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.
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.
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.
