in that meeting and in subsequent discussions was that the Sweetwater Solar project was likely a harbinger of what’s to come in the next decade as the cost of developing solar and wind energy continues to fall dramatically.
The expected boom in renewable energy puts advocates for conservation in Wyoming in a challenging spot. We understand the dire importance of transitioning to cleaner energy sources, and at the same time recognize the significant development footprint that utility-scale renewables can have on Wyoming’s wildlife and open spaces. The question and dilemma on many of our minds is this: How does Wyoming decarbonize its electricity production while not sacrificing the crucial wildlife habitat and open space that make it so unique?
As with many of the challenges our state faces, there is no silver bullet to solve this problem, but common sense and science both tell us that focusing our efforts on responsible siting and permitting processes for renewables is the logical place to start. That’s exactly what WOC tried to do with its effort to jumpstart the Wyoming Renewable Energy Siting Collaborative.
As with many of the challenges our state faces, there is no silver bullet to solve this problem, but common sense and science both tell us that focusing our efforts on responsible siting and permitting processes for renewables is the logical place to start.
After the 2020 legislative session, WOC started reaching out to stakeholders around the state to understand the perception of renewable energy and ways we might be able to improve our siting and permitting policies. We worked closely with faculty at the University of Wyoming to convene a group of policy thinkers representing conservation, industry, local government, landowners, and independent consultants to explore opportunities for the state to improve how renewable energy is sited.
During 2021 this group met nine times over Zoom to discuss issues related to renewable energy in Wyoming, including tax policy, federal and state revenue sharing, transmission development, supply chain manufacturing, and other topics. The group also learned from and consulted with experts from the Wyoming Industrial Siting Division, the Wyoming Game and Fish Department, and the Wyoming Wildlife and Natural Resource Trust. The group’s final recommendations were published in November 2021 and can be found on UW’s Ruckelshaus Institute website.
These recommendations are a start. They form an important foundation for future policy and advocacy work, especially as our country moves to decarbonize electricity production and accelerate the growth of renewables. They also show that industry and conservation can work together to agree on important concepts moving forward.
Some of the most important points of agreement in these recommendations address the need for more proactive planning for renewable development on public lands, the need for early and frequent consultation with the Wyoming Game and Fish Department to avoid wildlife conflicts, and the need to evaluate previously disturbed locations as places to site renewable energy. There is also strong agreement on the importance of public transparency and engagement as projects move forward so impacted citizens and communities have opportunities for meaningful input on project proposals.
We know that more wind and solar energy is on the horizon, and the development of these resources will present historic challenges and opportunities for Wyoming. But as with all development, we must insist that this growth be done on our terms — in a responsible and measured way — that does not degrade and diminish the very things clean energy is supposed to protect. Holding that line will require leadership at the state level. It will also take collaborative efforts like the one that played out last year at the University of Wyoming — with the full spectrum of experts and advocates coming together with a shared goal of making sure future development is sited appropriately. We’ve already seen the impacts on wildlife when things go wrong. But done right, renewable energy development could be an asset, not a liability, to Wyoming’s environment and quality of life.
HOW UNSEEN EMISSIONS CONTINUE TO IMPAIR AIR QUALITY IN WYOMING’S UPPER GREEN RIVER BASIN
Whether you ranch, farm, hunt, fish, or ski, there is a season for most things in Wyoming. But there are some seasons that we could do without. Topping that list is “winter ozone season” in the Upper Green River Basin of Sublette County.
For nearly two decades, the Wyoming Outdoor Council and Pinedale-based Citizens United for Responsible Energy Development (CURED) have been actively working to improve winter ozone conditions in this region, which is home to the state’s largest natural gas fields. This seasonal phenomenon typically occurs when the right combination of weather patterns, surface reflectivity from snow and ice, and emissions like nitrogen oxides and volatile organic compounds (known as VOCs) all combine to create ozone molecules. When the ground-level ozone concentration exceeds 70 parts per billion, it can have harmful respiratory effects and cause lung damage in people who breathe the polluted air.
While there have been some modest improvements in the region’s air quality since development in the basin started, the basic fact remains that the UGRB, which once boasted some of the cleanest air in the country, remains dangerously close to violating the Clean Air Act’s standards for ozone. The consequences of this violation could be significant not only for the people living, working, and breathing in Sublette County, but for the industry operators who would likely see new regulations to bring the region back into compliance with air quality standards.
The UGRB, which once boasted some of the cleanest air in the country, remains dangerously close to violating the Clean Air Act’s standards for ozone.
To better understand why this area continues its seasonal struggle with high ozone levels, the Outdoor Council teamed up with CURED and a trained thermographer from Earthworks, a community-based advocacy organization, to visit the Upper Green in November 2020 and inspect roughly a dozen oil and gas sites on the Jonah and Pinedale Anticline fields. Our goal was simple: to document examples of permitted emissions from oil and gas facilities on public lands and consider what appropriate next steps regulators can take to continue improving this region’s air quality.
Engine stack emissions from the Enterprise Products’ Bridger Compressor Station are an obvious example of a “major source” facility permitted under the Clean Air Act. This footage shows the stark contrast between what an observer can see with the naked eye versus through the lens of specialized infrared camera equipment. (Infrared video footage by Earthworks, Nov. 19, 2020.)
Almost all of the sites our team visited had some detectable levels of fugitive emissions — none of which would have been visible without the use of a state of the art forward-looking infrared camera. These FLIR cameras, which individually cost as much as a high end sports car, provide a glimpse of the otherwise invisible emissions occurring across the Jonah and Pinedale Anticline oil and gas fields.
As part of their operating permits, companies are typically allowed to emit certain levels of pollutants into the atmosphere. Sometimes emissions are vented and released intentionally, while other times they are accidental and the result of old or leaky equipment that needs to be updated or repaired. Both contribute to poor air quality and the region’s ozone season.
Natural gas producers operate thousands of facilities in Wyoming’s Upper Green River Basin. These facilities collectively leak or vent thousands of tons of methane and VOCs each year.
Fugitive emissions seen on Jonah Energy LLC’s Stud Horse Butte Tanks #10-28. The basin’s windy conditions can make it more difficult to see the gas plumes leaking from infrastructure in the UGRB. The region’s poorest air quality is typically on calm days during inversions when concentrations of pollutants build up. (Infrared video footage by Earthworks, Nov. 19, 2020.)
One routine and permitted practice in the Upper Green that contributes to the region’s wintertime ozone problems is when oil and gas wells are intentionally “blown down” to clear them of debris and sludge that accumulates over time. Blowdown tanks are often used to hold the residual fluids and gases that are expelled during these events, but this process frequently results in large volumes of fugitive gasses and VOCs escaping into the atmosphere. During a two-month period in the winter of 2020, Jonah Energy reported 1,008 blowdown events totaling over 159 hours of uncontrolled emissions venting. Dozens of other production companies operate in the region and, collectively, blowdowns result in hundreds of thousands of dollars in wasted gas annually and thousands of tons of vented methane and VOCs.
Emissions venting from tanks at Ultra Resource’s Stud Horse Butte Tanks #7-21. (Infrared video footage by Earthworks, Nov. 19, 2020.)
Emissions from leaking equipment or intentional venting can combine to create ground-level ozone, which can cause respiratory problems and lung damage.
When added up across the landscape, blowdown events and other forms of permitted emissions have the potential to play a big role in the seasonally unhealthy air that impacts the Upper Green. In our day in the field, we were able to document these emissions coming from blowdown tanks, combustor units, and dehydrators. It’s not hard to imagine what that impact could be when multiplied by the thousands of permitted facilities currently operating in the basin.
A leaking tank at Pinedale Energy Partners’ Mesa #1 well. Oil and gas companies operate thousands of facilities in the Upper Green River Basin. (Infrared video footage by Earthworks, Nov. 19, 2020.)
Pinedale Energy Partners’ Mesa well #3-17 shows blowdown tanks that are badly venting emissions. The harmful gasses being released into the atmosphere could be controlled by flaring which would turn these emissions into less harmful ones like carbon dioxide and water vapor. (Infrared video footage by Earthworks, Nov. 19, 2020.)
If the oil and gas industry is going to continue to serve Wyoming as it has historically, it needs to adapt and change to meet the expectations of mostly out-of-state consumers who are increasingly holding energy production to higher environmental and social standards. Based upon our own field observations, a good starting point for Wyoming regulators would be to reduce, and ultimately end, the common practice of using uncontrolled blowdown tanks to vent emissions from oil and gas operations. These emission sources and others should be minimized by being routed to combustors, and more work is needed to reduce the amount of wasted gas that is vented into the atmosphere. While blowdowns are just one of many emissions sources that need to be addressed by operators and regulatory agencies, this would protect public health and air quality. It would also be in the best interest of the industry in the long term.
We look forward to a future trip to the UGRB where the only things to see through a FLIR camera would be the silhouettes of mountains and clouds. But for that future to become a reality, there is still clear work to be done. With states like New Mexico and Colorado taking strong steps to clamp down on uncontrolled venting and set high standards for leak detection and repair, Wyoming’s operators should be following suit to address growing concerns over fugitive emissions, air pollution, and climate change.
A change in federal administrations — and the policies that follow — is cause for either excitement or anxiety depending on how you voted. And for good reason: Elections have consequences. National policies affect our health, our economy, and our environment. And in Wyoming, where nearly half of the land is managed by the federal government, national policies have a disproportionate impact.
Members of the Wyoming Outdoor Council fall all along the political spectrum. We agree to disagree on many issues, but find common ground when it comes to conservation. Conservation is not — and should not be — a partisan issue.
From the standpoint of conservation and environmental justice, the legacy of the outgoing administration is dire. From climate change denial and the loosening of air and water quality safeguards to oil and gas leasing in areas important to Indigenous people and in crucial wildlife habitats, there have been more than 100 documented rollbacks to existing protections or short-sighted policies that threaten public health and our air, water, wildlife, and lands.
Many of the administrative wins we celebrated over the last decade were among those rolled back. The fate of others — like the Bureau of Land Management’s methane waste prevention rule — remains uncertain as challenges are still working their way through the courts. And while there are some rules that the incoming administration will be able to restore and it will certainly abandon some public land policies like “energy dominance,” we’ve lost important ground.
To be sure, the Outdoor Council looks forward to an incoming administration that is less hostile to our mission. At the same time, we are wary of ambitious campaign goals that don’t take Wyoming values into account. For example, in the urgency to transition away from fossil fuels, proposals for industrial-scale wind and solar development on public lands in Wyoming shouldn’t be rushed. Development should be encouraged in already disturbed areas so that, in our effort to mitigate climate impacts, we don’t harm intact habitat and our most cherished open spaces and public lands.
And we’ll be careful not to rely too heavily on federal policy for solutions to the specific challenges we face in Wyoming. We don’t relish what has come to feel like a game of administrative ping-pong.
Instead, what we strive for — regardless of who occupies the White House — are common-sense conservation initiatives and environmental policies that endure. Although incremental progress isn’t as newsworthy as sweeping change, we’re playing a long game. We’d much rather build on measured steps forward than have fleeting successes that can’t withstand the next election.
What we strive for — regardless of who occupies the White House — are common-sense conservation initiatives and environmental policies that endure.
Assuming they work as promised, we support state-level initiatives. Past examples include rules for detecting and fixing methane leaks in new and modified oil and gas fields and requiring baseline water testing before oil and gas drilling. We’ve also supported executive orders for sage-grouse conservation and big game migration corridors, although we continue to scrutinize their implementation.
And when we advocate for big policy solutions with the power to deliver conservation wins, we also champion strong public processes. We’re dedicated to empowering citizens in local communities to help craft lasting solutions. In the coming year we’ll build on the groundwork we laid in 2020 to seek consensus recommendations for large-scale renewable energy siting, support community-led climate change resolutions like the one recently adopted in Lander, and work with Tribal partners and other citizens toward permanent protection for parts of the incredible Northern Red Desert.
Our approach to conservation keeps us grounded in Wyoming. This doesn’t mean that we are always successful. There are frequent setbacks, but it’s this approach that accounts for the conservation gains we’ve celebrated over the last 54 years. With your support, I’m confident we’ll continue this progress — not just in the coming year or coming four years, but for the long haul.
On Wednesday, July 15, we received some good news.
In a series of challenges that have been ongoing for nearly four years, a federal district court in California found that the Bureau of Land Management illegally repealed a 2016 rule designed to improve air quality, slow the progress of climate change, and provide a fair return for taxpayers by reducing the amount of natural gas lost through leaks, venting, and flaring from oil and gas development on public and tribal lands.
The BLM’s 2016 methane waste prevention rule updated 30-year-old regulations regarding the agency’s congressional mandate to prevent waste of publicly owned oil and gas resources. This common-sense and much needed update protects our public lands, air quality, and our health by requiring oil and gas companies to conduct inspections and repair leaks that endanger human health and contribute to climate change. Because the pollution captured is also the product to be sold, these inspections and fixes end up paying for themselves. The rule helps ensure that natural gas owned by the American taxpayers generates revenue for our schools, public infrastructure, and social services, instead of literally being cast to the wind.
But oil and gas industry groups — as well as Wyoming, Montana, and North Dakota — challenged the rule. The Wyoming Outdoor Council joined 17 public health, Indigenous rights, and conservation organizations, along with New Mexico and California, to help the BLM defend the rule in Wyoming federal district court.
When President Donald Trump was elected, the BLM changed course. At industry’s urging, the BLM first sought to not enforce the rule and then took steps to repeal it altogether. We soon found ourselves on the other side of the courtroom as plaintiffs challenging the BLM’s 2018 “rescission rule.” The court’s decision on Wednesday means that the 2016 rule will be reinstated.
While industry lobbying groups will likely challenge the 2016 rule — and we’ll be back in Wyoming district court to defend the rule again — the decision to reinstate it represents a huge victory for common-sense management of a valuable public resource. Notably, during the legal limbo of the past four years, more and more oil and gas companies have voluntarily adopted the requirements of the rule — because they’re cost effective and good PR for an industry under scrutiny for its contributions to climate change.
More than $2.5 billion in natural gas has been lost to venting, flaring, or fugitive emissions on public and tribal lands since 2013. This loss also contributes to climate change — methane is a greenhouse gas and a serious contributor to global warming — and releases pollutants such as benzene into the air.
As a 53-year old organization, the Wyoming Outdoor Council learned long ago not to rely exclusively on federal administrative rules for lasting policy change. This is a textbook example of why we don’t. The shifting politics of Washington D.C. mean any victories gained under one administration could be on the chopping block during the next.
For this reason, even while we sought to defend the BLM’s national rule, we worked tirelessly with the state of Wyoming, the Department of Environmental Quality, and operators here in Wyoming to ensure state-level standards for leak detection and repair of fugitive emissions. In 2018, the DEQ finalized these requirements and they apply statewide in new and modified oil and gas fields. Ultimately, we’d like the state to require the same practices for existing oil and gas fields.
Our work to combat climate change, protect public health, and support policies that reduce unnecessary lost revenue for the state of Wyoming will continue and we’ll keep you posted on our progress.
The winter of 2019 was a bad season for ozone pollution in the Upper Green River Basin, particularly near Boulder where monitoring stations recorded nine days in which ozone levels exceeded federal standards.
Winter ozone is not new for this region, but increasing concentrations over the last several years have called into question whether the regulations governing fugitive emissions from oil and gas operations — and our clean air — need tightening. This was the context that led members of the local Pinedale advocacy group Citizens United for Responsible Energy Development and the Wyoming Outdoor Council to tour the Jonah and Pinedale Anticline natural gas fields with Wyoming’s Department of Environmental Quality. Our goal was to better understand current operations — and learn what state regulators are doing in response to last season’s unhealthy ozone conditions.
CURED member Jana Weber looks at the emissions from a combustor through a flare camera. These cameras can cost more than $100,000 and are used to quickly identify emission leaks.
As one might expect, there’s a lot to see in the state’s largest natural gas field. Our group visited facilities owned by the three major energy companies in the area: Pinedale Energy, Ultra Energy, and Jonah Energy. We examined lake tanks, pig launchers, combusters, disposal facilities, production units, and dehydrators with state-of-the-art flare cameras used to detect leaking emissions from a distance. Looking into these cameras is like looking under a microscope where the invisible world of gasses and heat is revealed in ghostly detail. Technological advances like this are essential for quickly identifying leaks and monitoring emissions and are a key component of what’s known as Leak Detection and Repair.
New technologies might make inspections easier and more efficient, but it remains a daunting task over such a large area. Currently, the Upper Green River Basin has more than 8,000 permitted facilities and only two full-time DEQ air quality inspectors. Even with each inspector performing hundreds of inspections annually, the vast majority of these facilities will go uninspected each year.
Fortunately, DEQ has ways of prioritizing the most important inspections based upon factors like the facility’s previous violations, its potential for emissions, and when it was last inspected. With low compliance rates a lingering concern and priority, it was also refreshing to learn that inspectors took enforcement actions against several operators this summer for permit violations.
Touring the Jonah and Pinedale Anticline fields was a reminder of the good work and intentions of our state’s Department of Environmental Quality in the Upper Green River Basin. But, while we were pleased with what we saw, the bar for whether or not current efforts are enough will be determined by the ozone levels we see in future winters. We’re encouraged that the DEQ seems to be taking last year’s violations seriously and has set ambitious goals for engine monitoring and working to bring on a third air quality inspector in the basin this winter. However, funding for the department’s two current full-time inspectors will need to be added to the DEQ’s budget next year, due to the elimination of the federal contribution for this work.
We have to make sure that DEQ has the resources it needs to prioritize inspections and improve compliance rates to achieve better air quality in the Upper Green. You can be sure that the Outdoor Council will be advocating for this at the 2020 legislative session in Cheyenne.
The DEQ’s annual pre-season ozone meeting is slated for November 18 at the Boulder Community Center in Boulder, WY. Outdoor Council staff and CURED members will be in attendance. More information can be found here.
The Outdoor Council is asking the state to implement best practices in oil and gas fields that would save the state and counties millions of dollars by curbing intentional flaring and venting, and unintentional leaks of natural gas.
The Wyoming Natural Gas Waste Report, compiled by the Outdoor Council and the Environmental Defense Fund, finds that the state is missing out on an estimated $8.8 million to $16.1 million each year in unrealized tax revenue due to wasted natural gas. Of that statewide loss, $3.4 million to $6.5 million is uncollected ad valorem revenue — property tax that goes directly to counties. That money could have gone to the purchase of emergency equipment, or road and bridge repair, or human services like nurses and libraries.
The top five counties missing out on the most ad valorem dollars associated with wasted gas in 2015 were Converse, Goshen, Campbell, Laramie and Sweetwater. The total lost in ad valorem for those counties in 2015 was $2.8 million with an average of $560,000 per county.
The Wyoming Department of Environmental Quality has already successfully implemented — in one corner of the state — operational protocols that reduce the need for flaring and venting, as well as leak detection and repair (LDAR) requirements. This program, implemented in the Jonah and Pinedale Anticline gas fields in the Upper Green River Basin, is a proven cost savings to Sublette County as well as the operators themselves.
“Sublette County is not on the list of missing out on ad valorem dollars due to wasted gas,” said Elaine Crumpley, of Citizens United for Responsible Energy Development (CURED). “That is because oil and gas field operators in the Upper Green River Basin, basically Sublette County, have already been doing flareless completions and LDAR inspections for several years.”
It’s urgent that Wyoming expands this successful program to oil and gas fields statewide, because the industry is preparing for a major increase in drilling. Projects such as the 5,000-well Converse County Oil & Gas Project and the 1,500-well Greater Crossbow field may be approved for drilling as soon as 2019.
“Addressing this problem is common sense: reducing waste means increasing revenue. Clean air and public health are added bonuses,” Outdoor Council Executive Director Lisa McGee said. “The state can and should take action to require oil and gas operators in eastern Wyoming to implement frequent leak detection and repair inspections as they have successfully done in western Wyoming.”
The state needs to live up to its responsibilities to protect its clean air and to collect all revenue that is due to its citizens and communities that desperately need it. Insisting on methods that reduce flaring and venting, and protocols that detect and fix gas leaks is a proven win-win-win for Wyoming communities, oil and gas operators, and the environment.
“Our operators pioneered all these gas-waste management methods, and our gas fields are flourishing, with 11 rigs drilling today,” Crumpley said of the Upper Green River Basin fields. “From our experienced perspective, the rest of the state should follow our lead. It’s a major step in the right direction.”
Last week, a U.S. district court reinstated a commonsense rule to prevent the waste of natural gas on public lands. The court found the Trump administration’s attempt to suspend the rule without the required public input violated the law. The Outdoor Council was a party to this suit, and we’re happy to report that the Bureau of Land Management’s methane waste prevention rule is back in place—at least for now. The rule requires oil and gas companies to inspect and fix leaky, faulty equipment, and to operate in ways that reduce waste of our finite natural resources.
Unfortunately, the Trump administration’s attack on this rule is just one example of many attempted environmental rollbacks in recent weeks. Whether it’s scrapping the EPA’s Clean Power Plan, ending the moratorium on federal coal leasing, throwing out the BLM’s land management planning rule and its sage-grouse habitat protection measures, or failing to enforce rules that prevent the waste of natural gas, this administration’s agenda is clear: prioritizing fossil fuel development above all other values.
There’s good news, though. Regardless of this administration’s goals, our local, national, and global energy markets are going in the opposite direction. More and more companies are making decisions every day that are good for both the environment and their bottom lines.
Take ExxonMobil, the largest oil and gas producer in the United States. Just last month it announced a plan to voluntarily enhance its leak detection and repair protocols at its new and existing wells. In 2014, 10 leading gas companies formed the ONE Future Coalition to identify best practices for curbing methane leaks from natural gas infrastructure. And in Wyoming, companies like Jonah Energy have established leak detection and repair protocols that go far beyond what is required by the state and federal governments.These decisions are good for air quality and people’s health, and they are also good for the companies’ profits. The capture of fugitive methane gas—which, when leaked into the atmosphere, is a potent greenhouse gas pollutant—means more gas is kept in the pipeline as a marketable product. These are wise business decisions as these protocols often pay for themselves.
Even as we successfully defend the good rules and regulations put in place by the prior administration, the Wyoming Outdoor Council is also thinking ahead. We realize that political swings at the federal level create tremendous uncertainty, and ultimately delay progress to ensure clean air. That’s why we’re committed to a multi-year effort to urge Wyoming’s Department of Environmental Quality to expand leak detection and repair requirements to the entire state. Durable state-level pollution controls—coupled with the efforts of companies to “do it right”—means more responsible energy development, cleaner air, and healthier communities.
