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CUTTING METHANE POLLUTION: SAFEGUARDING HEALTH, CREATING JOBS, AND PROTECTING OUR CLIMATE

Summary

The record of "Cutting Methane Pollution: Safeguarding Health, Creating Jobs, and Protecting Our Climate," a hearing of the House Select Committee on the Climate Crisis held June 24, 2022, Serial No. 117–20. Chair Kathy Castor of Florida calls methane the second-largest source of heat-trapping pollution and says the hearing is part two of a series on cutting methane pollution from oil and gas infrastructure. She cites a House Science Committee majority staff report finding that oil and gas companies routinely fail to address super-emitting leaks. Ranking Member Garret Graves of Louisiana also gives an opening statement. The witnesses are Patrice Tomcik of Moms Clean Air Force, Dr. Robert L. Kleinberg of the Columbia University Center on Global Energy Policy, Dr. Caroline Alden of LongPath Technologies and Sarah Ann Smith of the Clean Air Task Force.

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“CUTTING METHANE POLLUTION: SAFEGUARDING HEALTH, CREATING JOBS, AND PROTECTING OUR CLIMATE.” Original at www.govinfo.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/cutting-methane-pollution-safeguarding-health-creating-jobs-and-protec-7da9323a92/, SHA-256 702ad6346dbb0cf3f7fdb146e8e8ee92129250ae71557974e35b41ca9be4dd42.

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                                                                                           CUTTING METHANE POLLUTION:
                                                                                       SAFEGUARDING HEALTH, CREATING JOBS,
                                                                                           AND PROTECTING OUR CLIMATE



                                                                                                                  HEARING
                                                                                                                         BEFORE THE


                                                                                             SELECT COMMITTEE ON THE
                                                                                                  CLIMATE CRISIS
                                                                                             HOUSE OF REPRESENTATIVES
                                                                                                ONE HUNDRED SEVENTEENTH CONGRESS
                                                                                                                       SECOND SESSION


                                                                                                                       HEARING HELD
                                                                                                                        JUNE 24, 2022



                                                                                                             Serial No. 117–20




                                                                                                                            (

                                                                                                                 www.govinfo.gov
                                                                                        Printed for the use of the Select Committee on the Climate Crisis

                                                                                                           U.S. GOVERNMENT PUBLISHING OFFICE
                                                                                    48–849                             WASHINGTON : 2022




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                                                                                                  SELECT COMMITTEE ON THE CLIMATE CRISIS

                                                                                                           ONE HUNDRED SEVENTEENTH CONGRESS
                                                                                                       KATHY CASTOR, Florida, Chair
                                                                              SUZANNE BONAMICI, Oregon             GARRET GRAVES, Louisiana,
                                                                              JULIA BROWNLEY, California             Ranking Member
                                                                              JARED HUFFMAN, California            GARY PALMER, Alabama
                                                                              A. DONALD MCEACHIN, Virginia         BUDDY CARTER, Georgia
                                                                              MIKE LEVIN, California               CAROL MILLER, West Virginia
                                                                              SEAN CASTEN, Illinois                KELLY ARMSTRONG, North Dakota
                                                                              JOE NEGUSE, Colorado                 DAN CRENSHAW, Texas
                                                                              VERONICA ESCOBAR, Texas              ANTHONY GONZALEZ, Ohio


                                                                                                           ANA UNRUH COHEN, Majority Staff Director
                                                                                                           SARAH JORGENSON, Minority Staff Director
                                                                                                                   climatecrisis.house.gov




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                                                                                                                             CONTENTS

                                                                                                         STATEMENTS OF MEMBERS OF CONGRESS
                                                                                                                                                                                                           Page
                                                                              Hon. Kathy Castor, a Representative in Congress from the State of Florida,
                                                                               and Chair, Select Committee on the Climate Crisis:
                                                                                  Opening Statement ...........................................................................................              1
                                                                                  Prepared Statement .........................................................................................               3
                                                                              Hon. Garret Graves, a Representative in Congress from the State of Lou-
                                                                               isiana, and Ranking Member, Select Committee on the Climate Crisis:
                                                                                  Opening Statement ...........................................................................................              4

                                                                                                                                     WITNESSES
                                                                              Patrice Tomcik, Senior National Field Manager, Moms Clean Air Force
                                                                                  Oral Statement .................................................................................................           6
                                                                                  Prepared Statement .........................................................................................               8
                                                                              Dr. Robert L. Kleinberg, Senior Research Scholar, Columbia University Cen-
                                                                                ter on Global Energy Policy
                                                                                  Oral Statement .................................................................................................           9
                                                                                  Prepared Statement .........................................................................................              11
                                                                              Dr. Caroline Alden, Co-Founder and Vice President of Product and Markets,
                                                                                LongPath Technologies
                                                                                  Oral Statement .................................................................................................          19
                                                                                  Prepared Statement .........................................................................................              21
                                                                              Sarah Ann Smith, Chief of Programs, Clean Air Task Force
                                                                                  Oral Statement .................................................................................................          26
                                                                                  Prepared Statement .........................................................................................              28

                                                                                                                  SUBMISSIONS FOR THE RECORD
                                                                              A June 23, 2022 letter from energy companies to President Biden, submitted
                                                                                for the record by Mr. Graves ...............................................................................                56
                                                                              A June 24, 2022 letter from AXPC to the Select Committee on the Climate
                                                                                Crisis, submitted for the record by Mr. Graves .................................................                            56
                                                                              A June 22, 2022 letter from the Evangelical Environmental Network to
                                                                                the Select Committee on the Climate Crisis, submitted for the record by
                                                                                Ms. Castor .............................................................................................................    58
                                                                              A June 22, 2022 letter from the Environmental Defense Fund to the Select
                                                                                Committee on the Climate Crisis’ Chair Kathy Castor, submitted for the
                                                                                record by Ms. Castor ............................................................................................           62
                                                                              A June 24, 2022 letter from Clarke Valve to the Select Committee on the
                                                                                Climate Crisis, submitted for the record by Ms. Castor ...................................                                  64

                                                                                                                                      APPENDIX
                                                                              Questions for the Record from Hon. Kathy Castor to Patrice Tomcik ................                                            67
                                                                              Questions for the Record from Hon. Kathy Castor to Dr. Robert Kleinberg ......                                                70
                                                                              Questions for the Record from Hon. Kathy Castor to Dr. Caroline Alden ..........                                              75
                                                                              Questions for the Record from Hon. Kathy Castor to Sarah Ann Smith ............                                               75




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                                                                                       CUTTING METHANE POLLUTION:
                                                                                   SAFEGUARDING HEALTH, CREATING JOBS,
                                                                                       AND PROTECTING OUR CLIMATE

                                                                                                               FRIDAY, JUNE 24, 2022

                                                                                                            HOUSE OF REPRESENTATIVES,
                                                                                                 SELECT COMMITTEE ON THE CLIMATE CRISIS,
                                                                                                                                Washington, DC.
                                                                                 The committee met, pursuant to call, at 9:02 a.m., in Room 210,
                                                                              Cannon House Office Building, Hon. Kathy Castor [Chairwoman of
                                                                              the committee] presiding.
                                                                                 Present: Representatives Castor, Bonamici, Brownley, Huffman,
                                                                              Levin, Graves, Palmer, Carter, Miller, Armstrong, Crenshaw, and
                                                                              Gonzalez.
                                                                                 Ms. CASTOR. The committee will come to order.
                                                                                 Without objection, the Chair is authorized to declare a recess of
                                                                              the committee at any time.
                                                                                 As a reminder, members participating in a hearing remotely
                                                                              should be visible on camera throughout the hearing. For members
                                                                              participating in person, masks are optional, per the Office of the
                                                                              Attending Physician.
                                                                                 As with in-person meetings, members are responsible for control-
                                                                              ling their own microphones. Members can be muted by staff only
                                                                              to avoid inadvertent background noise.
                                                                                 As a reminder, statements, documents, or motions must be submit-
                                                                              ted to the electronic repository, to SCCC.repository@mail.house.gov.
                                                                                 Finally, members or witnesses experiencing any technical prob-
                                                                              lems should inform the committee staff immediately.
                                                                                 Well, good morning. Welcome to our ‘‘Cutting Methane Pollution:
                                                                              Safeguarding Health, Creating Jobs, and Protecting our Climate’’
                                                                              hearing. Today, we will review community perspectives on public
                                                                              health, climate, and jobs and the economic benefits of cutting meth-
                                                                              ane pollution from oil and gas infrastructure.
                                                                                 I will now recognize myself for 5 minutes for an opening state-
                                                                              ment.
                                                                                 Well, welcome to part two of our hearing series on methane, the
                                                                              second-largest source of heat-trapping pollution and a major con-
                                                                              tributor to the climate crisis. Last week, we discussed state per-
                                                                              spectives on cutting methane pollution and waste from the oil and
                                                                              gas sector. This week, we will discuss how slashing methane will
                                                                              help us safeguard the public health, create family-sustaining jobs,
                                                                              and improve lives across the nation.
                                                                                 It is clear that we need Federal action to reduce methane pollu-
                                                                              tion from the oil and gas sector, which remains the largest indus-




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                                                                                                                                  2

                                                                              trial source in the United States. According to the majority staff re-
                                                                              port from the House Science Committee, oil and gas companies are
                                                                              routinely failing to address super-emitting leaks.
                                                                                 Deployment of technologies to find and repair leaks is limited,
                                                                              and it is inconsistent. In order to fix this, it is crucial that the Fed-
                                                                              eral Government holds producers accountable for wasteful leaks as
                                                                              well as harmful practices like venting and flaring. Unless we step
                                                                              up our work, American families will continue to face the costly
                                                                              harms posed by this super-pollutant.
                                                                                 The health risks associated with methane pollution are clear.
                                                                              Americans living near oil and gas production suffer more asthma
                                                                              attacks as well as other lung and heart problems. Living near oil
                                                                              and gas wells can be dangerous to pregnant women, causing lower
                                                                              birth weights and pre-term births. In too many cases, these harms
                                                                              fall on frontline communities, including communities of color and
                                                                              low-income neighborhoods.
                                                                                 But these outcomes are entirely avoidable. There are ample tech-
                                                                              nologies available to help producers cut methane in cost-effective
                                                                              ways. These include continuous monitoring technologies, handheld
                                                                              optical imaging sensors that use infrared light, satellites that de-
                                                                              tect plumes from individual sites, and technologies to cleanly com-
                                                                              bust methane on site.
                                                                                 Deploying these technologies would allow the oil and gas sector
                                                                              to slash its methane emissions in half at no net cost. This is low-
                                                                              hanging fruit. These technologies can reduce waste and help save
                                                                              producers and customers money, but we need more companies to
                                                                              take advantage of them. Strong methane regulations from the En-
                                                                              vironmental Protection Agency to address the industry’s wasteful
                                                                              methane leaks will help drive innovation, enhance deployment, and
                                                                              create jobs.
                                                                                 The good news: we are getting help from the Biden administra-
                                                                              tion. Last week, along with the European Union and others, Presi-
                                                                              dent Biden helped launch the Global Methane Pledge Energy Path-
                                                                              way, a commitment to drive down methane pollution in the oil and
                                                                              gas sector and to eliminate routine flaring as soon as possible.
                                                                                 The President is also committed to slashing methane emissions
                                                                              in half by 2030. And his proposed EPA rule would reduce methane
                                                                              emissions by roughly 41 million tons through 2035.
                                                                                 House Democrats have also taken action. In the Energy Act of
                                                                              2020, we included improvements to natural gas pipeline safety as
                                                                              well as requirements for minimum performance standards, strict
                                                                              deadlines, and the use of advanced technologies to find and repair
                                                                              methane leaks.
                                                                                 Last year, we passed a bipartisan resolution rejecting the Trump
                                                                              administration’s attempt to weaken methane safeguards. And
                                                                              through the Bipartisan Infrastructure Law, we invested $4.7 billion
                                                                              to help states and Tribes plug and remediate abandoned oil and
                                                                              gas wells.
                                                                                 We also increased funding for reclaiming abandoned mines, mod-
                                                                              ernizing natural gas pipelines, and addressing undocumented or-
                                                                              phan wells. The House-passed reconciliation bill also included a
                                                                              methane fee to address wasteful pollution. And the House-passed
                                                                              Bipartisan Innovation Act included provisions to help states repair




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                                                                              and replace leaking natural gas distribution pipelines.




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                                                                                                                                  3

                                                                                So cutting harmful methane pollution will protect the public
                                                                              health and the climate, it will catalyze growth of new small busi-
                                                                              nesses, and it will create tens of thousands of new jobs. So I look
                                                                              forward to hearing from our witnesses today as we bring these
                                                                              cost-saving benefits to more American communities.
                                                                                I yield back the balance of my time and recognize the Ranking
                                                                              Member, Mr. Graves of Louisiana, for his 5-minute opening state-
                                                                              ment.
                                                                                [The statement of Ms. Castor follows:]
                                                                                                     Opening Statement of Chair Kathy Castor
                                                                                                  Hearing on ‘‘Cutting Methane Pollution:
                                                                                      Safeguarding Health, Creating Jobs, and Protecting Our Climate’’
                                                                                                                        June 24, 2022
                                                                                                                  As prepared for delivery
                                                                                 Welcome to Part 2 of our hearing series on methane, the second largest source
                                                                              of heat-trapping pollution and a major contributor to the climate crisis. Last week,
                                                                              we discussed state perspectives on cutting methane pollution and waste from the
                                                                              oil and gas sector. This week, we’ll discuss how slashing methane will help us safe-
                                                                              guard public health, create family-sustaining jobs, and improve lives across the na-
                                                                              tion.
                                                                                 It’s clear that we need federal action to reduce methane pollution from the oil and
                                                                              gas sector, which remains the largest industrial source in the United States. Accord-
                                                                              ing to a Majority Staff Report from the House Science Committee, oil and gas com-
                                                                              panies are routinely failing to address super-emitting leaks. Deployment of tech-
                                                                              nologies to find and repair leaks is limited and inconsistent. In order to fix this,
                                                                              it’s crucial that the federal government holds producers accountable for wasteful
                                                                              leaks, as well as harmful practices like venting and flaring. Unless we step up our
                                                                              work, American families will continue to face the costly harms posed by this super-
                                                                              pollutant.
                                                                                 The health risks associated with methane pollution are clear. Americans living
                                                                              near oil and natural gas production suffer more asthma attacks, as well as other
                                                                              lung and heart problems. Living near oil and gas wells can be dangerous to preg-
                                                                              nant women, causing lower birth weights and preterm births. In too many cases,
                                                                              these harms fall on frontline communities, including communities of color and low-
                                                                              income neighborhoods, but these outcomes are entirely avoidable.
                                                                                 There are ample technologies available to help producers cut methane in cost-ef-
                                                                              fective ways. These include continuous monitoring technologies; handheld optical
                                                                              imaging sensors that use infrared light; satellites that detect plumes from indi-
                                                                              vidual sites; and technologies to cleanly combust methane on site. Deploying these
                                                                              technologies would allow the oil and gas sector to slash its methane emissions in
                                                                              half at no net cost. This is low-hanging fruit. These technologies can reduce waste
                                                                              and help save producers and customers money. But we need more companies to take
                                                                              advantage of them. Strong methane regulations from the Environmental Protection
                                                                              Agency to address the industry’s wasteful methane leaks will help drive innovation,
                                                                              enhance deployment, and create jobs.
                                                                                 We’re getting help from the Biden administration. Last week, along with the Eu-
                                                                              ropean Union and others, President Biden helped launch the Global Methane Pledge
                                                                              Energy Pathway, a commitment to drive down methane pollution in the oil and gas
                                                                              sector, and to eliminate routine flaring as soon as possible. The President is also
                                                                              committed to slashing methane emissions in half by 2030. And his proposed EPA
                                                                              rule would reduce methane emissions by roughly 41 million tons through 2035.
                                                                                 House Democrats have also taken action. In the Energy Act of 2020, we included
                                                                              improvements to natural gas pipeline safety, as well as requirements for minimum
                                                                              performance standards, strict deadlines, and use of advanced technologies to find
                                                                              and repair methane leaks. Last year, we passed a bipartisan resolution rejecting the
                                                                              Trump administration’s attempt to weaken methane safeguards. And through the
                                                                              Bipartisan Infrastructure Law, we invested $4.7 billion to help states and tribes
                                                                              plug and remediate abandoned oil and gas wells. We also increased funding for re-
                                                                              claiming abandoned mine lands, modernizing natural gas pipelines, and addressing
                                                                              undocumented orphaned wells. The House-passed reconciliation bill included a




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                                                                              methane fee to address this wasteful pollution. And the House-passed Bipartisan In-




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                                                                                                                                  4
                                                                              novation Act included provisions to help states repair and replace leaky natural gas
                                                                              distribution pipelines.
                                                                                Cutting harmful methane pollution will protect public health and the climate. It
                                                                              will catalyze the growth of new small businesses. And it will create tens of thou-
                                                                              sands of new jobs. I look forward to hearing from our witnesses as we bring these
                                                                              cost-saving benefits to more American communities.
                                                                                 Mr. GRAVES. Thank you, Madam Chair.
                                                                                 I want to thank the witnesses for being here, and those that are
                                                                              here online.
                                                                                 I represent South Louisiana and, I would argue, one state that
                                                                              probably is more at risk from sea rise, from more intense storms,
                                                                              than probably anywhere else in the country.
                                                                                 And, Ms. Tomcik, Moms Clean Air Force—you know, I have got
                                                                              kids too, and I think a lot about the country that we leave them,
                                                                              the planet that we leave them.
                                                                                 You read the news and you listen to all the narratives that are
                                                                              out there, and you get this perspective that one side is here and
                                                                              then another side is over here. When you actually start digging in
                                                                              and looking at the data, the reality is you get a very different pic-
                                                                              ture. You get a very different picture.
                                                                                 You know, I will remind you that the United States has led the
                                                                              world in reducing emissions. We have led the world. I will remind
                                                                              you that Russian gas, when it is delivered to Europe, has 41-per-
                                                                              cent higher lifecycle emissions, Russian gas delivered to Asia, 47-
                                                                              percent higher lifecycle emissions, as compared to the United
                                                                              States.
                                                                                 The Biden administration has said very clearly—the Biden ad-
                                                                              ministration—that there is going to be a significant increase in nat-
                                                                              ural gas demand over the next 30 years. They have said that there
                                                                              is going to be a 50-percent increase in global energy demand over
                                                                              the next 28 years.
                                                                                 Yet what is happening in the United States? We are watching
                                                                              our administration carry out policies that shuts down American oil
                                                                              and gas production. So you can sit there and say, ‘‘Oh, this is great,
                                                                              because we are getting rid of oil and gas production, so that is
                                                                              going to reduce emissions and it is going to save our planet.’’ What
                                                                              the facts show is that that results in higher global emissions.
                                                                                 Don’t shake your head. That is the fact. It is a fact. You want
                                                                              to debate me? I can’t wait—I can’t wait to debate this.
                                                                                 Because the United States has some of the lowest intensity of
                                                                              emissions of conventional fuel production than any other country in
                                                                              the world. And don’t take my word for it; it is the IEA’s data. And
                                                                              it is crystal-clear. It is crystal-clear.
                                                                                 You want to argue with me on the other one? National Energy
                                                                              Technology Lab’s 2019 September, October report. Would love to
                                                                              have that discussion.
                                                                                 So here is the thing: what do we do? Instead of going out there
                                                                              and stopping Germany from building the Nord Stream II pipeline,
                                                                              the President of the United States effectively lifts the remaining
                                                                              sanctions that were blocking that from being built. You are facili-
                                                                              tating more Russian gas going into Germany.
                                                                                 Do you know, if we just took just the gas coming in from Russia
                                                                              into Europe in 2021, if we had just stopped it and replaced it—not




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                                                                              stopped it—stopped it and replaced it with U.S. gas, do you know




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                                                                              that the lifecycle emissions reduction would have been 218 million
                                                                              tons of greenhouse gas reductions? 218 million tons.
                                                                                 According to your testimony, as I recall, you say that there are
                                                                              8 million tons of methane emissions from U.S. oil, gas, and coal
                                                                              production. And I am not going to sit here and try and do the math
                                                                              between total greenhouse gas emissions and the methane, but—my
                                                                              gosh, 218 million tons from 1 year. And, according to your testi-
                                                                              mony, I believe it is 8 million tons for oil, gas, and coal—for all en-
                                                                              ergy production in the United States.
                                                                                 This is baffling to me. This administration shuts down the Key-
                                                                              stone Pipeline, whenever you have his own Press Secretary stand-
                                                                              ing up there and saying, oh, no, it didn’t stop the production of the
                                                                              areas where the Keystone was going to transport from. They are
                                                                              just sending it through different means. Do you know what that
                                                                              means? That means that you have higher emissions, and it means
                                                                              you have a greater chance of spilling. Wait a minute. I thought we
                                                                              were doing this to protect the environment?
                                                                                 You know, what is happening right now with this administra-
                                                                              tion’s policies, they have said, well, we are going to ban Russian
                                                                              oil, all right? We are going to ban Russian oil. We are going to stop
                                                                              it. And we said this was going to happen, and we said it on Feb-
                                                                              ruary 22: if you don’t do this right, it is actually going to cause
                                                                              greater emissions, and it is going to cause greater problems.
                                                                                 So look at what is happening right now. Russia is actually mak-
                                                                              ing more money—they are making more money off of their oil
                                                                              today than they were before they invaded Ukraine. Look at their
                                                                              economy. Look at the ruble.
                                                                                 And you know what we have done? We are selling cheaper en-
                                                                              ergy right now to India and to China, which has higher greenhouse
                                                                              gas emissions. So all we have done is we have incentivized the pur-
                                                                              chase of Russian oil that has greater greenhouse gas emissions.
                                                                              Nice job. And, hey, on top of it, there is lagniappe. We have actu-
                                                                              ally incentivized a higher-emitting source and, on top of it, we have
                                                                              undermined the U.S. economy and lost competitiveness.
                                                                                 You know, I have been accused—I am from South Louisiana,
                                                                              where we have energy production—and, by the way, some of the
                                                                              lowest-intensity-of-emissions energy production in the world. And I
                                                                              have been accused of being a shill of the oil and gas industry.
                                                                                 I want you all to think about something. The policies this admin-
                                                                              istration has carried out have resulted in over a 100-percent in-
                                                                              crease in gasoline prices, nearly tripling of natural gas, that have
                                                                              been heard as price gouging and all these massive profits from
                                                                              these companies. Who has caused that? They have. The policies we
                                                                              are advocating for? Lower emissions.
                                                                                 Let me ask you a question. Who is the environmentalist?
                                                                                 Ms. CASTOR. Now I want to welcome our witnesses.
                                                                                 Patrice Tomcik is the Senior National Field Manager with Moms
                                                                              Clean Air Force. She advocates for equitable solutions to protect
                                                                              children’s health from air pollution and climate change. A resident
                                                                              of Pennsylvania, Ms. Tomcik first became involved with Moms
                                                                              Clean Air Force as a volunteer, joining other local parents to push
                                                                              for clean air safeguards after fracking was permitted at gas wells




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                                                                              near her children’s schools.




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                                                                                 Dr. Robert Kleinberg is a Senior Research Scholar at Columbia
                                                                              University’s Center on Global Energy Policy. His work focuses on
                                                                              energy technology and economics as well as environmental and reg-
                                                                              ulatory issues associated with the oil and gas industry. Dr.
                                                                              Kleinberg earned a Doctorate in Physics from the University of
                                                                              California, San Diego, and is a Senior Fellow at the Boston Univer-
                                                                              sity Institute for Sustainable Energy.
                                                                                 Dr. Caroline Alden is the Co-Founder and Vice President of Prod-
                                                                              uct and Markets at LongPath Technologies, which is a greenhouse
                                                                              gas emissions monitoring service based in Boulder, Colorado. Dr.
                                                                              Alden earned her Doctorate in Geology from the University of Colo-
                                                                              rado, Boulder, and she previously worked with the National Oce-
                                                                              anic and Atmospheric Administration’s Carbon Cycle Group on
                                                                              greenhouse gas flux algorithms.
                                                                                 Sarah Ann Smith is the Chief of Programs with the Clean Air
                                                                              Task Force. A member of Clean Air Task Force’s senior leadership
                                                                              team, Ms. Smith led the growth of the organization’s methane
                                                                              emissions reduction program, building up a small team into a sub-
                                                                              stantial global operation on four continents.
                                                                                 Without objection, the witnesses’ written statements will be
                                                                              made part of the record.
                                                                                 With that, Ms. Tomcik, you are now recognized for 5 minutes.
                                                                              Welcome.
                                                                              STATEMENTS OF PATRICE TOMCIK, SENIOR NATIONAL FIELD
                                                                               MANAGER, MOMS CLEAN AIR FORCE; DR. ROBERT L. KLEIN-
                                                                               BERG, SENIOR RESEARCH SCHOLAR, COLUMBIA UNIVER-
                                                                               SITY CENTER ON GLOBAL ENERGY POLICY; DR. CAROLINE
                                                                               ALDEN, CO-FOUNDER AND VICE PRESIDENT OF PRODUCT
                                                                               AND MARKETS, LONGPATH TECHNOLOGIES; AND SARAH
                                                                               ANN SMITH, CHIEF OF PROGRAMS, CLEAN AIR TASK FORCE

                                                                                                      STATEMENT OF PATRICE TOMCIK
                                                                                 Ms. TOMCIK. Thank you. And hello, Chair Castor, Ranking Mem-
                                                                              ber Graves, and members of the Select Committee. Thank you for
                                                                              inviting me here today to speak about protecting our health, our
                                                                              climate, by cutting methane pollution.
                                                                                 I am Patrice Tomcik, a National Field Manager for Moms Clean
                                                                              Air Force, a national community of more than 1 million moms and
                                                                              caregivers united to protect our children’s health from air pollution
                                                                              and climate change. We envision a safe and equitable future where
                                                                              all children breathe clean air and live in a stable climate.
                                                                                 I am a mother of two boys living in southwest Pennsylvania on
                                                                              top of the Marcellus Shale, where many oil and gas operations are
                                                                              located within communities like mine.
                                                                                 In the U.S., the oil and gas sector is the largest industrial source
                                                                              of methane pollution contributing to climate change. Methane is a
                                                                              potent greenhouse gas and a main component of natural gas.
                                                                                 Children who live, learn, and play near oil and gas operations
                                                                              face higher risk of exposure to oil and gas industry’s harmful air
                                                                              pollution. Across our nation, more than 3.9 million children go to
                                                                              school within a half a mile of oil and gas operations.
                                                                                 My children attend the Mars Area School District, where there




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                                                                              are gas wells and a spiderweb network of gathering pipelines. The




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                                                                              closest wells that have been fracked are approximately a half a
                                                                              mile away from my children’s school campus, where 3,200 students’
                                                                              health is put at risk.
                                                                                 Oil and gas operations emit climate-warming methane and also
                                                                              harmful volatile organic compounds, otherwise known as VOCs.
                                                                              Both can contribute to ground-level ozone or smog. Smog is a lung
                                                                              irritant that triggers asthma attacks and increases lung infections.
                                                                                 Children have a higher respiratory rate than adults and, thus,
                                                                              can be exposed to higher rates of air pollution than adults. My boys
                                                                              play outdoor sports for school, and I am very concerned about what
                                                                              they are breathing into their still-developing lungs.
                                                                                 In addition, VOCs such as benzene are emitted by oil and gas op-
                                                                              erations. Benzene can affect lung development in children and in-
                                                                              crease the risk of immune system damage, neurological problems,
                                                                              and cancers such as childhood leukemia.
                                                                                 As a parent of a child who had leukemia, I know firsthand how
                                                                              critical clean air is to good health. In fact, it was my youngest son’s
                                                                              cancer journey that motivated me to speak out about protecting
                                                                              children’s health long before the first gas well was fracked near my
                                                                              school.
                                                                                 Every day I send my children to school, I fear for their health.
                                                                              This is especially true for Carson, who is at a higher risk of having
                                                                              cancer again. I am constantly reminded about how important my
                                                                              work is to protect children’s health from air pollution and climate
                                                                              change.
                                                                                 The families I work with would tell you that our climate crisis
                                                                              is a health crisis. These families are experiencing climate change
                                                                              impacts when smoke from record-breaking wildfires can poison the
                                                                              air for millions across the West; when severe heat waves regularly
                                                                              threaten public health, preying on older adults, pregnant women,
                                                                              and low-income communities. The list goes on.
                                                                                 This is happening right now, and we are all impacted by it. And
                                                                              especially at risk are Black, indigenous, and Latino communities,
                                                                              who are disproportionately exposed to the effects from climate
                                                                              change and harmful pollution from oil and gas operations. We need
                                                                              environmental justice now, and we need climate justice now.
                                                                                 Quickly and significantly reducing methane pollution is one of
                                                                              the best levers we have to slow the rate of climate change now and
                                                                              clean up the air to protect children’s health. Our families need
                                                                              strong Federal standards to create baseline methane protections,
                                                                              especially for states that have failed to enact meaningful oil and
                                                                              gas methane protections.
                                                                                 This is why it is so important that the EPA finalize a comprehen-
                                                                              sive methane rule to eliminate routine flaring and include frequent
                                                                              inspections for small wells with leak-prone equipment.
                                                                                 As parents, we can’t control the air our children breathe. It is
                                                                              why we depend on you, our elected leaders, to do your jobs and pro-
                                                                              tect our children. What we want is for our Congressmembers to ur-
                                                                              gently pass legislation than invest in a clean, healthy energy fu-
                                                                              ture.
                                                                                 Thank you.




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                                                                                 [The statement of Ms. Tomcik follows:]




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                                                                                                                                        8
                                                                                                              Testimony of Patrice Tomcik
                                                                                                 Senior National Field Manager for Moms Clean Air Force
                                                                                         U.S. House of Representatives Select Committee on the Climate Crisis
                                                                                                        Hearing on ‘‘Cutting Methane Pollution:
                                                                                           Safeguarding Health, Creating Jobs, and Protecting Our Climate’’
                                                                                                                              June 24, 2022
                                                                                       Chair Castor, Ranking Member Graves, and members of the Select Committee,
                                                                                    thank you for inviting me here today to speak about cutting methane pollution.
                                                                                       I commend each of you for your commitment to protecting our health and climate
                                                                                    while creating jobs.
                                                                                       I am Patrice Tomcik, a Senior National Field Manager for Moms Clean Air Force.
                                                                                    Moms Clean Air Force is a community of more than 1 million moms and dads na-
                                                                                    tionwide united to protect our children’s health from air pollution and climate
                                                                                    change. We envision a safe and equitable future where all children breathe clean
                                                                                    air and live in a stable climate.
                                                                                       I am the mother of two boys living in the town of Gibsonia located in Southwest
                                                                                    Pennsylvania on top of the Marcellus Shale where oil and gas operations are wide-
                                                                                    spread with many located within communities like mine. I am here in person today
                                                                                    to emphasize how important it is for frontline community members to literally be
                                                                                    in the room as climate and air pollution discussions are happening with lawmakers
                                                                                    and agencies.
                                                                                       Methane is a potent greenhouse gas responsible for over a quarter of current
                                                                                    global warming, and the oil and gas sector is the nation’s largest industrial source
                                                                                    of methane pollution. In the U.S., it is estimated that the oil and gas industry emits
                                                                                    more than 16 million metric tons of methane pollution annually—the equivalent of
                                                                                    the climate pollution from all of the nation’s passenger vehicles in a year. Methane
                                                                                    is the principal component of natural gas.
                                                                                       Climate change is causing a health crisis—and it’s happening right now. We see
                                                                                    it when extreme storms cause devastating flooding; when smoke from record-break-
                                                                                    ing wildfires can poison the air for millions across the West; when severe heat
                                                                                    waves regularly threaten public health, preying on older adults, pregnant women,
                                                                                    and low-income communities. Especially at risk are Black, Indigenous, and Latino
                                                                                    communities who are disproportionately exposed to the effects from climate change
                                                                                    and harmful pollution from oil and gas operations.
                                                                                       We need environmental justice. We need climate justice. And we need it now.
                                                                                       In the U.S., more than 17 million people live within a half mile of an active oil
                                                                                    and gas operations and more than 3.9 million children go to school within a half
                                                                                    mile of oil and gas operations that puts their health at risk.
                                                                                       My children attend the Mars Area School District where there are unconventional
                                                                                    gas wells and a spider web network of gathering pipelines. The closest gas wells
                                                                                    that have been fracked are approximately a half mile away from my children’s 5-
                                                                                    school campus that puts 3,200 students’ health at risk.
                                                                                       Oil and gas operations not only emit climate warming methane but also harmful
                                                                                    volatile organic compounds (VOCs). Both can contribute to ground level ozone, or
                                                                                    smog. Smog is a lung irritant that triggers asthma attacks and increases lung infec-
                                                                                    tions. Children have a higher respiratory rate than adults and thus can be exposed
                                                                                    to higher rates of air pollution than adults. In our family, my boys both play outdoor
                                                                                    sports for school. I am very concerned about what they are breathing into their still-
                                                                                    developing lungs.
                                                                                       In addition, VOCs such as benzene are emitted by oil and gas operations. Benzene
                                                                                    can affect lung development in children and increase the risk of immune system
                                                                                    damage, neurological and developmental problems, adverse birth outcomes, and
                                                                                    even cancer such as childhood leukemia.
                                                                                       As a parent of a child who had leukemia, I know first-hand how critical clean air
                                                                                    is to good health. In fact, it was my youngest son Carson’s cancer journey that moti-
                                                                                    vated me to speak up about protecting children’s health—and long before the first
                                                                                    gas well was fracked near the school. Yet, every day I send my children to school,
                                                                                    I fear for their health. This is especially true for Carson who is at a higher risk
                                                                                    of having cancer again.
                                                                                       My children and children across the nation need strong federal standards to cre-
                                                                                    ate baseline methane protections, especially for states that have failed to enact




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                                                                                    meaningful oil and gas methane protections. This is why it is so important that the
                                                                                    EPA finalize a comprehensive methane rule to eliminate routine flaring, require the
                                                                                    use of non-polluting equipment and include frequent inspections for smaller, leak-




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                                                                                                                                  9
                                                                              prone wells. Low-producing oil and gas wells are responsible for approximately half
                                                                              of the methane emitted from all well sites in the United States while accounting
                                                                              for only 6% of the nation’s oil and gas production.
                                                                                It is important that Congress properly funds the EPA to carry out the enforce-
                                                                              ment of rules in order to protect the health of communities. And as regulations and
                                                                              policies are being considered, there needs to be frequent consulting of environmental
                                                                              justice communities and communities living on the frontlines near oil and gas oper-
                                                                              ations to influence decisions related to the design and implementation of rules and
                                                                              policies. This week EDF published a new study that combines location of active oil
                                                                              and gas wells with census tract data showing that in dozens of counties throughout
                                                                              the U.S. a disproportionately large number of communities of color, people living
                                                                              below the poverty line, older individuals and young children live near wells.
                                                                                Parents can’t control the air our children breathe; we depend on our leaders to
                                                                              do their jobs and protect them. Moms and dads want action on climate, and we want
                                                                              those who represent us in Washington—our members of Congress—to pass laws, in-
                                                                              centives and funding that builds a clean energy future.
                                                                                Every child has the right to breathe clean air, and the right to a stable climate.
                                                                                Thank you.
                                                                              Resources
                                                                                 (1) https://www.edf.org/media/new-epa-rules-will-cut-methane-pollution-thousands-
                                                                              oil-and-gas-facilities-benefit-millions#:∼:text=EDF%20estimates%20the%20U.S.%20
                                                                              oil,and%20air%20 toxics%20like%20benzene
                                                                                 (2) https://oilandgasthreatmap.com/threat-map/
                                                                                 (3) https://www.momscleanairforce.org/resources/how-oil-and-gas-operations-impact-your-
                                                                              babys-health/
                                                                                 (4) https://www.nature.com/articles/s41467-022-29709-3
                                                                                 (5) https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.edf.org
                                                                              %2Fmedia%2Fstudy-explores-demographics-communities-living-near-oil-and-gas-wells&
                                                                              data=05%7C01%7Cptomcik%40edf.org%7C19d347ee348c4ee29d1508da53da48e6%7Cfe4574
                                                                              edbcfd4bf0bde843713c3f434f%7C0%7C0%7C637914494243881035%7CUnknown%7CTWF
                                                                              pbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0
                                                                              %3D%7C3000%7C%7C%7C&sdata=So%2BSvTYQeC2UzwGJ%2FiTjZ9q17BBGfy6wUe39
                                                                              CK%2BmqX8%3D&reserved=0
                                                                                Ms. CASTOR. Thank you very much.
                                                                                Next, Dr. Kleinberg, you are recognized for 5 minutes to provide
                                                                              a summary of your testimony. Welcome.

                                                                                                STATEMENT OF DR. ROBERT L. KLEINBERG
                                                                                 Dr. KLEINBERG. Yes. Good day, Chair Castor, Ranking Member
                                                                              Graves, and members of the Select Committee. It is an honor to ad-
                                                                              dress you.
                                                                                 The subtitle of today’s hearing is ‘‘Safeguarding Health, Creating
                                                                              Jobs, and Protecting Our Climate.’’
                                                                                 Methane emission mitigation is essential to reducing the rate of
                                                                              global warming between now and 2050. This is technically and eco-
                                                                              nomically feasible and has already generated a constellation of in-
                                                                              novative U.S. small businesses exploiting American designed and
                                                                              built technologies.
                                                                                 We know we must reduce our use of fossil fuels, and we know
                                                                              the transition from fossil fuels to zero-carbon sources of energy will
                                                                              take time. One of our chief challenges will be to minimize the dam-
                                                                              age associated with fossil fuel use during this transition.
                                                                                 According to the International Energy Agency, the world con-
                                                                              sumed 4 trillion cubic meters of natural gas in 2020. Assuming na-
                                                                              tions adhere to their announced Paris Agreement nationally deter-
                                                                              mined contributions, the world will consume almost exactly the




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                                                                              same amount of gas in 2050.




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                                                                                 Assuming the world can do much better than this and satisfy the
                                                                              IEA sustainable development scenario, consumption would still be
                                                                              2.5 trillion cubic meters. No matter how optimistic you are that na-
                                                                              tions will respect their Paris Agreement commitments, you must
                                                                              take methane emission reduction seriously.
                                                                                 Moreover, even after the transition from fossil fuels is complete,
                                                                              the methane problem will not go away by itself. Biogas and bio-
                                                                              methane production and transport have been found to be sources
                                                                              of this climate pollutant as well.
                                                                                 It is a time-honored truth that you cannot manage what you
                                                                              don’t measure. EPA relies on emission factor methodology which is
                                                                              now, sadly, outdated. Remarkably, over the last 7 years, American
                                                                              industry, academia, and nongovernmental organizations have
                                                                              worked together to find out how much methane the oil and gas in-
                                                                              dustries are actually emitting. The results show that EPA dramati-
                                                                              cally underestimates methane emissions.
                                                                                 Two examples of new measurement methods are aerial surveil-
                                                                              lance and continuous monitoring. The practicality of large-scale,
                                                                              quantitative, airborne remote sensing is now well-established. A
                                                                              large number of large-scale campaigns have been performed in
                                                                              major oil- and gas-producing regions. Costs are surprisingly mod-
                                                                              est.
                                                                                 Dr. Caroline Alden, who personifies the transformation of world-
                                                                              class academic research into successful business, will tell us about
                                                                              continuous monitoring in a few minutes.
                                                                                 You have probably heard that methane reduction can be imple-
                                                                              mented at no cost or even implemented at a profit, and I am sure
                                                                              this is true in some cases. But if it were generally true, industry
                                                                              would not be emitting as much methane as it does. I can tell you
                                                                              from personal experience that the petroleum industry does not
                                                                              leave money on the table.
                                                                                 As it is, oil- and gas-source methane emissions are declining at
                                                                              the meager rate of 0.3 percent per year. The truth is, industry
                                                                              needs to be nudged to do the right thing. This means smart regula-
                                                                              tion.
                                                                                 Oil and gas methane emissions can be remediated by known en-
                                                                              gineering solutions. In my written testimony, I review some simple
                                                                              measures that can reduce emissions by millions of tons per year.
                                                                              I compare these measures to the health and safety improvements
                                                                              I saw over the course of my career in the oil field. Our highly
                                                                              skilled and inventive workforce has made our workplaces safer
                                                                              while keeping American industry the most efficient and productive
                                                                              in the world. Given smart regulations and incentives, they will do
                                                                              the same with methane.
                                                                                 Finally, to address Ranking Member Graves’s point, I would like
                                                                              to point out that Russia is taking advantage of inferior methane re-
                                                                              porting methods to improve its environmental image. Like the
                                                                              United States, Russia uses the emission factor method when re-
                                                                              porting its methane emissions to the UNFCCC, but, unlike the
                                                                              United States, Russia’s self-reported methane emissions from its oil
                                                                              and gas sector declined by a remarkable factor of eight since 2015.
                                                                                 As a result, Russia’s self-reported methane intensity is now less




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                                                                              than that of the United States. If left unchallenged, the Russian re-




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                                                                                                                                            11

                                                                              ports weaken the case for reduction of European dependence on
                                                                              Russian natural gas. Only measurements will reveal the truth.
                                                                                 Please see my written submission for some specific recommenda-
                                                                              tions. And thank you for giving me the opportunity to share these
                                                                              observations with you.
                                                                                 [The statement of Dr. Kleinberg follows:]
                                                                                                 Testimony of Dr. Robert L. Kleinberg—Final
                                                                                                          Senior Research Scholar,
                                                                                            Columbia University Center on Global Energy Policy
                                                                                      Senior Fellow, Boston University Institute for Sustainable Energy
                                                                                              Member of the National Academy of Engineering
                                                                                   U.S. House of Representatives Select Committee on the Climate Crisis
                                                                                                  Hearing on ‘‘Cutting Methane Pollution:
                                                                                     Safeguarding Health, Creating Jobs, and Protecting Our Climate’’
                                                                                                                                June 24, 2022
                                                                              Contents
                                                                              Introduction ................................................................................................................ 11
                                                                              Methane as a Greenhouse Gas .................................................................................. 12
                                                                              Methods for Quantifying Methane Emissions Need to be Improved ..................... 12
                                                                              The Methane Problem is Relatively Easy to Solve .................................................. 13
                                                                                 Aircraft Surveillance ............................................................................................... 13
                                                                                 Continuous Monitoring ........................................................................................... 14
                                                                                 Remediation ............................................................................................................. 14
                                                                              Economic Benefits of Methane Mitigation ............................................................... 14
                                                                                 Methane Emission Characterization is Dominated by U.S. Technology and
                                                                                   Service Providers ................................................................................................. 14
                                                                                 Increasing Interest in Fossil Fuels with Low Greenhouse Gas Footprints ....... 15
                                                                                 Russia Takes Advantage of Inferior Methane Accounting Standards ................ 15
                                                                              Recommendations ....................................................................................................... 16
                                                                                 Launch a Methane Census ..................................................................................... 16
                                                                                 Support the International Methane Emissions Observatory .............................. 16
                                                                                 Reform the Alternative Means of Emission Limitation Process ......................... 16
                                                                                 Carefully Examine OGMP 2.0 Before Adopting It as U.S. Policy ...................... 17
                                                                              References ................................................................................................................... 17
                                                                              Introduction
                                                                                Good day Chair Castor, Ranking Member Graves, and members of the Select
                                                                              Committee. My name is Robert Kleinberg. I am presently affiliated with energy pol-
                                                                              icy research units of Columbia University and Boston University, which I joined
                                                                              after working for four decades in technology development in the oil and gas indus-
                                                                              try. I have been elected to the National Academy of Engineering in recognition of
                                                                              my contributions to geoscience technology.
                                                                                The subtitle of today’s hearing is ‘‘Safeguarding Health, Creating Jobs, and Pro-
                                                                              tecting Our Climate’’. Some people see creating jobs and protecting our health and
                                                                              environment as mutually exclusive goals, particularly with respect to oil and gas de-
                                                                              velopment. I hope to show you today that those goals support each other. Methane
                                                                              emission mitigation is essential to reducing the rate of global warming between now
                                                                              and 2050. It is technically and economically feasible. And it has already generated
                                                                              a constellation of innovative U.S. small businesses exploiting a variety of American
                                                                              designed and built technologies. If we use the technologies we have developed, we
                                                                              will secure the United States’ place as the world’s premier supplier of fuels while
                                                                              minimizing climate change during the transition to zero-carbon energy.
                                                                                To understand the importance of minimizing climate change during the transition
                                                                              to low-carbon sources of energy, we must have a clear view of the magnitude and
                                                                              pace of the transition. According to the International Energy Agency, the world con-
                                                                              sumed four trillion cubic meters of natural gas in 2020. Assuming nations adhere
                                                                              to their announced Nationally Determined Contributions, the world will consume al-
                                                                              most exactly the same amount of gas in 2050 [IEA, 2021, Table A.12]. No matter
                                                                              how optimistic you are that nations will respect their Paris Agreement commit-
                                                                              ments, you must take methane emission reduction seriously.
                                                                                Moreover, even after the transition from fossil fuels is complete, the methane
                                                                              problem will not go away by itself. Biogas and biomethane production and transport
                                                                              have been found to be increasingly important sources of this climate pollutant




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                                                                              [Scheutz, 2019].




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                                                                              Methane as a Greenhouse Gas
                                                                                We know we must reduce our use of fossil fuels, and we know the transition from
                                                                              fossil fuels to zero carbon sources of energy will take time. One of our chief chal-
                                                                              lenges will be to minimize the damage associated with fossil fuel use during the
                                                                              transition. One of the big questions we face is, who can provide energy with the
                                                                              smallest greenhouse gas (GHG) footprint. The European Union is considering the
                                                                              Carbon Border Adjustment Mechanism, a market-based plan that preferences those
                                                                              countries best able to meet this challenge. Many of us believe the United States
                                                                              should be able to out-compete most everyone else.
                                                                                You have already learned that control of methane emissions plays an important
                                                                              role in greenhouse gas reduction. Reducing methane is likely the only realistic route
                                                                              to mitigating global temperature increase before 2050, see Figure 1. Unlike carbon
                                                                              dioxide, which is an inevitable by-product of the generation of useful energy from
                                                                              fossil fuels, methane emissions benefit no one. No one makes money sending meth-
                                                                              ane into the atmosphere, no energy is produced as a result of it, no communities
                                                                              are supported by it, no one’s job depends on it. Venting methane into the atmos-
                                                                              phere is like throwing garbage into the street outside your home. It is worse than
                                                                              that, it is like throwing good food, that could be used elsewhere, into the street out-
                                                                              side your home.




                                                                              Methods for Quantifying Methane Emissions Need to be Improved
                                                                                 We are rapidly refining our understanding of where methane waste is coming
                                                                              from, and therefore how to reduce it. Every year, Annex 1 nations report their meth-
                                                                              ane emissions to the secretariat of the United Nations Framework Convention on
                                                                              Climate Change (UNFCCC). The United States submits the Environmental Protec-
                                                                              tion Agency Inventory of U.S. Greenhouse Gas Emissions and Sinks (‘‘GHGI’’)
                                                                              [UNFCCC, 2022a; EPA, 2022a]. The effort and care EPA invests in this report is
                                                                              extraordinary. EPA tracks 250 methane source types from natural gas and petro-
                                                                              leum systems alone [EPA, 2022b].
                                                                                 EPA relies on emission factor methodology, which when it was introduced in the
                                                                              1990s was the best method of the time, but which is now decidedly outdated. Emis-
                                                                              sions are calculated from the populations and estimated gas loss rates of each of
                                                                              the 250 source types found in oil and natural gas infrastructure. This is a spread-
                                                                              sheet exercise that requires no measurements of equipment operating in the field
                                                                              and therefore does not represent actual amounts of methane emitted to the atmos-
                                                                              phere.
                                                                                 Due to its own extraordinarily restrictive rules on acceptance of alternative means




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                                                                              of emission limitation, EPA has to date approved only two methods for natural gas




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                                                                                                                                  13
                                                                              leak detection, neither of which are quantitative [40 CFR 60 Appendix A–7 Method
                                                                              21; 73 Fed Reg 78199–78219]. Remarkably, over the last seven years, American in-
                                                                              dustry, academia, and non-governmental organizations have moved beyond regula-
                                                                              tions and worked together to find out how much methane our oil and gas industries
                                                                              are actually emitting. The results have showed that EPA dramatically underesti-
                                                                              mates methane emissions [see e.g., Alvarez, 2018; Rutherford, 2021].
                                                                              The Methane Problem is Relatively Easy to Solve
                                                                                 Current regulations to control oil and gas methane emissions are both inefficient
                                                                              and ineffective [Kleinberg, 2021b]. However, this does not imply that solving meth-
                                                                              ane emission problems are economically ruinous or technically difficult. In fact, solu-
                                                                              tions are not particularly expensive and fall within the range of current engineering
                                                                              practice.
                                                                                 Realizing the limitations of current EPA regulations, the oil and gas industry,
                                                                              competing technology innovators, academics, and non-governmental organizations
                                                                              have cooperated to develop new and better methods to detect and characterize
                                                                              sources of methane emissions. Scientific and technical publications number well
                                                                              above a thousand and a thorough review of this work is beyond the scope of this
                                                                              testimony. I present a few examples that might serve as models for national-scale
                                                                              efforts in the future.
                                                                              Aircraft Surveillance
                                                                                 The practicality of large scale, quantitative airborne remote sensing is well estab-
                                                                              lished. A number of basin-scale campaigns have already been performed in major
                                                                              oil and gas producing regions, by public and private entities using a variety of re-
                                                                              mote sensing technologies. Here are some examples:
                                                                                 • In the Permian Basin, aircraft-based instrumentation was used to survey areas
                                                                                   totaling 55,000 km2. Methane emission rates were measured at the largest
                                                                                   emitters: more than 1000 oil and gas facilities. Updated results are published
                                                                                   by the Environmental Defense Fund on maps showing every large emission
                                                                                   event, tagged with emission rate and owner/operator identity; see Figure 2
                                                                                   [EDF, 2021b; Cusworth, 2021]. Flare malfunction is the subject of special stud-
                                                                                   ies [EDF, 2021a].




                                                                                   • In the Permian Basin of New Mexico, Kairos Aerospace surveyed more than
                                                                                     30,000 active oil and gas wells and more than 10,000 miles of gas gathering
                                                                                     pipeline. These comprised 93% of surface facilities and 77% of pipeline length
                                                                                     over an area of 10,859 square miles. As a result, 1056 active methane emitters
                                                                                     were located, identified, and quantified [Berman & Deiker, 2020; Sridharan,
                                                                                     2020].
                                                                                   • In California, 272,000 infrastructure elements were surveyed over 59,000 km2.
                                                                                     As a result, 564 methane point sources (including those in agricultural and




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                                                                                     waste sectors) were identified and quantified [Duren, 2019].




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                                                                                Consistent with a modeling study [Rashid, 2020], these surveys have shown that
                                                                              facility-level measurements, even when 100 to 1000 times less sensitive than cur-
                                                                              rent EPA mandates, are efficient and effective in finding vented and fugitive meth-
                                                                              ane emissions. Moreover, these surveys are remarkably inexpensive: about $150 per
                                                                              well site in the Permian Basin according to one source [Johnson, 2021]. About
                                                                              45,000 wells have been drilled in the Permian Basin since January 2011, arranged
                                                                              on a smaller number of pads [EIA, 2021]. These wells can be surveyed for about
                                                                              the cost of drilling and hydraulically fracturing a single well. Note however that
                                                                              service pricing varies with location and other factors.
                                                                              Continuous Monitoring
                                                                                 Continuous monitoring of oil and gas infrastructure for methane emissions is not
                                                                              yet mature, but I believe it will become an essential element of methane surveil-
                                                                              lance in the future. The intermittency of super-emitters is a problem that is at the
                                                                              forefront of methane control issues [House Committee on Science, Space, and Tech-
                                                                              nology, 2022]. Continuous monitoring, which is more expensive than occasional air-
                                                                              craft surveys, is best suited for sites with emission-prone infrastructure. These in-
                                                                              clude gas processing plants, refineries, biogas and biomethane production facilities,
                                                                              liquefied natural gas terminals, and well sites or other facilities with storage ves-
                                                                              sels. By contrast, simple well sites with minimal ancillary hardware are unlikely to
                                                                              need this service. Simple wells account for most of the one million U.S. well sites
                                                                              that the EPA seeks to regulate in its proposed new methane control rules [EPA,
                                                                              2021]; avoiding the extra expense of monitoring them continuously is desirable.
                                                                              General comments detailing the capabilities and deployment options of continuously
                                                                              monitoring sensors have been submitted to EPA [LongPath, 2022; CleanConnect.AI,
                                                                              2022].
                                                                              Remediation
                                                                                While we have discovered we are emitting much more methane than we thought,
                                                                              we have also discovered that oil and gas methane emissions problems can usually
                                                                              be remediated by known engineering solutions. EPA has already determined that
                                                                              replacing natural-gas-actuated valves with electrical or compressed air systems can
                                                                              reduce methane emissions by a remarkable two million tons per year. Simple com-
                                                                              bustion sensors can be used to prevent unlit flares from emitting vast amounts of
                                                                              methane. SCADA systems that make sure pressure relief valves on tanks close prop-
                                                                              erly should be universally implemented. Again, note the contrast with carbon diox-
                                                                              ide. Reducing our carbon dioxide emissions will entail a multi-decadal, multi-trillion
                                                                              dollar reorganization of our economy. Reducing our oil and gas methane emissions
                                                                              will require some engineering fixes. I compare these to the health and safety im-
                                                                              provements I saw over the course of my career in the oilfield. Our highly skilled
                                                                              and inventive workforce has made our workplaces safer while keeping American in-
                                                                              dustry the most efficient and productive in the world. Given smart regulations and
                                                                              incentives, they will do the same with methane.
                                                                              Economic Benefits of Methane Mitigation
                                                                              Methane Emission Characterization is Dominated by U.S. Technology and Service
                                                                                   Providers
                                                                                 A rapidly growing, highly competitive, small-business-dominated industry is de-
                                                                              veloping in the absence of regulatory drivers. For example, here is a partial list (in
                                                                              alphabetical order) of U.S. service providers offering commercial aerial surveillance
                                                                              of methane emissions on a fee-for-service basis:

                                                                                           Aerial Production Services   https://www.flyaps.io/oil-gas
                                                                                           Baker Hughes                 https://www.bakerhughes.com/emissions-management
                                                                                           Bridger Photonics            https://www.bridgerphotonics.com/
                                                                                           Carbon Mapper                https://carbonmapper.org/
                                                                                           Kairos Aerospace             https://kairosaerospace.com/
                                                                                           LaSen                        https://www.lasen.com/
                                                                                           Scientific Aviation          https://www.scientificaviation.com/
                                                                                           SeekOps                      https://seekops.com/




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                                                                                                                                  15
                                                                               Here is a partial alphabetical list of mostly small companies providing continuous
                                                                              monitoring services for oil and gas clients:

                                                                                                                   Airdar
                                                                                                                   CleanConnect.ai
                                                                                                                   Honeywell | Rebellion
                                                                                                                   IntelliView Technologies
                                                                                                                   Kuva Systems
                                                                                                                   LongPath Technologies
                                                                                                                   Project Canary
                                                                                                                   Qube Technologies
                                                                                                                   Scientific Aviation
                                                                                                                   Sensirion Connected Solutions

                                                                                These leading-edge companies are a small fraction of the total effort devoted to
                                                                              methane emissions mitigation today. A report written for the Environmental De-
                                                                              fense Fund estimates that 215 U.S. companies are engaged in various phases of
                                                                              methane control [EDF, 2021c].
                                                                              Increasing Interest in Fossil Fuels with Low Greenhouse Gas Footprints
                                                                                 The proposed European Union Carbon Border Adjustment Mechanism (CBAM)—
                                                                              which includes methane as part of the ‘‘CO2equivalent’’—is the leading example of
                                                                              the trend towards preferencing imports of low-GHG products. CBAM will be mean-
                                                                              ingless if it is based on spreadsheet exercises unmoored to measurement. If U.S. fos-
                                                                              sil fuels have lower GHG impact than those from other nations (as plausibly as-
                                                                              serted by minority members in a House Committee on Science, Space and Tech-
                                                                              nology hearing last week) certification based on measurement will both immediately
                                                                              benefit U.S. energy exporters and, in the long run, spur other nations to take
                                                                              verifiable actions to reduce their GHG emissions. This will help reduce the rate of
                                                                              climate change during the energy transition.




                                                                              Russia Takes Advantage of Inferior Methane Accounting Standards
                                                                                Like the United States and other Annex 1 countries, Russia uses the emission fac-
                                                                              tor method when reporting its methane emissions to UNFCCC. However, Russia re-
                                                                              ports on only fourteen source types in their oil and gas industry. And whereas the
                                                                              United States changes its emission factors cautiously, Russian emission factors vary
                                                                              by large amounts from year to year [Kleinberg, 2022]. Figure 3 compares U.S. and




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                                                                              Russian reports.




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                                                                                                                                  16
                                                                                With regard to methane emissions associated with natural gas exports to Europe,
                                                                              the U.S. would today appear to be at a competitive disadvantage relative to Russia.
                                                                              Since 2015, Russia’s methane emissions from the oil and gas sector have declined
                                                                              by a factor of eight, according to its National Inventory Reports to UNFCCC. As a
                                                                              result, Russia’s reported methane intensity is now less than that of the United
                                                                              States. If left unchallenged, these data weaken the case for reduction of European
                                                                              dependence on Russian natural gas. Although there is broad consensus in U.S. in-
                                                                              dustry and policymaking circles that U.S. natural gas is the cleaner product,
                                                                              UNFCCC data must be challenged, and the only way to do this is with measure-
                                                                              ments such as those being developed and perfected by American industry and aca-
                                                                              demic groups.
                                                                              Recommendations
                                                                              Launch a Methane Census
                                                                                 I draw the Committee’s attention to the recently released majority staff report
                                                                              ‘‘Seeing CH4 Clearly: Science-Based Approaches to Methane Monitoring in the Oil
                                                                              and Gas Sector’’ [House Committee on Science, Space and Technology, 2022]. The
                                                                              Recommendations section of this report is worthy of attention. I particularly point
                                                                              to the idea of a Methane Census:
                                                                                   The Methane Census would utilize commercially-available innovative LDAR
                                                                                   [Leak Detection and Repair] technologies to perform large-scale methane
                                                                                   detection surveys covering the majority of oil and gas infrastructure in each
                                                                                   basin and to quantify the size of the detected emissions. The Methane Cen-
                                                                                   sus would gather data to improve the characterization of oil and gas sector
                                                                                   methane emissions in several key aspects, including by segment and by
                                                                                   emission source, as well as data regarding the aggregate emissions for each
                                                                                   basin. [House Committee on Science, Space and Technology, 2022, page 53]
                                                                                 As documented above, aerial surveys of the Permian Basin and of California have
                                                                              already shown the feasibility of this idea, which can be implemented at relatively
                                                                              low cost. Comprehensive nationwide data would establish the United States as a
                                                                              supplier of verifiably low-GHG fossil fuels for the rest of the world and serve as a
                                                                              baseline for future reduction efforts.
                                                                              Support the International Methane Emissions Observatory
                                                                                The International Methane Emissions Observatory (IMEO) is mentioned but not
                                                                              highlighted in the House Committee on Science, Space and Technology majority
                                                                              staff report. The IMEO is a project of the United Nations Environment Programme
                                                                              and supported by the European Commission [European Commission, 2021]. Its mis-
                                                                              sion is to integrate multiple streams of methane emission data to better understand
                                                                              causes and remedies. ‘‘A technical study to inform approaches to reconciling the
                                                                              data from the Methane Census with existing EPA data sources’’ [House Committee
                                                                              on Science, Space and Technology, 2022, page 53] is exactly what IMEO was created
                                                                              to do. The United States has not yet strongly engaged with this effort, which would
                                                                              most certainly benefit from the energy and expertise of U.S. actors in this space.
                                                                              The United States, in turn, would benefit from interaction with European technical
                                                                              experts, particularly in the field of satellite surveillance of oil and gas infrastruc-
                                                                              ture, in which Europe has taken the lead.
                                                                              Reform the Alternative Means of Emission Limitation Process
                                                                                Through multiple waves of Environmental Protection Agency rule-making over
                                                                              the last ten years, the EPA has remained an impediment to technical innovation
                                                                              in methane emission control, when it should be a promoter of it. American small
                                                                              business, academics, and NGOs, are enthusiastically innovating in this space, but
                                                                              inflexible EPA rules have discouraged widespread adoption of new technology by oil
                                                                              and gas operators. To put it bluntly, the only two EPA-approved methods, Method
                                                                              21 and OGI, have been cold dead hands in this horror story.
                                                                                The Clean Air Act recognizes the role of new technologies in helping to solve our
                                                                              environmental problems:
                                                                                   If after notice and opportunity for public hearing, any person establishes to
                                                                                   the satisfaction of the Administrator that an alternative means of emission
                                                                                   limitation will achieve a reduction in emissions of any air pollutant at least
                                                                                   equivalent to the reduction in emissions of such air pollutant achieved
                                                                                   under the requirements of paragraph (1), the Administrator shall permit
                                                                                   the use of such alternative by the source for purposes of compliance with




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                                                                                   this section with respect to such pollutant. [42 USC 7411(h)(3)]




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                                                                                                                                  17
                                                                                It has been shown over and over again that basin-wide aircraft overflights have
                                                                              the potential to reduce methane emissions by half or more. This would be out-
                                                                              standing progress compared to the present rate of methane reduction, which aver-
                                                                              ages 0.3% per year [Kleinberg, 2021b].
                                                                                However, the Alternative Means of Emission Reduction (AMEL) process, as imple-
                                                                              mented by 40 CFR 60 Subpart OOOO in 2012 and renewed by 40 CFR 60 Subpart
                                                                              OOOOa [40 CFR 60.5398a, 29 August 2017], was perversely, fiendishly difficult to
                                                                              satisfy. From 2012 to 2020, while American innovators were developing and success-
                                                                              fully field testing numerous ground-based, drone-based, aerial, and satellite methods
                                                                              for emission reduction, not a single application for AMEL was filed with EPA. The
                                                                              2020 Technical Amendments (which were not withdrawn by Public Law 117–23)
                                                                              considerably simplified AMEL application requirements [40 CFR 60.5398a, 15 Sep-
                                                                              tember 2020]. A single application has been filed, more than a year ago [Bridger,
                                                                              2021], but to the best of my knowledge, this application has not yet been acted on.
                                                                              For more details on the AMEL issue see [Kleinberg, 2021a, Section 16 and Appendix
                                                                              IV].
                                                                              Carefully Examine OGMP 2.0 Before Adopting It as U.S. Policy
                                                                                 OGMP 2.0 is a methane emission measurement and reporting protocol for the oil
                                                                              and gas industry that has been embraced by the United Nations Environment Pro-
                                                                              gramme, the European Commission, the Government of the United Kingdom, the
                                                                              Environmental Defense Fund, and eighty oil and gas companies [OGMP, 2022a].
                                                                              Companies that adhere to a subset of its principles are deemed to have attained
                                                                              ‘‘gold standard’’ status. The original OGMP 2.0 Framework [OGMP, 2020] was de-
                                                                              fective in many respects, but it has recently been replaced by an improved version
                                                                              [OGMP, 2022b] that honors the learnings that have accumulated over the last sev-
                                                                              eral years. The range of sponsors has lent momentum to this protocol, and the Euro-
                                                                              pean Commission seems predisposed to incorporating it into initiatives such as the
                                                                              Carbon Border Adjustment Mechanism. U.S. policymakers should be prepared to re-
                                                                              spond.
                                                                                 Thank you for giving me the opportunity to share these observations with you.
                                                                              References
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                                                                              gas supply chain, Science 10.1126/science.aar7204
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                                                                                   Ms. CASTOR. Thank you very much.
                                                                                   Next, Dr. Alden, you are recognized for 5 minutes. Welcome.
                                                                                                   STATEMENT OF DR. CAROLINE ALDEN
                                                                                 Dr. ALDEN. Thank you. Chairwoman Castor, Ranking Member
                                                                              Graves, and members of the committee, thank you for inviting
                                                                              LongPath to testify today.
                                                                                 My name is Caroline Alden. I have spent the last 15 years using
                                                                              greenhouse gas measurements to understand emission sources to
                                                                              the atmosphere. After a decade researching this topic, I helped co-
                                                                              found LongPath Technologies. And in my current role, I develop al-
                                                                              gorithms that convert our laser measurements to emission volumes
                                                                              and I work with stakeholders across industry, academia, environ-
                                                                              mental organizations, and government on how best to reduce emis-
                                                                              sions.
                                                                                 This morning, I look forward to discussing the technology and
                                                                              the benefits of measuring and mitigating methane emissions, which
                                                                              I believe is a win-win for the climate, for industry, and for neigh-
                                                                              boring communities.
                                                                                 Methane leaks from oil and gas operations are unpredictable.
                                                                              They can happen anywhere at any time, and they can be intermit-
                                                                              tent. Methane leak plumes are invisible and odorless. These char-
                                                                              acteristics make methane leaks very difficult to catch without ad-
                                                                              vanced technologies.
                                                                                 There are three pillars of advanced methane detection: number
                                                                              one, frequency of emission readings. Total emissions are governed
                                                                              by how long the leak goes on, meaning the faster you catch it, the
                                                                              better. Number two, site coverage. It is important to see all emis-
                                                                              sion points on a site. The EPA method of handheld cameras often
                                                                              misses unlit flares, for example, simply because they are high up
                                                                              off the ground. Number three, sensitivity to different leak sizes. As
                                                                              industry keeps reducing emissions, technologies must ultimately be
                                                                              able to help operators get to zero emissions.
                                                                                 So there are a range of new methane detection technologies. Air-
                                                                              planes and satellites generally perform periodic surveys. Aerial sur-
                                                                              veys only really catch larger leaks, but they do see all of the equip-
                                                                              ment on a site and they cover large areas. This informs what emis-
                                                                              sions look like as a whole, including whether policy targets are




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                                                                              being met.




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                                                                                 Fixed continuous monitors provide high-frequency emission read-
                                                                              ings, allowing for rapid fixing of leaks. Continuous technologies
                                                                              vary in terms of coverage, but most have the ability to catch small
                                                                              leaks, and many have the ability to quantify leak volumes.
                                                                                 The U.S. doesn’t currently have a regulatory system established
                                                                              to leverage quantification data, but quantitative data provides many
                                                                              benefits. Quantification lets operators prioritize leaks for faster re-
                                                                              pair, prioritize what equipment to replace, tune equipment set
                                                                              points, and ultimately assess how well compliance measures work.
                                                                                 LongPath Technologies uses Nobel Prize-winning frequency comb
                                                                              lasers that emit hundreds of thousands of colors of infrared light
                                                                              to measure methane and other greenhouse gases in the atmos-
                                                                              phere. Each laser is tower-mounted and covers 20 square miles,
                                                                              measuring emissions on a site-by-site basis for customers within
                                                                              the purview. LongPath’s network-style coverage lowers the barrier
                                                                              to entry for monitoring all types of facilities, importantly including
                                                                              marginal and orphaned well sites.
                                                                                 So, going back to those pillars of advanced monitoring, LongPath
                                                                              provides continuous emissions data to customers in real-time, our
                                                                              readings cover all the equipment on a site, and we quantify all
                                                                              sizes of leaks. Importantly, the tech is proven through extensive
                                                                              third-party blind testing and in the field, and we have made all of
                                                                              that data publicly available.
                                                                                 In closing, I would like to offer four themes for methane detec-
                                                                              tion in emerging policy, differentiated markets, and with respect to
                                                                              industry adoption.
                                                                                 Number one, methane monitoring reduces emissions, saves costs
                                                                              for operators, drives energy efficiencies for the market, and creates
                                                                              jobs. LongPath tripled in size last year, with new jobs ranging from
                                                                              field technicians in West Texas to software engineers working re-
                                                                              motely across the U.S.
                                                                                 Number two, the U.S. is the world leader in methane monitoring
                                                                              technologies. If we recognize the aligned incentives of policymakers,
                                                                              climate advocates, and industry, then U.S. gas can also become the
                                                                              cleanest in the world.
                                                                                 To accomplish this, regulations need to encourage operators to
                                                                              use new technologies and plan for quantification-based metrics.
                                                                              EPA rules should include a matrix that allows for technology-neu-
                                                                              tral choices by operators. SEC rules should require measurements,
                                                                              not outdated inventories. And responsibly sourced gas standards
                                                                              should preclude greenwashing by driving stringency, transparency,
                                                                              and quality in monitoring.
                                                                                 Relatedly, number three, the Federal Government could invest in
                                                                              the creation of independent third-party bodies to certify and create
                                                                              standards for new technologies.
                                                                                 Lastly, number four, continuous monitoring is inexpensive, and
                                                                              it more than pays for itself through reduced costs and revenue re-
                                                                              tention for operators. We can outfit the Permian Basin, the largest
                                                                              gas-producing basin in the U.S., for quantitative continuous meth-
                                                                              ane monitoring for less than the cost of 20 to 30 miles of interstate
                                                                              highway—or, as my colleague Gregory Rieker puts it, for less than
                                                                              the cost of the last James Bond movie.
                                                                                 So thank you for the opportunity to contribute to today’s hearing.




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                                                                                 [The statement of Dr. Alden follows:]




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                                                                                                       The Testimony of Caroline Alden, Ph.D.
                                                                                                            LongPath Technologies, Inc.
                                                                                                       ‘‘Cutting Methane Pollution:
                                                                                      Safeguarding Health, Creating Jobs, and Protecting Our Climate’’
                                                                                                                 A Hearing of the
                                                                                                       Select Committee on the Climate Crisis
                                                                                                           U.S. House of Representatives
                                                                                                                   Friday, June 24, 2022
                                                                                 Chairwoman Castor, Ranking Member Graves, and distinguished Members of the
                                                                              Committee, thank you for inviting LongPath Technologies to testify today. My name
                                                                              is Caroline Alden. I have spent the last 15 years using greenhouse gas measure-
                                                                              ments to understand emission sources and sinks to the atmosphere. After a decade
                                                                              contributing to academic research on this topic, I co-founded and am now the Vice
                                                                              President of Product and Markets for LongPath Technologies. In this role, I not only
                                                                              work on the algorithms to leverage atmospheric measurements to monitor methane
                                                                              emissions, but I also work with experts and stakeholders across industry, academia,
                                                                              environmental organizations, and government.
                                                                                 This morning I look forward to discussing both the technology and benefits of
                                                                              measuring and mitigating methane emissions from oil and gas operations and other
                                                                              man-made sources. In the oil and gas industry, where LongPath provides methane
                                                                              monitoring, reducing emissions is a win-win for the climate, for industry, for neigh-
                                                                              boring communities, and for policymakers who are concerned about methane pollu-
                                                                              tion.
                                                                                 Methane leaks from oil and gas operations are unpredictable. They can happen
                                                                              anywhere and at any time, and they can also be intermittent, meaning leak sizes
                                                                              can change over hours or days.1 Finally, methane leak plumes are invisible and
                                                                              odorless. These characteristics make leaks of methane from oil and gas operations
                                                                              very difficult to catch without advanced technologies.
                                                                                 There are three pillars of advanced methane detection:
                                                                                 1. Frequency of data readings. Total emissions are the leak rate times how
                                                                                    long the leak goes on, meaning the faster you catch it the better. And intermit-
                                                                                    tent emissions are hard to catch at all without high-frequency data.
                                                                                 2. Site coverage. It’s important to see all emission points on a site. The older
                                                                                    EPA method of using handheld infrared cameras often misses unlit flares, for
                                                                                    example, because they are high up off the ground.
                                                                                 3. Sensitivity to different leak sizes. Can a technology catch all leaks or only
                                                                                    large leaks? As industry keeps reducing emissions, technologies must ulti-
                                                                                    mately be able to help operators get to zero emissions. That means seeing both
                                                                                    large and small leaks is important.
                                                                                 There is a wide range of new methane detection technologies. Airplanes and sat-
                                                                              ellites generally perform periodic surveys of sites. Aerial surveys see all equipment
                                                                              on a site, but generally only catch larger leaks. However, by covering large areas,
                                                                              aerial surveys provide important information about what emissions look like as a
                                                                              whole, including whether policy targets are being met.
                                                                                 Fixed, continuous monitors provide a high frequency of readings. This char-
                                                                              acteristic allows for reliable and rapid fixing of leaks. LongPath’s laser fencelines
                                                                              provide full site coverage, including of tall equipment like stick flares. While other
                                                                              continuous technologies vary in terms of site coverage, many are able to catch small
                                                                              leaks, and many have the ability to quantify leak rates.
                                                                                 The U.S. doesn’t currently have a regulatory system established to leverage quan-
                                                                              tification data. However, quantitative data provides many benefits. Quantification
                                                                              lets operators prioritize leaks for repair, gauge the cost-effectiveness of equipment
                                                                              replacements, tune equipment set points to lower emissions, track how equipment
                                                                              performs in different settings, and, ultimately, assess how well compliance measures
                                                                              work.
                                                                                 The LongPath network is a little like a methane radar. We use Nobel prize-win-
                                                                              ning frequency comb lasers that emit hundreds of thousands of colors of infrared
                                                                              light. We measure methane and other greenhouse gasses by detecting how much of

                                                                                1 Cusworth, D.H., Duren, R.M., Thorpe, A.K., Olson-Duvall, W., Heckler, J., Chapman, J.W.,
                                                                              Eastwood, M.L., Helmlinger, M.C., Green, R.O., Asner, G.P. and Dennison, P.E., 2021.
                                                                              Intermittency of large methane emitters in the Permian Basin. Environmental Science & Tech-




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                                                                              nology Letters, 8(7), pp. 567–573.




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                                                                                                                                  22
                                                                              that light is absorbed while it is traveling through the atmosphere. The laser is
                                                                              tower-mounted, and each tower covers 20 square miles, measuring emissions on a
                                                                              site-by-site basis for customers within the purview. The ability to provide broad-
                                                                              scale network style coverage means that there is a very low barrier to entry for
                                                                              monitoring all types of facilities including, importantly, marginal well sites.2,3
                                                                                 Going back to those pillars of advanced monitoring: LongPath provides contin-
                                                                              uous, quantitative emissions data to customers in real-time; our data provides full
                                                                              coverage of all equipment on site; and we have a very sensitive ability to see leaks—
                                                                              10 to 1000 times more sensitive than aerial and satellite technologies. Importantly,
                                                                              the tech is proven through extensive 3rd-party blind testing at test sites 4 and in
                                                                              the field, and we have made that data publicly available.5,6
                                                                                 I’d like to offer 4 themes for methane detection in emerging policy, differentiated
                                                                              markets, and industry adoption:
                                                                                 1. Methane monitoring reduces emissions, saves costs for operators, drives energy
                                                                                     efficiencies for the market (extending all the way to the ratepayer), and creates
                                                                                     jobs. LongPath has tripled in size in the last year, with new jobs ranging from
                                                                                     field technicians in West Texas to software engineers working remotely across
                                                                                     the U.S.
                                                                                 2. The U.S. is the world leader in methane monitoring technologies. If we recog-
                                                                                     nize the aligned incentives of policy makers, climate advocates and industry,
                                                                                     then U.S. gas can also become the cleanest in the world. To accomplish this,
                                                                                     policies and regulations should encourage operators to use new technologies
                                                                                     and also plan for quantification and performance-based metrics. EPA rules
                                                                                     should include new technologies in a matrix that allows for technology-neutral
                                                                                     choices by operators. SEC rules should require measurements, not outdated in-
                                                                                     ventories. And responsibly sourced gas standards should preclude green-
                                                                                     washing by driving stringency, transparency and quality in monitoring.
                                                                                 3. The federal government should invest in the creation of independent third-
                                                                                     party bodies to create standards for certifying the capabilities of new alter-
                                                                                     native technologies.
                                                                                 4. Finally, continuous monitoring is inexpensive and more than pays for itself
                                                                                     through increased efficiencies for the oil and gas industry. Reduced costs and
                                                                                     revenue retention for operators occur in two ways: by fixing leaks and equip-
                                                                                     ment malfunctions, and by providing real-time feedback on operations. Not to
                                                                                     mention the co-benefits of cleaner air, a more stable climate, jobs creation and
                                                                                     American leadership in environmental standards and technological innovation.
                                                                                     As my colleague Greg Rieker said two weeks ago in testimony to the House
                                                                                     Science Committee, we can outfit the Permian Basin for continuous, quan-
                                                                                     titative methane emissions monitoring for less than the cost of 20–30 miles of
                                                                                     interstate highway, or, as he put it, for less than the cost of the last James
                                                                                     Bond movie.
                                                                              Summary Information on LongPath Technologies
                                                                                The LongPath system is a fixed-location continuous monitoring system. The
                                                                              LongPath monitoring system employs dual frequency comb spectrometer (DCS) tech-
                                                                              nology with a detection range of up to 5 km. The LongPath system is capable of
                                                                              continuously monitoring multiple facilities via a single installation of a centralized
                                                                              tower from which the laser light source is generated. The high site coverage of a
                                                                              single reading, combined with high frequency of data collection and low detection
                                                                              threshold, classify this technology as ‘‘true continuous.’’ The LongPath system em-
                                                                              ploys a rigorous system of quality control checks to ensure incoming data is valid.
                                                                              With this data, the LongPath system is capable of accurately quantifying emission
                                                                              rates with a detection and quantification level of 0.2 kg/hr. Time-to-detect of emis-
                                                                              sion from leak start to leak detection for sustained emissions ranges from several
                                                                              minutes to less than one day.

                                                                                 2 Bowers, Richard L. Quantification of Methane Emissions from Marginal (Low Production
                                                                              Rate) Oil and Natural Gas Wells. United States: N. p., 2022. Web. doi:10.2172/1865859.
                                                                                 3 Omara, M., Zavala-Araiza, D., Lyon, D.R., Hmiel, B., Roberts, K.A. and Hamburg, S.P., 2022.
                                                                              Methane emissions from U.S. low production oil and natural gas well sites. Nature communica-
                                                                              tions, 13(1), pp. 1–10.
                                                                                 4 Methane Emissions Technology Evaluation Center (METEC): https://energy.colostate.edu/metec/
                                                                                 5 Alden, C. B., Coburn, S., Wright, R. J., et al. (2019). Single-blind quantification of natural
                                                                              gas leaks from 1 km distance using frequency combs. Environmental Science & Technology,
                                                                              53(5), 2908–2917. https://doi.org/10.1021/acs.est.8b06259
                                                                                 6 Coburn, S., Alden, C. B., Wright, R., et al. (2020). Long distance continuous methane emis-
                                                                              sions monitoring with dual frequency comb spectroscopy: deployment and blind testing in com-




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                                                                              plex emissions scenarios. https://arxiv.org/abs/2009.10853




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                                                                                                                                    23
                                                                                      LongPath’s DCS technology was developed at the National Institute of Standards
                                                                                    and Technology (NIST) and the University of Colorado Boulder and was transitioned
                                                                                    for field use and oil and gas monitoring by LongPath’s founders at the University
                                                                                    of Colorado under the Department of Energy’s ARPA–E MONITOR program. Open-
                                                                                    path, laser-based DCS measurements rely on frequency combs, a specialized class
                                                                                    of lasers that output hundreds of thousands of stable, discrete wavelength elements
                                                                                    or ‘‘comb teeth’’; an innovation that garnered the Nobel Prize at the University of
                                                                                    Colorado in 2005. DCS leverages these properties to enable spectroscopic measure-
                                                                                    ments at an unprecedented combination of spectral bandwidth (>100 nm), resolution
                                                                                    (<2x10-3 nm) and signal-to-noise ratio, providing precise and accurate absorption
                                                                                    spectra that yield high-fidelity, multi-species measurements.7,8
                                                                                      The LongPath system is composed of a 50-foot-tall retractable tower on an ap-
                                                                                    proximately 8-foot square base, where a field hardened control cabinet houses
                                                                                    LongPath’s proprietary laser spectrometer and computing and control systems. A
                                                                                    telescope, which emits the laser light and receives (detects) the reflected, return
                                                                                    laser light, sits at the top of the tower. The control cabinet, tower, and an anemom-
                                                                                    eter are all co-located at a central node. Retroreflectors are installed on and/or
                                                                                    around each monitored area and return emitted laser light to the transceiver.




                                                                                      Measurements are coupled to an atmospheric model and methane source sizing/
                                                                                    localization inversion framework. LongPath positions laser beams to create a
                                                                                    fenceline around each monitored area and measures plumes as they cross the
                                                                                    beamline. The sensor geometry for LongPath is not a single point in space, but, in-
                                                                                    stead, an integrated line (pathway) through space between the telescope head and
                                                                                    the retroreflective mirror (and back). LongPath’s full fenceline attribute results in
                                                                                    high spatial coverage of the monitored area with each reading that is taken under
                                                                                    a wide range of wind directions.




                                                                                      7 Rieker, G. B., Giorgetta, F. R., Swann, W. C., Kofler, J., Zolot, A. M., Sinclair, L. C., . . .

                                                                                    Newbury, N. R. (2014). Frequency-comb-based remote sensing of greenhouse gases over kilo-
                                                                                    meter air paths. Optica, 1(5), 290–298. https://doi.org/10.1364/OPTICA.1.000290




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                                                                                      8 Coburn, S., Alden, C. B., Wright, et al., (2018). Regional trace-gas source attribution using

                                                                                    a field-deployed dual frequency comb spectrometer. Optica, 5(4), 320.
                                                                                    https://doi.org/10.1364/OPTICA.5.000320




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                                                                                LongPath has demonstrated in blind testing (METEC and field) the ability to de-
                                                                              tect, locate, and quantify methane sources from individual facilities at rates of 0.2
                                                                              kg/hr over large regions.9,10,11,12




                                                                              Importance of Continuous Monitoring
                                                                                 The benefits of continuous monitoring are many and impact many stakeholders:
                                                                              neighboring communities in oil and gas production areas, the environment and glob-
                                                                              al communities grappling with a changing climate, and an industry that is working
                                                                              to reduce waste and cut emissions.
                                                                                 Methane emissions from oil and gas are intermittent and vary through time, at
                                                                              both producing and abandoned well sites,13,14 with intermittent emissions contrib-
                                                                              uting substantially to overall emissions. Continuous monitoring is therefore unpar-
                                                                              alleled in the value it provides. Snapshot monitoring approaches (OGI, aircraft, sat-
                                                                              ellite surveys) can’t provide adequate information for operators to mitigate, or often
                                                                              even detect, intermittent emissions. Continuous monitors can mitigate intermittent
                                                                              emissions by revealing temporal context about deviations from baseline rates, which
                                                                              can be linked with SCADA data for root cause analysis. Off-site diagnosis and even
                                                                              repair can often be accomplished. Further, continuous monitors don’t mistake inter-
                                                                              mittent emissions for persistent emissions, as can be the case for snapshot-in-time
                                                                              surveys (resulting in wasted OGI follow-ups).
                                                                                 The temporal context and coverage provided by continuous monitors also means
                                                                              that leak repairs can be immediately verified without site visits or OGI surveys.
                                                                              LongPath has found linked leaks that it took more than one attempt to repair—
                                                                              without continuous monitoring, the first repair would not have mitigated all emis-

                                                                                9 Rieker, G., et al., (2014). Frequency Comb-Based Remote Sensing of Greenhouse Gases over
                                                                              Kilometer Air Paths, Optica, 1, 290–298. https://doi.org/10.1364/OPTICA.1.000290
                                                                                10 Coburn, S., Alden, C. B., Wright, et al., (2018). Regional trace-gas source attribution using
                                                                              a field-deployed dual frequency comb spectrometer. Optica, 5(4), 320.
                                                                              https://doi.org/10.1364/OPTICA.5.000320
                                                                                11 Alden, C. B., Ghosh, S., Coburn, S., et al. (2018). Bootstrap inversion technique for atmos-
                                                                              pheric trace gas source detection and quantification using long open-path laser measurements.
                                                                              Atmospheric Measurement Techniques, 11(3), 1565–1582. https://doi.org/10.5194/amt-11-1565-2018
                                                                                12 Alden, C. B., Coburn, S., Wright, R. J., et al. (2019). Single-blind quantification of natural
                                                                              gas leaks from 1 km distance using frequency combs. Environmental Science & Technology,
                                                                              53(5), 2908–2917. https://doi.org/10.1021/acs.est.8b06259
                                                                                13 Johnson and Heltzel, ‘‘On the Long-Term Temporal Variations in Methane Emissions from
                                                                              an Unconventional Natural Gas Well Site.’’
                                                                                14 Riddick et al., ‘‘Variability Observed over Time in Methane Emissions from Abandoned Oil




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                                                                              and Gas Wells.’’




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                                                                                                                                   25
                                                                              sions, and the operator wouldn’t have known that other problems persisted, despite
                                                                              OGI follow-up.
                                                                                Continuous monitoring is highly scalable. With modest capital investment, around
                                                                              1000 LongPath sensors could provide cost-effective continuous monitoring for most
                                                                              of the Permian Basin of West Texas and Southeastern New Mexico. Already,
                                                                              LongPath is continuously monitoring more than 230,000 acres in the DJ, Anadarko,
                                                                              Delaware and Midland basins. Once LongPath’s networked infrastructure is in
                                                                              place, any site in the area can be quickly and cost-effectively subscribed. This in-
                                                                              cludes orphaned and marginal wells, which LongPath can monitor, quantify and
                                                                              prioritize for plugging at a very low cost compared with other methods.
                                                                                Finally, and most importantly, continuous monitoring affords rapid repair, such
                                                                              that cumulative emissions to the atmosphere are tens to hundreds of times lower
                                                                              than survey approaches can provide. The figure below is based on a real leak miti-
                                                                              gated by LongPath; a stuck dump valve that was identified and repaired in 2 days,
                                                                              resulting in a cumulative loss to the atmosphere of 300 Mcf. A bi-monthly or quar-
                                                                              terly survey might not have discovered the leak for 2–3 months, which would have
                                                                              resulted in some 30–50 times higher cumulative emissions emitted to the atmos-
                                                                              phere. The difference in gas lost between continuous monitoring and a theoretical
                                                                              quarterly survey would have been 13,500 Mcf, or roughly 10.4 t. At a (currently
                                                                              below-market) value of $3.25/Mcf, a loss of 13,800 Mcf is roughly $44,850 over 3
                                                                              months. These losses dwarf the cost of the monitoring itself (and for many years)—
                                                                              a clear proof point that continuous monitoring is cost effective. The social cost of
                                                                              methane ($1,800/t) would equate to $18,720 saved compared with quarterly LDAR.




                                                                                 The below LDAR-Sim model results 15 show expected emissions given a LongPath
                                                                              emissions mitigation program (‘‘P_LongPath’’, blue), a quarterly LDAR program
                                                                              (‘‘P_OGI’’, green, with efficacy matching Zimmerle et al.) 16 and no LDAR program
                                                                              (‘‘P_none’’, red). Interestingly, in this simulation, a super-emitter event occurs just
                                                                              following an OGI visit. While this would seem to be a rare event, LongPath has doc-
                                                                              umented occurrences of this scenario in customer monitoring. In periods of both nor-
                                                                              mal operations and during a fugitive event, LongPath’s overall emissions reductions
                                                                              are substantially better than quarterly OGI.




                                                                                   15 Highwood Emissions Management, January 2022.
                                                                                16 Zimmerle et al., ‘‘Detection Limits of Optical Gas Imaging for Natural Gas Leak Detection




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                                                                              in Realistic Controlled Conditions.’’




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                                                                              EPA and Continuous Monitoring as an Alternative Means of Compliance
                                                                                 LongPath has provided to EPA a detailed and complete work practice and frame-
                                                                              work for the inclusion of LongPath and other forms of continuous monitoring in the
                                                                              EPA’s rule as an alternative means of compliance.
                                                                                 Separately, we are providing to EPA, together with a diverse group of stake-
                                                                              holders, including industry, NGOs and legal experts, a matrix table for compliance
                                                                              under different frequencies and detection thresholds that is entirely technology-neu-
                                                                              tral, paving the way for regulations that will not hinder either current or future
                                                                              technological innovations.
                                                                                 Accompanying each method (technology) used to meet a given portion of the ma-
                                                                              trix table will be: 1) technology-specific work practices, 2) details of method certifi-
                                                                              cation, and 3) response requirements for when emissions exceed stated thresholds.
                                                                              Elements of a Framework Provided to EPA by LongPath
                                                                                LongPath provided a written response to all questions posed by EPA in the draft
                                                                              language published in November. These questions formed the EPA’s pathway for in-
                                                                              clusion of continuous monitoring as a compliance method in the final rule.
                                                                                In addition to providing answers to the EPA’s prompts, LongPath also outlined
                                                                              a specific framework for monitoring and response requirements that suit the
                                                                              LongPath technology class. No other technologies operate in the same way as
                                                                              LongPath, so we currently stand as the only C-Open Path (Continuous-Open Path)
                                                                              technology type in our class. Nonetheless, it is incumbent upon EPA to create rules
                                                                              open to all technology classes, regardless of how unique, and the offered matrix ap-
                                                                              proach and generalized frameworks provide this ability.
                                                                                Despite the work practice and response requirements being specific to the C-Open
                                                                              Path technology class, the bulk of the framework is generalizable to include all con-
                                                                              tinuous monitoring platforms and the unique challenges posed by and solvable by
                                                                              continuous tech (e.g., the ability to characterize intermittent emissions and offer al-
                                                                              ternate response requirements than for persistent emissions).
                                                                              Next Steps: R&D Efforts Needed To Enable the EPA’s Proposed Regulations
                                                                                Formation of a neutral third party organization to: 1) set standards for testing
                                                                              of emissions detection work practices, 2) provide auditing of and testing of tech-
                                                                              nologies with stated work practices, and 3) provide a clearing house for certification
                                                                              and reports.
                                                                                The DOE and other federal institutions will be ideal venues for these efforts to
                                                                              be initiated and/or carried forward. Existing and new R&D dollars should be consid-
                                                                              ered for use in the development of the standards, certification practices and clear-
                                                                              inghouse for approved technologies.
                                                                                Ms. CASTOR. Thank you, Dr. Alden.
                                                                                Next, Ms. Smith, you are recognized for 5 minutes to provide
                                                                              your testimony. Welcome.
                                                                                                     STATEMENT OF SARAH ANN SMITH
                                                                                Ms. SMITH. Chair Castor, Ranking Member Graves, members of
                                                                              the Select Committee, thank you so much for inviting me to testify.
                                                                                My name is Sarah Smith. I am the Chief of Programs at Clean
                                                                              Air Task Force, a global nonprofit organization working to safe-
                                                                              guard against the worst impacts of climate change by catalyzing
                                                                              the rapid development and deployment of low-carbon energy and
                                                                              other climate-protecting technologies.
                                                                                I would like to emphasize three points.
                                                                                The world is warming rapidly, and serious impacts are here
                                                                              today. Simple solutions like finding and fixing plumes of methane
                                                                              at oil and gas sites can dramatically cut U.S. emissions and rep-
                                                                              resent the fastest way to slow warming while also limiting
                                                                              unhealthy air pollution and creating jobs. Strong EPA standards
                                                                              represent a key opportunity to accomplish this and should be final-
                                                                              ized this year.
                                                                                Whether it is severe storms, rising seas, deadly heat waves, or




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                                                                              felt today. And recent reports from the Intergovernmental Panel on
                                                                              Climate Change make it very clear that, if emissions continue,
                                                                              these impacts will get much worse in the coming years.
                                                                                 Methane is a key culprit, responsible for about half a degree of
                                                                              the 1 degree Celsius of warming we have already experienced. But
                                                                              methane is also a key opportunity. Its high warming potential dur-
                                                                              ing its relatively short lifetime in Earth’s atmosphere provides us
                                                                              with our biggest chance to slow warming over the next few dec-
                                                                              ades.
                                                                                 Reducing methane is like a handbrake for our warming planet,
                                                                              which is currently hurdling toward a much hotter period to which
                                                                              humans may not be able to quickly adapt.
                                                                                 Pulling this handbrake while we tackle carbon dioxide, too, is es-
                                                                              sential, both to limit direct impacts on people and, importantly, to
                                                                              limit the acceleration of harmful feedback loops, where warming
                                                                              causes more warming, such as the rapidly disappearing Arctic sea
                                                                              ice. The darker surfaces left behind after the ice melts, they absorb
                                                                              more sunlight, just like removing a natural canopy that exposes a
                                                                              dark parking lot in the summer, creating more warming—a feed-
                                                                              back loop.
                                                                                 The good news is, we can cut methane emissions very rapidly
                                                                              from oil and gas today just by using technologies and practices that
                                                                              are already included in standards on the books in leading states
                                                                              like New Mexico and Colorado. EPA can cut oil and gas methane
                                                                              emissions by 65 percent in just a few years. These solutions do not
                                                                              require rocket science, just simple, sound plumbing.
                                                                                 The standards EPA should put in place would require the oil and
                                                                              gas industry to regularly check their equipment for leaks using
                                                                              modern instruments and to replace equipment that is designed to
                                                                              dump methane gas into the air with modern, clean equipment that
                                                                              doesn’t. It is that simple.
                                                                                 EPA’s proposal last fall would go a long way to accomplish these
                                                                              reductions, but it needs to be strengthened. The methane emissions
                                                                              reductions program in the House-passed Build Back Better Act
                                                                              would serve as an effective and efficient complement to the EPA
                                                                              regulations because it would go into effect more quickly for existing
                                                                              sources, incentivizing the highest-emitting operators to rapidly in-
                                                                              vest in cleaner equipment.
                                                                                 These policies would lead to dramatic cuts in methane from U.S.
                                                                              oil and gas—nearly 8 million tons per year of methane. And, as Ms.
                                                                              Tomcik underscored, these policies would cut pollution beyond
                                                                              methane as well—millions of tons of other ozone smog precursors
                                                                              and over 100,000 tons of air toxics, like carcinogenic benzene, every
                                                                              year.
                                                                                 Finally, strong EPA standards would create more than 60,000
                                                                              high-paying jobs, according to CATF estimates, in the oil and gas
                                                                              industry, manufacturing, and other sectors. These policies can dra-
                                                                              matically cut U.S. methane emissions by 2030 and build on global
                                                                              momentum to address methane emissions, as seen by the Global
                                                                              Methane Pledge, led by the United States and the European Union.
                                                                                 The U.S. has shown great leadership on methane around the
                                                                              world and can back up that leadership with strong action to cut




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                                                                              methane here at home.




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                                                                                Methane emissions from oil and gas are wreaking havoc on our
                                                                              planet and our communities, and we have the solutions in hand to
                                                                              rein them in. We must use them now.
                                                                                Thank you.
                                                                                [The statement of Ms. Smith follows:]
                                                                                                             Testimony of Sarah Smith
                                                                                                      Chief of Programs, Clean Air Task Force
                                                                                                      Before the U.S. House of Representatives
                                                                                                       Select Committee on the Climate Crisis
                                                                                                  Hearing on ‘‘Cutting Methane Pollution:
                                                                                      Safeguarding Health, Creating Jobs, and Protecting Our Climate’’
                                                                                                                        June 24, 2022
                                                                                 Madam Chair, Ranking Member, and Distinguished Members of the Committee:
                                                                                 My name is Sarah Smith and I am the Chief of Programs and former Director
                                                                              of Super Pollutants at Clean Air Task Force (CATF), an environmental organization
                                                                              founded in 1996. CATF is a global nonprofit organization working to safeguard
                                                                              against the worst impacts of climate change by catalyzing the rapid development
                                                                              and deployment of low-carbon energy and other climate-protecting technologies.
                                                                              With over 25 years of internationally recognized expertise on climate policy and a
                                                                              fierce commitment to exploring all potential solutions, CATF is a pragmatic, non-
                                                                              ideological advocacy group with the bold ideas needed to address climate change.
                                                                              CATF has offices in Boston, Washington D.C., and Brussels, with staff working vir-
                                                                              tually around the world. Thank you for the opportunity to be here today to testify.
                                                                                 Today I will share CATF’s thoughts on how reducing methane emissions from the
                                                                              oil and gas sector can provide crucial climate benefits, as well as help communities
                                                                              that surround oil and gas developments by reducing harmful pollution and creating
                                                                              jobs using technologies that are already mature and available today.
                                                                                 [1] Methane is a greenhouse gas that is much more potent that carbon dioxide,
                                                                                     and it is a primary driver of climate change. Addressing methane emissions,
                                                                                     particularly from the oil and gas industry, is a critical piece of the climate ac-
                                                                                     tion puzzle here in the United States and around the world.
                                                                                 The world stands on the brink of irreversible changes. As the Intergovernmental
                                                                              Panel on Climate Change (‘‘IPCC’’) put it in its Sixth Assessment Report (‘‘AR6’’):
                                                                              ‘‘Human influence has warmed the climate at a rate that is unprecedented in at
                                                                              least the last 2000 years.’’ 1 The impacts of this warming climate are hitting the
                                                                              most vulnerable populations the hardest, and efforts to adapt to our new climate
                                                                              reality are being outpaced by those impacts.2 As the scientific understanding of cli-
                                                                              mate change impacts has evolved, it has revealed that we can pass catastrophic tip-
                                                                              ping points much more suddenly or at lower temperatures than once thought.3 This
                                                                              means that the collapse of ice sheets or the loss of rainforests, and the resulting
                                                                              impacts on vulnerable populations, are likely much nearer than we thought.
                                                                                 Reducing emissions of methane, a potent greenhouse gas with a warming poten-
                                                                              tial over 80 times greater than that of carbon dioxide over a twenty-year period,4
                                                                              must play a crucial role in any rapid greenhouse gas mitigation. Because of its
                                                                              warming potency and atmospheric lifetime—which is much shorter than that of car-
                                                                              bon dioxide—establishing policies to quickly reduce methane emissions is the fastest
                                                                              way to slow the escalating rate of global warming, serving as a handbrake to slow
                                                                              the accelerating climate crisis. As of June 17, 2022, the U.S. has joined 119 other
                                                                              countries in pledging to reduce global methane emissions by 30 percent by 2030
                                                                              under the Global Methane Pledge.5

                                                                                1 IPCC, AR6 Working Group I (‘‘WGI’’), Summary for Policymakers 6 (2021),
                                                                              https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_SPM.pdf.
                                                                                2 IPCC, AR6 Working Group II (‘‘WGII’’), Summary for Policy Makers SPM–27–28 (2022), https://
                                                                              www.ipcc.ch/report/ar6/wg2/downloads/report/IPCC_AR6_WGII_SummaryForPolicymakers.pdf.
                                                                                3 IPCC, WGI, Technical Summary Box TS.9 (2021),
                                                                              https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_TS.pdf.
                                                                                4 IPCC, WGI, Full Report Table 7.15 (2021),
                                                                              https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf.
                                                                                5 Press Release, U.S.-EU Joint Press Release on the Global Methane Pledge Energy Pathway,
                                                                              U.S. Dep’t of State (June 17, 2022), https://www.state.gov/u-s-eu-joint-press-release-on-the-




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                                                                                 In the U.S., the most cost-effective way to achieve this is by reducing methane
                                                                              emissions from the oil and natural gas sector. The oil and natural gas sector, com-
                                                                              prised of the oil and natural gas production and natural gas processing, trans-
                                                                              mission and storage, and distribution segments, is the largest industrial source of
                                                                              methane emissions in the country, responsible for over 8 million tons in 2020, ac-
                                                                              cording to the U.S. Greenhouse Gas Inventory (‘‘GHGI’’).6 We know that this under-
                                                                              estimates the true scale of the problem as the current version of the GHGI fails to
                                                                              capture the emissions from super-emitters: infrequent but large emission events
                                                                              that have been documented in many independent studies to arise at oil and gas
                                                                              sites.7 CATF estimates the actual emissions to be approximately 12 million metric
                                                                              tons.8 Fortunately, solutions to reduce methane emissions from the oil and natural
                                                                              gas industry which are already being used in various jurisdictions can jumpstart the
                                                                              curbing of these emissions.
                                                                                 a. We have the solutions in hand to address the oil and natural gas methane
                                                                                    problem.
                                                                                 There are no technical barriers to rapidly reducing emissions from the oil and nat-
                                                                              ural gas industry. Relying on technologies and practices that are in use today, CATF
                                                                              has laid out a pathway by which regulatory standards—all based on regulations in
                                                                              place today—can reduce methane emissions from the industry by 65 percent relative
                                                                              to 2012 levels.9 The House-passed Build Back Better Act contains a complementary
                                                                              program, the Methane Emission Reduction Plan, to further reduce emissions to
                                                                              align with the industry’s ambition by assessing a charge on the methane emissions
                                                                              above a specified leak rate. Together, these two approaches provide two near-term,
                                                                              cost-effective solutions to address the industry’s methane emissions.
                                                                                 b. There are Solutions Required by Leading States Today That, if Used Nation-
                                                                                    wide, Would Reduce Oil and Natural Gas Methane Emissions to 65 Percent
                                                                                    Below 2012 Levels
                                                                                 Based on CATF’s calculations, the oil and natural gas industry emits 12 million
                                                                              metric tons (MMT) annually, which using EPA’s Greenhouse Gas Equivalency Cal-
                                                                              culator warms the climate in the decades after emissions as much as the carbon di-
                                                                              oxide emissions from 260 coal-fired power plants.10 Within the industry, those emis-
                                                                              sions primarily originate from: fugitive emissions (‘‘leaks’’) and other improper con-
                                                                              ditions; intentional venting and flaring; and outdated equipment that is designed to
                                                                              emit gas. Standards on the books today in leading states address each of these
                                                                              sources.
                                                                              Fugitive Emissions
                                                                                Emissions from leaks and other improper conditions occur when the mechanical
                                                                              processes or pieces of equipment at an oil or natural gas facility deteriorate or fail
                                                                              to operate in the intended manner, and these constitute the single largest source

                                                                                6 EPA, Greenhouse Gas Inventory Data Explorer,
                                                                              https://cfpub.epa.gov/ghgdata/inventoryexplorer/#allsectors/allsectors/allgas/econsect/current (last
                                                                              accessed June 21, 2022).
                                                                                7 David Lyon et al., Constructing a spatially resolved methane emission inventory for the
                                                                              Barnett Shale region, 49 Env’t Sci. Tech. 8147 (2015); Daniel Zavala-Araiza et al., Reconciling
                                                                              divergent estimates of oil and gas methane emissions, 112 Proc. Nat’l Acad. Sci. 15597 (2015);
                                                                              Daniel Zavala-Araiza et al., Super-emitters in natural gas infrastructure are caused by abnormal
                                                                              process conditions, 8 Nat. Commc’ns. 14012 (2017); Daniel Zimmerle et al., Methane emissions
                                                                              from the natural gas transmission and storage system in the United States, 49 Env’t Sci. Tech.
                                                                              9374 (2015); Mark Omara et al., Methane emissions from conventional and unconventional nat-
                                                                              ural gas production sites in the Marcellus Shale region, 50 Env’t Sci. Tech. 2099 (2016); Jeff
                                                                              Peischl. et al., Quantifying atmospheric methane emissions from Haynesville, Fayetteville, and
                                                                              northeastern Marcellus shale gas production regions, 120 J. of Geophysical Res.: Atmospheres
                                                                              2119 (2015); Dana Caulton et al., Importance of superemitter natural gas well pads in the
                                                                              Marcellus Shale, 53 Env’t Sci. Tech. 4747 (2019); Robertson et al., New Mexico Permian Basin
                                                                              measured well pad methane emissions are a factor of 5–9 times higher than U.S. EPA estimates,
                                                                              54 Env’t Sci. Tech. 13926 (2020); Yuzhong Zhang et al., Quantifying methane emissions from
                                                                              the largest oil-producing basin in the United States from space, 6 Sci. Advances 5120 (2020);
                                                                              David Lyon et al., Concurrent variation in oil and gas methane emissions and oil price during
                                                                              the COVID–19 pandemic, 21 Atmospheric Chemistry and Physics 6605 (2021); Ramón Alvarez,
                                                                              Assessment of methane emissions from the U.S. oil and gas supply chain, 361 Science 186 (2018).
                                                                                8 CATF, Reducing Methane from Oil and Gas: A Path to a 65% Reduction in Sector Emissions
                                                                              (Dec. 2020), https://cdn.catf.us/wp-content/uploads/2020/04/21092556/Path_to_65pc_OG_reduction-
                                                                              Dec2020_update.pdf (‘‘65 Percent Memo’’).
                                                                                9 65 Percent Memo at 8.
                                                                                10 EPA, Greenhouse Gas Equivalencies Calculator (last updated Mar. 2022),




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                                                                              of methane emissions within the oil and natural gas sector. Based on CATF’s anal-
                                                                              ysis, fugitive emissions accounted for 5.6 MMT of methane emissions in 2020. Most
                                                                              of these emissions arise from the abnormal process emissions and equipment fail-
                                                                              ures that create super emitters.
                                                                                 To effectively reduce these fugitive emissions, the leak or problem must be de-
                                                                              tected as quickly as possible, and then rapidly fixed. Leak detection and repair
                                                                              (‘‘LDAR’’) programs can be used to find and fix everything—from a simple leaking
                                                                              valve to super-emitters. The strength of a LDAR program, and thus its potential to
                                                                              reduce emissions, depends upon the capabilities of the detection technology, the fre-
                                                                              quency an operator deploys it to detect leaks, and the scope of components that are
                                                                              inspected.
                                                                                 A number of technologies to detect methane emissions are well-established, while
                                                                              newer powerful techniques have advanced rapidly in recent years. The rapidly grow-
                                                                              ing list of LDAR technologies 11 can be divided into two groups: close-range tech-
                                                                              nologies and screening technologies.
                                                                                 Close-range technologies are handheld instruments that can diagnose individual
                                                                              leaks on a component-by-component basis, such as optical gas imaging (‘‘OGI’’) cam-
                                                                              eras, which produce an infrared light image in real time, making a normally invis-
                                                                              ible pollution stream visible to our eyes. Older handheld detectors are also used to
                                                                              detect hydrocarbon leaks. Close-range technologies are extremely useful to pinpoint
                                                                              exactly where individual leaks are, both big and small, so they can be fixed.
                                                                                 Screening technologies can quickly monitor larger areas, typically at a detection
                                                                              limit greater than close-range technologies. This means that screening technologies
                                                                              are only able to detect larger sources. Examples of screening technologies include
                                                                              instruments mounted on aircraft, drones, ground vehicles, and satellites, in addition
                                                                              to fixed monitors or measurement devices which continuously measure methane con-
                                                                              centrations to monitor for higher levels indicating an increase in emissions.
                                                                                 These innovative technologies can bring the cost of monitoring sites for emissions
                                                                              down and offer the opportunity to find emitters faster, or perhaps much faster—es-
                                                                              pecially for large super-emitters. In proposed regulations, EPA and other regulators
                                                                              have required operators to use close-range technologies such as OGI, which have
                                                                              long been proven to be cost-effective. Concurrently, EPA and other regulators are
                                                                              also working with operators and technology providers to evaluate approaches for in-
                                                                              novative screening technologies to be used in alternative monitoring approaches
                                                                              that will further reduce emissions from leaks and improper emissions. Leading
                                                                              states have recognized that frequent inspection for emissions is the key to effective
                                                                              methane reduction. Colorado, which has years of experience in reducing emissions
                                                                              with LDAR inspections, requires all new and modified sites to be inspected month-
                                                                              ly.12 Some large existing sites are inspected monthly. Most operators in Colorado
                                                                              use optical gas imaging, but other technologies (including advanced technologies ap-
                                                                              proved by the State) are allowed. New Mexico has very recently approved rules that
                                                                              require operators to regularly inspect all sites, including wellpads with very low-
                                                                              producing wells.13
                                                                              Routine Flaring of Associated Gas and Intentional Venting
                                                                                 The oil and gas industry is currently venting and flaring huge amounts of associ-
                                                                              ated natural gas from oil wells. While there are many reasons that operators flare
                                                                              gas, the vast majority of gas flaring occurs when operators do not have the infra-
                                                                              structure (such as gathering pipelines) in place to handle natural gas at oil well
                                                                              sites. This scenario is referred to as routine flaring. Routine venting from oil wells—
                                                                              simply dumping the gas produced along with the oil into the air—is even worse, be-
                                                                              cause it releases all the methane and other pollutants directly into the air. But rou-
                                                                              tine flaring is also extremely harmful. In the U.S., routine flaring wasted enough
                                                                              gas in 2019 to heat over 8.5 million homes.14 Routine flaring is a source of huge
                                                                              amounts of harmful pollution, including vast amounts of carbon dioxide equivalent

                                                                                11 According to at least one report, there are over 100 distinct methane measurement tech-
                                                                              nologies. See Highwood Emission Management, Technical Report: Leak detection methods for
                                                                              natural gas gathering, transmission, and distribution pipelines 20 (2022), https://
                                                                              highwoodemissions.com/wp-content/uploads/2022/04/Highwood_Pipeline_Leak_Detection_2022.pdf.
                                                                                12 5 Colo. Code Regs. § 1001–9 D.II.E.4.e.(ii).
                                                                                13 N.M. Code R. § 20.2.50.116 (approved May 27, 2022, publication pending).
                                                                                14 Flare volume [The World Bank, 2022 Global Gas Flaring Tracker Report (2022), https://
                                                                              thedocs.worldbank.org/en/doc/1692f2ba2bd6408db82db9eb3894a789-0400072022/original/2022-Global-
                                                                              Gas-Flaring-Tracker-Report.pdf]; Gas per household calculated from EIA data [EIA, Natural Gas
                                                                              Consumption by End Use, https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_nus_a.htm (last accessed
                                                                              June 21, 2022); EIA, Number of Natural Gas Consumers, https://




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                                                                              to driving 17 million gasoline-powered vehicles for a year.15 Natural gas flares con-
                                                                              sistently malfunction or fail to completely burn gas (or go out entirely), leading to
                                                                              huge amounts of methane emissions. A recent study by Environmental Defense
                                                                              Fund found that in the Permian Basin region—which accounts for 46 percent of flar-
                                                                              ing in the U.S.—10 percent of flares were found to be malfunctioning and 5 percent
                                                                              were completely unlit.16 Finally, flares also produce large amounts of harmful pol-
                                                                              lutants such as black carbon soot, which directly impacts the health of people in
                                                                              communities near oil production sites.
                                                                                 Routine flaring has been recognized as wasteful for many years. Many oil pro-
                                                                              ducers avoid routine flaring entirely by ensuring that they have adequate infra-
                                                                              structure in place to handle all the natural gas a well will produce before the well
                                                                              is completed. However, other producers have track records of continuing to flare
                                                                              large volumes of gas for long periods of time perpetuating the industry’s flaring
                                                                              problems. Taking action to address this problem, leading states have now banned
                                                                              routine flaring entirely. New Mexico, one of the states with high levels of flaring
                                                                              in the Permian Basin, banned routine flaring with new rules in 2021.17 Colorado
                                                                              enacted rules prohibiting routine flaring in 2020.18 New Mexico’s rules will also re-
                                                                              quire operators to ramp down other types of flaring (such as that done for mainte-
                                                                              nance activities) over the next several years.19
                                                                                 In the standards EPA proposed last year, venting from oil wells would be prohib-
                                                                              ited (a valuable measure given the harm from venting), but routine flaring would
                                                                              not be prohibited if a wellsite did not have adequate pipeline capacity to take away
                                                                              the gas from the wells at the site. This is an enormous exception since this is the
                                                                              very reason most routine flaring occurs. If clear standards prohibiting routine flar-
                                                                              ing are put in place, oil producers will invest in the capacity they need to get gas
                                                                              from wells to market so flaring is not required. If those standards have loopholes,
                                                                              as is the case in EPA’s proposal, operators will continue to wastefully and harmfully
                                                                              flare. EPA should follow the precedent set by New Mexico and Colorado and prohibit
                                                                              oil producers from harmful and wasteful routine venting and flaring of gas.
                                                                              Outdated Equipment
                                                                                Another large source of methane emissions comes from industry’s reliance on out-
                                                                              dated equipment that is designed to release gas into the air. Examples of such
                                                                              equipment are: tanks for storing crude oil and hydrocarbons that are designed to
                                                                              release vapors as they evaporate into the air, rather than control those emissions;
                                                                              automated equipment which uses pressurized natural gas to pump liquids or to
                                                                              open and shut valves, releasing natural gas into the atmosphere every single time
                                                                              the equipment operates (and often when not operating); and compressors with non-
                                                                              hermetic seals on moving parts that are designed to vent harmful gas into the air.
                                                                                These types of outdated equipment emit millions of tons of methane a year. In
                                                                              each case, technologies exist today to greatly reduce or eliminate emissions from
                                                                              these types of equipment, and in fact standards on the books today in leading states
                                                                              require the use of lower- or non-emitting equipment. For example, both Colorado 20
                                                                              and New Mexico 21 require operators to replace automated gas-driven valve control-
                                                                              lers with non-emitting equipment, such as valve controllers powered by electricity
                                                                              or compressed air. Colorado,22 Pennsylvania,23 and New Mexico 24 all have good
                                                                              standards in place for storage tanks, ensuring that emissions from the tanks are
                                                                              controlled to a low level.
                                                                                The standards proposed by EPA in 2021 address some types of outdated equip-
                                                                              ment (such as automated valve controllers) very well, while the treatment of other
                                                                              types (such as liquids storage tanks) is inadequate and far behind the standards in

                                                                                15 EPA, Greenhouse Gas Equivalencies Calculator (last updated Mar. 2022),
                                                                              https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator#results.
                                                                                16 Permian Map, Flaring Aerial Survey Results, Env’t Def. Fund,
                                                                              https://www.permianmap.org/flaring-emissions/ (last accessed June 21, 2022).
                                                                                17 N.M. Code R. § 19.15.27.8 (Lexis, 2021).
                                                                                18 Colorado Oil & Gas Conservation Commission, Rule 903 (2021)
                                                                              https://cogcc.state.co.us/documents/reg/Rules/LATEST/900%20Series%20-
                                                                              %20Environmental%20Impact%20Prevention.pdf.
                                                                                19 N.M. Code R. § 19.15.27.9 (Lexis, 2021).
                                                                                20 5 Colo. Code Regs § 1001–9 D.III.C.4.c.
                                                                                21 N.M. Code R. § 20.2.50.122 (approved 27 May 2022, publication pending).
                                                                                22 5 Colo. Code Regs. § 1001–9 D.II.C.1.c.
                                                                                23 Pennsylvania Dep’t of Env’t Protection, Pennsylvania General Plan Approval And/Or Gen-
                                                                              eral Operating Permit, GP–5A, Section E,
                                                                              http://www.depgreenport.state.pa.us/elibrary/GetFolder?FolderID=36120.




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                                                                                24 N.M. Code R. § 20.2.50.123 (approved 27 May 2022, publication pending).




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                                                                              place for those types of equipment in leading states. CATF has provided EPA with
                                                                              detailed comments about how EPA should improve those provisions.25
                                                                              Benefits of Nationwide Standards Based on Policies in Place in Leading
                                                                                   States
                                                                                 Using a model of national methane emissions from the oil and gas inventory built
                                                                              by CATF that uses EPA’s Greenhouse Gas Inventory and adjusts for emissions from
                                                                              super emitters as estimated by Alvarez et al.,26 and using projections from the U.S.
                                                                              Energy Information Administration (EIA) to scale ‘‘potential emissions,’’ CATF has
                                                                              projected methane emissions for future years assuming that specific regulatory
                                                                              standards are put in place. The documented benefits of each standard are used to
                                                                              quantify the benefits of the standard in the model. Based on this model, we see that
                                                                              nationwide EPA standards for methane emissions from new, modified, and existing
                                                                              sources can reduce methane emissions from the industry by 65 percent.
                                                                                   i. The Environmental Protection Agency Has the Ability to Regulate Methane
                                                                                      Emissions from the Oil and Natural Gas Sector
                                                                                 As Congress has recognized, the EPA has clear authority under section 111 of the
                                                                              Clean Air Act to regulate methane for the oil and natural gas sector.27 EPA first
                                                                              promulgated methane standards for new and modified sources in 2016.28 But there
                                                                              are currently no nationwide standards for most existing sources: at present, sources
                                                                              that will account for about 60 percent of projected emissions in 2025 are not subject
                                                                              to any nationwide standard.29 Such standards are an essential component to have
                                                                              in place for reliable reductions, as they are federally enforceable and would protect
                                                                              the health of people living near oil and gas production sites.
                                                                                 In November 2021, EPA proposed updated standards for new and modified
                                                                              sources and emissions guidelines for existing sources.30 This proposal has several
                                                                              strong aspects, such as requiring operators to eliminate emissions from all gas-driv-
                                                                              en automatic valve controllers. However, the standards proposed for other emissions
                                                                              sources are not as strong, and lag well behind the standards on the books and im-
                                                                              plemented in leading states. Deep reductions in methane pollution from this indus-
                                                                              try are needed, so EPA must strengthen the standards and guidelines it proposes
                                                                              in the upcoming supplemental proposal.31
                                                                                 One key improvement EPA must make is to require frequent and regular LDAR
                                                                              inspections for all sources, without exceptions, to reduce fugitive emissions by 80 to
                                                                              90 percent. Additionally, EPA must follow in the steps of New Mexico and Colorado
                                                                              and ban the wasteful practice of routine flaring. As described in more detail above
                                                                              in section b, CATF has shown that those changes and others can reduce the sector’s
                                                                              emissions by 65 percent in a cost-effective way.
                                                                                   ii. The House Has a Plan to Address Many of the Industry’s Methane Emissions.
                                                                                 An important complementary tool to the EPA source-specific standards is the
                                                                              Build Back Better Act’s Methane Emissions Reduction Program (‘‘MERP’’), which
                                                                              would assess a charge on methane emissions from the oil and natural gas sector.32
                                                                              In general, this program would establish a charge levied to operators that would be
                                                                              assessed based on the methane emissions reported to EPA’s Greenhouse Gas Re-
                                                                              porting Program (GHGRP) if they are above a threshold established by the legisla-
                                                                              tion. An operator would calculate the natural gas production in each basin, the vol-
                                                                              ume of methane it reported under the GHGRP for that basin, and if the methane
                                                                              emissions were to exceed the threshold leak rate, the operator would pay the charge
                                                                              on those emissions.
                                                                                 This program would incentivize larger operators to reduce emissions quickly and
                                                                              efficiently. If operators emit at levels below the threshold level, they pay no fee. For

                                                                                25 Clean Air Task Force, et al., Comments on Standards of Performance for New, Recon-
                                                                              structed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural
                                                                              Gas Sector Climate Review (Jan. 31, 2022),
                                                                              https://cdn.catf.us/wp-content/uploads/2022/05/11104718/Joint-Environmental-Comments-on-
                                                                              Proposed-OOOOb-and-OOOOc.pdf.
                                                                                26 Ramón Alvarez, Assessment of methane emissions from the U.S. oil and gas supply chain,
                                                                              361 Science 186 (2018).
                                                                                27 42 USC § 7411(b); H. Rep. 117–64.
                                                                                28 40 C.F.R. § 60.5365a et seq.
                                                                                29 Based on CATF model projection of oil and gas methane emissions (based on EPA’s GHGI
                                                                              and EIA projections) and estimates of proportion of current and future equipment that will be
                                                                              subject to NSPS Subparts OOOO and OOOOa.
                                                                                30 86 Fed. Reg. 63,110 (Nov. 15, 2021).
                                                                                31 See 86 Fed. Reg. at 63,115 (announcing plans to issue a supplemental proposal).




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                                                                                32 Build Back Better Act, H.R. 5376, 117th Congress (2022).




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                                                                              oil and gas producers, the threshold level of emissions is a level targeted by the Oil
                                                                              and Gas Methane Partnership, a group of leading producers. Because there are
                                                                              many cost-effective ways to reduce emissions at costs below the amount of potential
                                                                              fees, operators with emissions above the threshold level will rapidly do so. The fee
                                                                              level ($1500 per metric ton of methane after full implementation of the legislation)
                                                                              is well below the societal damage caused by emitting a metric ton of methane.33
                                                                                 The MERP represents a valuable complement to the regulations EPA is devel-
                                                                              oping. First, any reductions required by EPA’s rules will reduce the fees operators
                                                                              will need to pay under the MERP. For some operators, especially those who start
                                                                              with relatively low emissions given the amount of gas they produce, the reductions
                                                                              required by the EPA rules will eliminate the MERP fee. But, given the long lead
                                                                              time required for EPA’s rules to be implemented, the MERP’s more immediate ap-
                                                                              plicability will incentivize more rapid adoption of the established technologies avail-
                                                                              able to operators.
                                                                                 Second, the MERP’s emissions-based fee will incentivize ongoing efforts for miti-
                                                                              gation beyond that achieved by the EPA standards. The EPA standards that we ad-
                                                                              vocate for would not eliminate methane emissions from the oil and gas sector—op-
                                                                              portunities will still exist for further reductions. The MERP will focus efforts on
                                                                              finding innovative ways to further reduce emissions. This will also help drive fur-
                                                                              ther innovation and growth in the methane emissions reduction industry.
                                                                                 Notably, only operators emitting above the GHGRP reporting threshold (25,000
                                                                              metric tons per year of CO2 equivalent) would need to pay any fees under the
                                                                              MERP; smaller operators would be entirely exempt.
                                                                                   [2] Implementing these solutions will provide welcome and much-needed benefits
                                                                                       to communities and populations around oil and natural gas development.
                                                                                Strengthening and finalizing EPA’s methane standards and emission guidelines
                                                                              and passing the MERP provisions of the Build Back Better Act will provide impor-
                                                                              tant climate benefits, improve the health of communities and workers around oil
                                                                              and natural gas development, and add jobs. It’s a win-win-win.
                                                                              Climate Benefits
                                                                                Beyond the impacts that rapidly reducing methane has on decelerating the warm-
                                                                              ing rate, methane reductions provide significant value to society. Under the current
                                                                              EPA regulations and state policies in place,34 CATF estimates that the oil and nat-
                                                                              ural gas industry would emit 11.8 million metric tons of methane in 2025. Thus,
                                                                              by reducing methane emissions by 65 percent, after adjusting for the actual emis-
                                                                              sions from super emitters, would prevent over 7.8 million metric tons of methane
                                                                              emissions.35 Using the Interagency Working Group’s social cost of methane,36 these
                                                                              reductions would save society over $13 billion annually by 2025.
                                                                              Health Benefits
                                                                                 Methane emissions from oil and gas production have serious negative impacts on
                                                                              public health. Using publicly available data, research from Earthworks and the
                                                                              Fractracker Alliance indicates that over 17 million people live within a half-mile of
                                                                              oil and gas production, of whom nearly 6 million are people of color. Furthermore,
                                                                              3.1 million children attend the more than 12,000 schools located within half a mile
                                                                              of oil and gas production.37
                                                                                 Methane contributes to the formation of ground-level ozone, or smog, by reacting
                                                                              with sunlight in a photochemical reaction in the lower atmosphere. Other air pollut-
                                                                              ants are also co-emitted when methane is leaked or vented. These co-emitted pollut-
                                                                              ants include volatile organic compounds (VOCs), which are also smog-forming, as
                                                                              well as a variety of toxic hazardous air pollutants (HAPs). The oil and gas industry

                                                                                 33 Drew Shindell, The social cost of methane: theory and applications, 200 Faraday Discuss 429
                                                                              (2017).
                                                                                 34 See 40 C.F.R. Part 60, subpart OOOOa.
                                                                                 35 65 Percent Memo at 2, Table 1.
                                                                                 36 $1,700, based on a 3 percent average discount rate for the year 2025. See EPA, Regulatory
                                                                              Impact Analysis for the Proposed Standards of Performance for New, Reconstructed, and Modi-
                                                                              fied Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate
                                                                              Review, 3–11, Table 3–3 (October 2021),
                                                                              https://www.epa.gov/system/files/documents/2021-11/proposal-ria-oil-and-gas-nsps-eg-climate-
                                                                              review_0.pdf (‘‘Proposed Rule RIA’’).




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                                                                                 37 Oil & Gas Threat Map, https://oilandgasthreatmap.com (last accessed June 21, 2022).




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                                                                                                                                  34
                                                                              emitted 2,504 kt of ozone smog-forming volatile organic compounds (VOCs) in
                                                                              2017.38
                                                                                 Methane, VOC, and HAP emissions from the oil and gas industry are typically
                                                                              emitted as a mixture. This means that technological solutions which reduce meth-
                                                                              ane emissions will also significantly reduce emissions of VOCs and HAPs, providing
                                                                              critical public health benefits to vulnerable communities. A 65 percent reduction of
                                                                              methane emissions in line with what CATF has shown is possible by a nationwide
                                                                              implementation of solutions on the books in leading states right now would prevent
                                                                              2.3 million tons of VOCs and 165,000 tons of HAPs from being emitted each year.
                                                                                 Reducing methane and VOC emissions will directly reduce the health risks associ-
                                                                              ated with ground-level ozone. Epidemiologically derived research suggests that
                                                                              methane-induced changes in ground-level ozone levels can impact air quality,
                                                                              human health, and even agricultural productivity.39 Reducing methane emissions
                                                                              can therefore change ground-level ozone levels in ways that provide significant
                                                                              value to society, including reduced risks of adverse health impacts.
                                                                                 Scientific research has firmly established that exposure to ground-level ozone
                                                                              smog harms human health. Such harms include asthma, decreased lung function
                                                                              among healthy adults, increases in respiratory-related hospital admissions and
                                                                              emergency room visits, and premature death.40 Long-term exposure can be particu-
                                                                              larly severe: EPA has found that there is ‘‘likely to be a causal relationship between
                                                                              long-term exposure to [ozone] and respiratory effects.’’ 41
                                                                                 For vulnerable populations, exposure to ground-level ozone can be particularly
                                                                              harmful. Many studies have demonstrated that children with asthma lose some lung
                                                                              function and face worsened respiratory symptoms when exposed to ozone pollu-
                                                                              tion.42 Moreover, people with respiratory diseases or asthma, older adults, and peo-
                                                                              ple who are active outdoors (including outdoor workers) can face adverse respiratory
                                                                              effects.43 In total, ozone smog attributable to oil and gas contributes to more than
                                                                              750,000 summertime asthma attacks in children every year, children miss 500,000
                                                                              days of school each year, and adults take approximately 1.5 million personal days
                                                                              when they are forced to rest or reduce activity due to high smog levels.44
                                                                                 Long-term exposure to HAPs can be life-altering for communities living near oil
                                                                              and gas operations. One such HAP emitted in large amounts, benzene, is a ‘‘known
                                                                              human carcinogen (causing leukemia) by all routes of exposure and . . . that expo-
                                                                              sure is associated with additional health effects, including genetic changes in both
                                                                              humans and animals’’ 45 that is naturally present in underground oil and natural
                                                                              gas. Chronic inhalation of benzene is also associated with noncancer health effects
                                                                              like the arrested development of blood cells, anemia, leukopenia, thrombocytopenia,
                                                                              and aplastic anemia.46 When natural gas leaks or is otherwise emitted in the pro-
                                                                              duction segment, benzene is often present in the emitted gas. EPA has also docu-
                                                                              mented the harmful effects of other specific toxic air pollutants emitted from oil and
                                                                              natural gas operations, including toluene, carbonyl sulfide, ethylbenzene, mixed
                                                                              xylenes, n-hexane, and other air toxics.47 In total, 234 counties in 20 states face can-
                                                                              cer risk, due to oil and gas air pollution, that exceeds the EPA’s one-in-a-million
                                                                              threshold, placing approximately 14 million people at risk. Some of the areas with
                                                                              the greatest health risk are found in New Mexico, West Virginia, Colorado, Texas,
                                                                              Louisiana, and North Dakota.48
                                                                                 Taking action to reduce methane emissions from the oil and natural gas industry
                                                                              will thus provide additional health benefits by reducing the risks of adverse health
                                                                              impacts associated with smog-forming pollution (VOCs and methane) as well as ben-
                                                                              zene and other toxic air pollution.

                                                                                38 See 86 Fed. Reg. at 63,132, Table 11 (sum of VOC emissions from oil and natural gas pro-
                                                                              duction, natural gas processing, and natural gas transmission and storage).
                                                                                39 Drew Shindell, The social cost of atmospheric release, 130 Climatic Change 313 (2015).
                                                                                40 EPA, 2013 Final Report: Integrated Science Assessment of Ozone and Related Photochemical
                                                                              Oxidants 1–6, EPA/600/R–10–076F (‘‘ISA’’).
                                                                                41 ISA at 1–8.
                                                                                42 Kathleen Mortimer et al., The Effect of Air Pollution on Inner-City Children with Asthma,
                                                                              19 European Respiratory J. 699 (2002); ISA at 6–120, 6–121, 6–160.
                                                                                43 ISA at 1–8.
                                                                                44 CATF, Gasping for Breath (Aug. 2016),
                                                                              http://www.catf.us/wp-content/uploads/2018/10/CATF_Pub_GaspingForBreath.pdf.
                                                                                45 Proposed Rule RIA at 3–22.
                                                                                46 Proposed Rule RIA at 3–23.
                                                                                47 Proposed Rule RIA at 3–23—3–26.




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                                                                                48 CATF, Fossil Fumes (forthcoming report update).




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                                                                              Employment Benefits
                                                                                 Implementing strong methane standards would result in a significant number of
                                                                              U.S.-based manufacturing jobs from upfront capital investments, as well as ongoing
                                                                              maintenance, repair, and inspections jobs. According to a forthcoming report, the
                                                                              CATF 65 Percent Plan will result in nearly 64,000 direct jobs, compared to just over
                                                                              27,000 direct jobs for the EPA proposal. In both cases, indirect and induced jobs are
                                                                              also significant: indirect jobs reflect inter-industry purchases and arise from firms
                                                                              purchasing inputs from their suppliers, while induced jobs result from wages paid
                                                                              to workers, who may spend these wages on consumer electronics, clothing, etc. Over-
                                                                              all, the CATF 65 Percent Plan results in nearly 220,000 total jobs compared to
                                                                              92,000 for the EPA proposal, a difference of 120,000 jobs.
                                                                                 There are several reasons why the jobs created by oil and gas methane standards
                                                                              will be good-quality jobs, which add value both for the workers themselves and for
                                                                              their communities.
                                                                                 Technologies exist which will help companies to comply with regulations, but
                                                                              firms will have to ramp up production of equipment in order to meet demand that
                                                                              will be driven by compliance with the standards. Such equipment includes optical
                                                                              gas imaging cameras, air compressors, electric pumps and actuators, solar panels
                                                                              and batteries, and vapor recovery units. In at least one important case—the manu-
                                                                              facture of optical gas imaging cameras—CATF has information indicating that 70
                                                                              percent of the manufacturing will take place domestically in the U.S.49
                                                                                 Globalization has undoubtedly had an impact on the American labor market
                                                                              through practices such as offshoring and outsourcing. However, the many jobs gen-
                                                                              erated by standards would be inherently non-offshorable. Many of the jobs required
                                                                              entail the installation of equipment, ongoing maintenance, and leak inspections and
                                                                              repairs, all of which require U.S.-based workers.
                                                                                 Many of the jobs, particularly those involving installation, maintenance, and in-
                                                                              spections at well sites and compressor stations, are likely to be filled by employees
                                                                              with oil and gas industry experience, using transferable skills and experience.
                                                                                 Some degree of upfront jobs is associated with initial capital investment in equip-
                                                                              ment. But most of the other jobs are ongoing, not time-limited jobs. These are jobs
                                                                              that provide stability to both the workers themselves and the communities in which
                                                                              they live.
                                                                                 Finally, we estimate that at least 10 percent of the jobs will be union jobs. There
                                                                              are unionization rates well above 10 percent in many of the top job categories that
                                                                              we identify.
                                                                              Impact of regulations on industry
                                                                                Strong standards for methane emissions from the oil and gas industry will lead
                                                                              to climate, public health, and economic benefits, and they will achieve these benefits
                                                                              with minimal negative impact on the industry and its workforce.
                                                                                CATF analyzed data on oil and gas well drilling in several U.S. states and con-
                                                                              clude that strong methane standards have not impacted activity in the oil and gas
                                                                              industries. As shown in the figure below, while the number of drilling rigs in each
                                                                              state changes over time, the number of rigs follows the price of oil, not whether the
                                                                              state has passed protective methane rules. Colorado has strong methane pollution
                                                                              standards in place (while Oklahoma and North Dakota do not), but changes in Colo-
                                                                              rado’s rig count are consistent with those in the other two states and shows no de-
                                                                              crease as a result of the state’s methane standards. Rig counts in all three states
                                                                              decreased substantially in late 2014, early 2015, and early 2020 due to a substantial
                                                                              decrease in oil prices. This indicates that methane regulations do not have a demon-
                                                                              strable effect on the level of drilling activity.




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                                                                                   49 Based on CATF conversations with OGI camera manufacturers.




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                                                                                 Ms. CASTOR. Thank you, Ms. Smith.
                                                                                 And thanks to all of our witnesses for your insightful testimony.
                                                                              I like the American ‘‘can do’’ spirit theme that you all have.
                                                                                 Now we will go to member questions.
                                                                                 First up, Ms. Brownley. You are recognized for 5 minutes. Good
                                                                              morning.
                                                                                 Ms. BROWNLEY. Thank you, Madam Chair. And I feel like this
                                                                              is the first time I have ever been first on the committee to ask
                                                                              questions, so thank you for that.
                                                                                 According to the International Energy Agency, natural gas mar-
                                                                              kets could have sold an addition 180 billion cubic meters of natural
                                                                              gas if all the leaks from fossil fuel operations in 2021 had been cap-
                                                                              tured—a volume equal to the entire gas market of Europe.
                                                                                 Ms. Smith, you noted in your testimony that routine flaring
                                                                              wasted enough gas in 2019 to heat over 8.5 million homes. This
                                                                              seems like it should be a powerful economic incentivize for industry
                                                                              to stop leaks and flares from drilling.
                                                                                 So what do you think accounts for industry’s failures to do more
                                                                              on their own to address the problem? Do you think industry’s fail-
                                                                              ure to fix the problem is yet another argument for strong EPA
                                                                              standards?
                                                                                 Ms. SMITH. Thank you so much for the question, Representative
                                                                              Brownley. And you are absolutely right; the amount of waste is
                                                                              staggering: billions of dollars’ worth of natural gas being vented
                                                                              and flared and leaked every year.
                                                                                 Why hasn’t the industry acted? I think we haven’t had uniform
                                                                              standards requirements. And that is the role that EPA can play,
                                                                              by issuing strong safeguards this fall.
                                                                                 Ms. BROWNLEY. Do you see any industries beginning to regulate
                                                                              this on their own, just to protect their bottom line?
                                                                                 Ms. SMITH. Some companies have been more forward-thinking in
                                                                              this area. We released a benchmarking report recently that looked
                                                                              at the top 100 operators, and there is a big range when it comes
                                                                              to emissions. So, again, that underscores that the solutions do exist
                                                                              but are not being used uniformly.




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                                                                                 Ms. BROWNLEY. Thank you. Thank you for that.




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                                                                                                                                    37

                                                                                       Ms. Tomcik, thank you for your testimony and being here.
                                                                                       You mentioned and talked about your children’s school being a
                                                                                    half a mile or so from fracking wells. So, with all of the new tech-
                                                                                    nology and satellite data that is really available now to track meth-
                                                                                    ane flares and emissions, has this data helped you in any way to
                                                                                    raise awareness at the local level about these problems?
                                                                                       Ms. TOMCIK. I am sorry. Could you repeat the last part of that
                                                                                    question one more time?
                                                                                       Ms. BROWNLEY. Yeah. I am asking if, with all of the tools and
                                                                                    data that we have available now to track methane flares and emis-
                                                                                    sions, has any of this—these tools, this data—has that been able
                                                                                    to help you in terms of raising awareness in your own community
                                                                                    to improve upon those leaks, et cetera, that are happening?
                                                                                       Ms. TOMCIK. What we do know is that there is a lot of oil and
                                                                                    gas air pollution that is impacting communities where they live.
                                                                                    And so the information, the technologies are making it clear that
                                                                                    we need Federal methane rules and regulations to protect those
                                                                                    communities who are being impacted by flaring and also the pollu-
                                                                                    tion that is created from the leaks from small leak prone wells.
                                                                                       And so it is very important that these methane rules are enacted
                                                                                    as quickly as possible to protect the health and help protect people
                                                                                    from climate change too.
                                                                                       Ms. BROWNLEY. Thank you. And, again, thanks for being here.
                                                                                       Ms. Smith, you noted in your testimony that there are a variety
                                                                                    of different kinds of leak detectors, including close-range tech-
                                                                                    nologies and screening technologies.
                                                                                       Do you have an estimate of how much these various technologies
                                                                                    would cost? For instance, the handheld device that you spoke of?
                                                                                       Ms. SMITH. I am sorry. Was that for me or Dr. Alden?
                                                                                       Ms. BROWNLEY. For Ms. Smith, yes.
                                                                                       Ms. SMITH. Oh, sure. Thank you. Thank you so much for that
                                                                                    question, Representative.
                                                                                       Fortunately, overall, the costs are very, very low. You know, we
                                                                                    look at leading states like Colorado, for example, which has had
                                                                                    strong leak detection and repair standards on the books, and it
                                                                                    hasn’t had an impact on their rig count and productivity compared
                                                                                    to other states that do not have standards.
                                                                                       Ms. BROWNLEY. And, Ms. Alden, can you add anything to that?
                                                                                       Dr. ALDEN. Sure. Yeah, I completely agree with Ms. Smith. And
                                                                                    it is pretty amazing how implementing this kind of monitoring
                                                                                    drives amazing efficiencies for operators. And so it really does kind
                                                                                    of keep product in the pipeline; identifies malfunctions, which,
                                                                                    whether it is a leak or not, I mean, that saves money; and provides
                                                                                    this kind of instant feedback on operations to help folks really dial
                                                                                    in their systems.
                                                                                       So the technologies——
                                                                                       Ms. BROWNLEY. Thank you.
                                                                                       Dr. ALDEN [continuing]. Themselves are very affordable and—
                                                                                    sorry, yeah,—and pay for themselves.
                                                                                       Ms. BROWNLEY. Thank you.
                                                                                       I yield back, Madam Chair.




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                                                                                       Ms. CASTOR. Next, Representative Gonzalez, you are recognized
                                                                                    for 5 minutes.




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                                                                                 Mr. GONZALEZ. Thank you, Chairwoman Castor and Ranking
                                                                              Member Graves, for holding this hearing today, and for our wit-
                                                                              nesses, for all your work and your testimony.
                                                                                 Dr. Alden, I am going to start with you. As you know, ARPA–
                                                                              E plays an invaluable role in the U.S. energy innovation ecosystem,
                                                                              spurring development and commercialization of transformative
                                                                              technologies that in some cases are too risky for the private sector
                                                                              to invest in. Cash flows are way out into the future. It is great to
                                                                              see, however, that LongPath is a two-time ARPA–E recipient, par-
                                                                              ticularly a selection of the SCALEUP program.
                                                                                 Despite the successes of ARPA–E, many of my colleagues and I
                                                                              remain concerned that some companies may face bureaucratic bar-
                                                                              riers from agencies outside the DOE in the ARPA–E process that
                                                                              chill future private investment and slow down the path to commer-
                                                                              cialization.
                                                                                 So, with that as sort of the backdrop, can you provide some in-
                                                                              sight into LongPath’s experience with regulatory agencies such as
                                                                              the EPA during the ARPA–E process?
                                                                                 Dr. ALDEN. Sure. And, yeah, we are a huge fan of ARPA–E. I
                                                                              mean, the ability for the Federal Government to invest in high-
                                                                              risk, high-reward ideas—and, you know, some of those won’t pan
                                                                              out; some of those do. And that is great for the American economy
                                                                              when they do.
                                                                                 And so working with other agencies—I mean, it is tough for Fed-
                                                                              eral regulations to keep pace with the kind of technological innova-
                                                                              tion that is happening right now. I think EPA has taken great first
                                                                              steps in their draft rules. They opened the door to new tech-
                                                                              nologies, which is huge.
                                                                                 And we have been working directly with them and a whole bunch
                                                                              of other stakeholders—including Dr. Kleinberg as well—to help
                                                                              them get those rules across the finish line in terms of, you know,
                                                                              kind of planning for the future of better technologies taking hold.
                                                                                 So I think, yeah, to the extent that, you know, agencies can look
                                                                              at regulations that are potentially adaptable in the future and also
                                                                              setting metrics that we think we can achieve in the future, I think
                                                                              that is a positive step.
                                                                                 Mr. GONZALEZ. Thanks.
                                                                                 And, outside of the rulemaking process, are there any other spe-
                                                                              cific recommendations that you would make to improve the process
                                                                              on your side, just to make sure that, you know, we don’t have a
                                                                              bunch of great technology companies stuck in sort of a bureaucratic
                                                                              mess, which I know happens at times?
                                                                                 Dr. ALDEN. Yeah. I think the ability to have agencies create rules
                                                                              that are very much inviting of stakeholder feedback is very posi-
                                                                              tive.
                                                                                 And, certainly, a great step right now, in terms of looking at
                                                                              agencies like ARPA–E or DOE or NETL or some of those groups,
                                                                              would be to now—what we really need to enable these technologies
                                                                              to take hold and get out there at large scale is going to be a gov-
                                                                              erning body or independent group. And I think that ARPA–E,
                                                                              DOE, some of those agencies, could help to fund an independent
                                                                              group to create, as I mentioned, those standards and certifications
                                                                              to make sure the technologies going out in the field are really of




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                                                                              that utmost, you know, highest quality.




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                                                                                 Mr. GONZALEZ. Thank you.
                                                                                 Shifting gears a bit, I want to take a minute to focus in on how
                                                                              the various methane-monitoring technologies can work together to
                                                                              improve our detection systems.
                                                                                 In recent years, one of the more popular emissions-control de-
                                                                              vices has been satellites. But, while satellite observations carry
                                                                              many benefits, they also feature some drawbacks, such as their
                                                                              considerable range of uncertainty and inability to apply to smaller
                                                                              emitting sources.
                                                                                 Can you explain how monitoring systems like LongPath’s can
                                                                              work in collaboration with today’s satellites and drones to monitor
                                                                              and identify leaks?
                                                                                 Dr. ALDEN. Yes. As I mentioned, there is a real value in both
                                                                              those, kind of, large-scale survey technologies, as you mentioned,
                                                                              and in having real fixed monitors to provide that mitigation piece.
                                                                                 So satellites are extremely powerful, especially on the world
                                                                              stage. So there are a lot of places on Earth where it is too hard,
                                                                              you are not going to be able to get ground-based monitors or even
                                                                              aircraft, aerial surveys, in place. So, on the global stage, satellites
                                                                              are a huge key to the puzzle.
                                                                                 In the U.S., where we do have the ability to deploy this tech at
                                                                              scale, I see some value in stacked solutions in terms of, you get
                                                                              your continuous fixed monitors on your discrete well pads—so well
                                                                              pads, tank batteries, LNG terminals, you know, compressor sta-
                                                                              tions. And then there is a lot of other infrastructure that is a little
                                                                              more diffuse, so gathering pipelines and pipelines, for example, can
                                                                              be a real nice place to kind of fill in that gap with some of the aer-
                                                                              ial technologies.
                                                                                 But there are a lot of ways to stack these technologies, and cer-
                                                                              tainly redundancy can’t hurt in this realm, where the stakes are
                                                                              so high.
                                                                                 Mr. GONZALEZ. Great. Well, thank you for that. Thank you for
                                                                              all the work that you are doing.
                                                                                 And, with that, I yield back.
                                                                                 Ms. CASTOR. Next, Representative Levin, you are recognized for
                                                                              5 minutes.
                                                                                 Mr. LEVIN. Thank you for holding today’s hearing, Chair Castor.
                                                                              I am glad we are continuing this conversation on the benefits of
                                                                              cutting methane pollution.
                                                                                 And I, too, think about these issues as a parent, with two young
                                                                              kids at home, 9 and 8 years old. And my wife and I encourage them
                                                                              to learn basic science, and I thought I would start with some very
                                                                              simple facts.
                                                                                 As we have heard, methane is a key greenhouse gas driving glob-
                                                                              al mean temperature rise. While addressing carbon dioxide emis-
                                                                              sions gets prime focus in many conversations around climate
                                                                              change, a recent study by scientists at Scripps Institution of Ocean-
                                                                              ography, in my district, confirms what we already know: reducing
                                                                              carbon dioxide emissions alone is not enough to meet our 2050 cli-
                                                                              mate targets.
                                                                                 In order to stay below these metrics, the study notes that we
                                                                              must also focus on addressing methane emissions and other non-
                                                                              carbon dioxide climate-warming pollutants in order to avoid trig-




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                                                                              gering irreversible climate change.




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                                                                                 Methane is particularly important because it has a warming po-
                                                                              tential nearly 80 times greater than carbon dioxide over 20 years,
                                                                              and human-caused emissions of methane currently represent one-
                                                                              third of all warming from greenhouse gases.
                                                                                 Given methane’s intense warming potential, stopping methane
                                                                              pollution is one of the most impactful interventions we can take in
                                                                              the short term to avoid additional warming in the coming years, as
                                                                              we continue working to decarbonize all facets of our society.
                                                                                 But, as we have discussed today, stopping methane leaks doesn’t
                                                                              just have climate benefits, but we also know that reducing methane
                                                                              emissions has key public health and economic benefits.
                                                                                 And as part of the United States’ efforts to help reduce Europe’s
                                                                              dependence on Russian fossil fuels, President Biden recently com-
                                                                              mitted to provide an additional 50 billion cubic meters per year of
                                                                              U.S. liquified natural gas.
                                                                                 A recent analysis by the Environmental Defense Fund found that
                                                                              reasonable reductions in methane waste from leaks and flaring
                                                                              could meet 50 percent of President Biden’s commitment of sending
                                                                              50 billion cubic meters to our European allies.
                                                                                 It seems to me that the oil and gas industry should focus on re-
                                                                              ducing waste of our natural resources as the most tangible short-
                                                                              term solution to increase the domestic supply of natural gas.
                                                                                 Ms. Smith, do you agree that reducing methane pollution by de-
                                                                              ploying leak detection and repair technologies represents a key op-
                                                                              portunity to increase our overall supply of natural gas and help ad-
                                                                              dress high energy prices, both domestically and for our European
                                                                              allies?
                                                                                 Ms. SMITH. Thank you for this question. Yes, ending wasteful
                                                                              venting and flaring would indeed free up additional gas for export
                                                                              to Europe and should absolutely be a priority. We are talking about
                                                                              billions of dollars’ worth of gas going up in flames or going straight
                                                                              into the air in the U.S. every single year.
                                                                                 Mr. LEVIN. So my hope is that if we are really serious about
                                                                              maximizing the potential of our current gas, that we should be
                                                                              doing all we can to mitigate leaks and we should be preventing
                                                                              flaring.
                                                                                 With my time remaining, I would like to shift a bit to discuss ef-
                                                                              forts going on in my home state of California in using aerial sur-
                                                                              veys to improve the detection of methane leaks.
                                                                                 Dr. Kleinberg, as you know, I think between 2017 and 2021,
                                                                              CARB led a pilot program—California Air Resources Board led a
                                                                              pilot program to use airplanes to detect methane leaks from
                                                                              sources including oil fields. And as part of this initiative, 44 Cali-
                                                                              fornia facilities voluntarily repaired leaks after they were notified
                                                                              about them as part of a pilot program.
                                                                                 The fixes prevented the equivalent of 1.2 million metric tons of
                                                                              carbon dioxide from escaping into the atmosphere, which is equal
                                                                              to taking about a quarter of a million cars off the road for a year.
                                                                                 And, as a result of this success, CARB and Carbon Mapper are
                                                                              planning on launching two satellites in 2023 to provide regular,
                                                                              complete, precise, and timely measurement, not just of methane,
                                                                              but also of carbon dioxide emissions as well as over 25 other envi-




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                                                                                 Dr. Kleinberg, given the success of California’s pilot program,
                                                                              what lessons should the Federal Government take from these ef-
                                                                              forts to improve standards and methods for detecting and remedi-
                                                                              ating methane leaks through aerial surveys perhaps on a national
                                                                              level.
                                                                                 Dr. KLEINBERG. Yeah. Well, the California survey was a model
                                                                              for the way I think we should be moving forward in terms of regu-
                                                                              lation and measurement. It was extremely comprehensive—272,000
                                                                              sites. Riley Duran testified just last week at the House Science
                                                                              Committee on this.
                                                                                 This is exactly what we need to be doing. It is remarkably inex-
                                                                              pensive to do it and, as Caroline Alden pointed out, comprehensive.
                                                                              So this is the way to go.
                                                                                 Mr. LEVIN. Well, I am very grateful to—and had the opportunity
                                                                              to have that pilot in California. I hope the rest of the country will
                                                                              take notice.
                                                                                 And it is also great to hear from a UCSD graduate on our panel
                                                                              today.
                                                                                 Dr. KLEINBERG. Yes, sir.
                                                                                 Mr. LEVIN. So I thank the witnesses, and I will yield back to the
                                                                              chair.
                                                                                 Ms. CASTOR. Next up, Representative Carter, you are recognized
                                                                              for 5 minutes.
                                                                                 Mr. CARTER. Thank you, Madam Chair.
                                                                                 And thanks to all of you for being here, the witnesses, for being
                                                                              here.
                                                                                 Look, as much as my colleagues on the other side of the aisle
                                                                              don’t want to admit it or don’t like it, we have to admit that fossil
                                                                              fuels, that natural gas and oil are going to be part of our portfolio
                                                                              for a long time. I mean, let’s face it, we know that a great percent-
                                                                              age of our energy portfolio today is fossil fuels. And that didn’t hap-
                                                                              pen overnight, and it is not going to change overnight, no matter
                                                                              how hard we want it to do that or how badly we want to do that.
                                                                                 But I have to tell you that I am encouraged by the progress that
                                                                              the oil and gas industry, the fossil fuel industry, if you will, has
                                                                              made in decreasing emissions. I had a group in my office just ear-
                                                                              lier this week, a group of six oil companies that are doing business
                                                                              up in Canada. And they have a desire, they have a goal of being
                                                                              carbon-neutral by 2050, even with the fossil fuels.
                                                                                 And I applaud them for that. I think that is great. And I think
                                                                              that we don’t give enough credit to the fossil fuel and the oil and
                                                                              gas industry for the progress that they have made in decreasing
                                                                              emissions.
                                                                                 And a lot of that has to do with the policies. Just last week, we
                                                                              had the Governor of Wyoming before this committee, and he was
                                                                              telling us how he has directed the state to pursue a goal of net-
                                                                              negative carbon-dioxide emissions and continue to use fossil fuels.
                                                                              So, you know, it is going to be part of our future, I understand
                                                                              that, and technology is going to play a big part of that as well.
                                                                                 But I want to pivot just a little bit, because we all know that cli-
                                                                              mate change and that—that this is a global problem. And we would
                                                                              be remiss, and we are being remiss, by not thinking about third-
                                                                              world countries and about up-and-coming countries, developing




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                                                                              countries, because they are using fossil fuels, and they are going




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                                                                              to. Yeah, they do their best to use renewable energy and clean en-
                                                                              ergy, but they are going to use whatever they have to in order to
                                                                              get their economies going and to have electricity, these developing
                                                                              and growing nations.
                                                                                 Just an example, the Indian Government’s own future fuel mix.
                                                                              Their modeling shows that they will overwhelmingly depend on fos-
                                                                              sil fuels, even though they are going to have a rapid rise in renew-
                                                                              able energy as well.
                                                                                 Nigeria’s Vice President put it this way, and I quote: ‘‘No country
                                                                              in the world has been able to industrialize using renewable en-
                                                                              ergy,’’ yet developing countries are being expected to do so, ‘‘when
                                                                              everybody else in the world knows that we need gas-powered in-
                                                                              dustries for business.’’ So it is just part of it.
                                                                                 Dr. Alden, I wanted to ask you—my question for you is this.
                                                                              Doesn’t that mean that it is extremely important to continue to in-
                                                                              vest, to explore, and to innovate in technologies, like LongPath has,
                                                                              so that we can reduce these emissions while still providing reliable
                                                                              energy?
                                                                                 Dr. ALDEN. Absolutely. I mean, I think that, you know, looking
                                                                              at the global stage, as I mentioned, there are—you know, satellites
                                                                              can kind of go everywhere all the time, or a lot of the time, and
                                                                              at least see the very, very large emissions that might be happening
                                                                              in other countries. But I think there is a lot of potential for export-
                                                                              ing the technologies that have been developed here in the U.S., like
                                                                              LongPath or the aerial surveys, all the different—I mean, there is
                                                                              a whole host of new tech here that is kind of ready to go abroad
                                                                              as well.
                                                                                 So I think that there is a great opportunity for the investments
                                                                              that have been made in U.S. innovation to exported overseas and
                                                                              try to solve that problem. Yeah. And, also, I think that, yeah, the
                                                                              other pathway is just, we have the technology here; let’s implement
                                                                              it and prove via measurement that U.S. gas is clean, and then, you
                                                                              know, we can even export that gas. So——
                                                                                 Mr. CARTER. Well, let me ask you this real quick. I am running
                                                                              out of time here. What about regulations? Wouldn’t improving reg-
                                                                              ulations to encourage more widespread adoption of technologies
                                                                              like we see at LongPath, wouldn’t that contribute to the potential
                                                                              for job creation in these areas?
                                                                                 Dr. ALDEN. Absolutely. So making sure the new rules that come
                                                                              online here are recognizing new technologies and creating a direct
                                                                              on-ramp for new technologies is going to be hugely important to
                                                                              kind of stimulate that innovation in the technology sector and to
                                                                              get the folks, you know, on the ground to want to use it. So, yeah,
                                                                              I think——
                                                                                 Mr. CARTER. Well—and just let me say that I have always said,
                                                                              in order to address this situation, we are going to have to have ad-
                                                                              aptation, mitigation, and innovation. And I truly believe that the
                                                                              greatest innovators, the greatest scientists, are right here in the
                                                                              United States of America, and we should be encouraging that.
                                                                                 Thank you, Madam Chair, and I will yield back.
                                                                                 Ms. CASTOR. Next, Representative Bonamici, you are recognized
                                                                              for 5 minutes.
                                                                                 Ms. BONAMICI. Thank you so much, Chair Castor.




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                                                                                 And thank you to the witnesses.




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                                                                                 I serve on the Science, Space, and Technology Committee, as well
                                                                              as the Select Committee. And, earlier this month, we released a
                                                                              majority staff report finding that oil and gas companies are failing
                                                                              to address super-emitting leaks, and they are not consistently de-
                                                                              ploying the innovative leak detection and repair technologies that
                                                                              exist.
                                                                                 And, Dr. Alden, yes, your colleague Dr. Rieker was there from
                                                                              LongPath at the hearing where we spoke about this. And I wanted
                                                                              to follow up on some of the questioning that you have been re-
                                                                              sponding to.
                                                                                 We know, as you have established, as others have established,
                                                                              that the technology now exists and that there are financial incen-
                                                                              tives. But, apparently, the industry is not adapting this technology.
                                                                              So how can Congress motivate industry to adapt this continuous
                                                                              monitoring technology?
                                                                                 And I just want to point out as well that I appreciate your com-
                                                                              ment, something that I have run across over the last decade on the
                                                                              Science Committee, that regulating technology is challenging be-
                                                                              cause the technology changes so much more rapidly than regula-
                                                                              tions.
                                                                                 So can you talk a little bit about the best things that Congress
                                                                              can do to motivate industry to adopt continuous monitoring?
                                                                                 And, also, if you could mention as well—there has been a lot of
                                                                              talk about the oil and gas industry, but that is not the only source
                                                                              of methane. So could you talk a little bit about how your technology
                                                                              works with other methane-emitting sources?
                                                                                 Dr. ALDEN. Thanks, Congresswoman Bonamici. Yeah, those are
                                                                              great questions.
                                                                                 So, with the EPA rules and the SEC rules and other rules com-
                                                                              ing down the pipeline, I mean, I think just being ready, the tech-
                                                                              nologies are here, and knowing that we can achieve the metrics we
                                                                              want—if you want quantitative metrics, like methane intensity,
                                                                              that effectively scale across different production zones, different ba-
                                                                              sins, in a meaningful way, we can get there now with the tech-
                                                                              nologies that we have.
                                                                                 So I think, in the more immediate term, though, the EPA rules—
                                                                              we have worked with a lot of stakeholders, Dr. Kleinberg has been
                                                                              a great leader in this process—in creating a technology-neutral ma-
                                                                              trix that EPA can directly implement into the rule so that we can
                                                                              have those technologies ready to go.
                                                                                 And the reason that is important for industry adoption is, if the
                                                                              EPA rules, for example, or the SEC rules don’t allow a direct on-
                                                                              ramp for these new technologies, then industry is going to be stuck
                                                                              doing the old methods. So they are going to be stuck doing these
                                                                              old OGI surveys four times a year, and they are not going to want
                                                                              to spend extra money to do the monitoring that is really effective
                                                                              with LongPath.
                                                                                 So we need to make sure that we are encouraging and at least
                                                                              not, you know, disincentivizing operators to use these technologies.
                                                                              So I think those would be really important things, to just recognize
                                                                              the technology is here and then build rigs to meet that.
                                                                                 And then, to your second point, that is absolutely a huge issue,
                                                                              is that biogas and other incredible, incredible innovations coming




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                                                                              online, they are going to need monitoring too. Because if you are




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                                                                              effectively capturing methane from various sources and moving it
                                                                              around, it has got the same type of leaks as you do in oil and gas
                                                                              infrastructure. They are equally difficult to find, if not harder to
                                                                              find. And so we need to be sure we are incentivizing the develop-
                                                                              ment and application of measurements in these realms as well.
                                                                                 Similarly, inventory numbers just don’t cut it. You just can’t pre-
                                                                              dict where and when these leaks are going to happen, so you need
                                                                              to be using measurements.
                                                                                 Ms. BONAMICI. Okay. Thank you very much, Dr. Alden.
                                                                                 Dr. Kleinberg, in your written testimony, you cite the need to re-
                                                                              form EPA’s alternative means of emission reduction process. So
                                                                              would you please explain a little bit about the process and how ad-
                                                                              dressing this limitation would help increase the deployment of
                                                                              methane emissions reduction technology?
                                                                                 Dr. KLEINBERG. Yes, I will be happy to.
                                                                                 You know, one thing that is really, really important in regula-
                                                                              tions is having them be adaptive, because this field in particular,
                                                                              where so much technology is being developed so fast, this begs for
                                                                              a regulatory scheme that takes into account new technology, which
                                                                              has been blossoming in the last 7 years.
                                                                                 And the alternative means of emission limitation is a provision
                                                                              of the Clean Air Act that basically anticipates that. But the way
                                                                              it has implemented so far by the Environmental Protection Agency,
                                                                              it has turned out to be more of a barrier than an enabler.
                                                                                 And, in fact, since 2012, when it was first implemented for meth-
                                                                              ane, there was no applications between 2012 and 2020, while peo-
                                                                              ple like Caroline Alden and others were developing this phe-
                                                                              nomenal technology, because the process was so onerous.
                                                                                 Now, it approved a bit in 2020. But, still, one application, which
                                                                              is still sort of floating around in EPA. You know, we need to do bet-
                                                                              ter than that. We need to give EPA the resources to handle these
                                                                              applications and regulations that encourage innovation, not dis-
                                                                              courage it.
                                                                                 Ms. BONAMICI. I appreciate that.
                                                                                 And I have another question for Ms. Smith, but I am out of time,
                                                                              so I am going to be submitting that for the record, as well as some
                                                                              followup for Dr. Kleinberg.
                                                                                 So thank you very much, Madam Chair. I yield back.
                                                                                 Ms. CASTOR. Thank you.
                                                                                 Next, Mr. Armstrong, you are recognized for 5 minutes.
                                                                                 Mr. ARMSTRONG. Thank you, Madam Chair.
                                                                                 If we think capturing 100 percent of the natural gas would lower
                                                                              our energy prices in the near term, then I don’t think we are really
                                                                              being honest about how products get to market.
                                                                                 In fact, one of the two biggest drivers for North Dakota not pro-
                                                                              ducing more oil and gas right now is human capital—we have a
                                                                              workforce shortage, as a lot of people do—and gas capture. And so
                                                                              if we would capture 100 percent of the gas in North Dakota right
                                                                              now, we would drop probably 250- to 300,000 barrels of oil a day,
                                                                              and that would happen overnight.
                                                                                 So you wouldn’t produce more gas, you would produce less oil.
                                                                              And the reason for that is we are the geographic center of North
                                                                              America, and we don’t have the capacity to get that product to




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                                                                              market.




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                                                                                 So when we are considering methane emissions from oil and gas
                                                                              industry, we continue to hear the majority paint the industry with
                                                                              one broad brush. I think it is important that when we talk about
                                                                              who these producers are, what they are, and where they do busi-
                                                                              ness, yes, there are large multinational companies, but the major-
                                                                              ity of the regulatory burden from broad Federal onshore policy will
                                                                              fall on small- and medium-size oil and gas companies.
                                                                                 And companies rightfully have concerns with these proposals. It
                                                                              is not because they want to pollute and it is not because they aren’t
                                                                              already being regulated. It is because they don’t want to be subject
                                                                              to duplicative regulation from wellhead to market.
                                                                                 And the real problem with actions by the EPA and Congress is
                                                                              that they stifle innovation. And even if they are intended not to,
                                                                              by the very nature of Federal regulation, they are burdensome.
                                                                                 As the majority has noted, states are already regulating and sup-
                                                                              porting innovative technology. We did this in North Dakota in the
                                                                              beginning of the oil boom when I served in the state legislature,
                                                                              talking about rewriting all our pipeline law. And at that time, we
                                                                              were talking about sensors, and we were really interested in how
                                                                              we were going to use them. It turns out they don’t work when it
                                                                              is 25 below zero. So they didn’t work, and we continued to move
                                                                              forward.
                                                                                 North Dakota does this through the DEQ through robust meth-
                                                                              ane regulation that is already on the books. But the problem is, is
                                                                              when you revert to Obama-era EPA policies or a one-size-fits-all
                                                                              approach, you cut out new technology. By the very nature of Fed-
                                                                              eral regulation, it is unwieldy, it is burdensome, and it’s unusable
                                                                              by producers. We need to stop duplicative regulations that only
                                                                              serve to slow down market innovation that limits methane.
                                                                                 Dr. Alden, in your presentation, you walk through the technology
                                                                              developed by LongPath that support continuous monitoring of fa-
                                                                              cilities that provides for leak detection and quantifiable data in
                                                                              real time. How do you accurately quantify emissions helps opera-
                                                                              tors that use this technology work more effectively, and how can
                                                                              that benefit both the industry and also reduce emissions?
                                                                                 Dr. ALDEN. Your question is about how quantification helps?
                                                                                 Mr. ARMSTRONG. Yeah.
                                                                                 Dr. ALDEN. Yeah. So quantification drives a lot of insights. I
                                                                              mean, you know, we hear a lot of operators say, oh, you need just
                                                                              a smoke detector. You just need to know if there is a leak or not.
                                                                              But when folks do start to onboard, like, quantitative data that is
                                                                              actually accurate and reliable, we see that they find a lot of value
                                                                              in that.
                                                                                 So, for example, folks can prioritize leaks for repair. They can
                                                                              start to tune in when they want to get alerts, what size leaks they
                                                                              want to get alerts on, what type of leaks they want to get alerts
                                                                              on, in order to really be efficient about attacking the worst leaks
                                                                              first.
                                                                                 They can track and compare how equipment performs in dif-
                                                                              ferent settings. They can look at, say, hey, you know, on windy
                                                                              days, this separator that doesn’t have a burner control unit, you
                                                                              know, blows out and leaks gas, but this other one over here with




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                                                                              a more advanced burner control unit doesn’t.




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                                                                                 So we see a lot of value in being able to track those emissions
                                                                              over time, really look at their reductions, quantify their reductions
                                                                              over time, and then compare site to site and equipment to equip-
                                                                              ment.
                                                                                 Mr. ARMSTRONG. And I appreciate that. We are always interested
                                                                              if it will work in February in North Dakota. That is usually a big
                                                                              concern for us.
                                                                                 So as you state in your testimony, technology-neutral regulations
                                                                              could allow for adoption and deployment of new technologies. How
                                                                              could a neutral regulatory framework help deploy these tech-
                                                                              nologies, and how important is it that regulatory agencies work
                                                                              with the different stakeholders to adopt a framework that allows
                                                                              this approach?
                                                                                 Dr. ALDEN. Yeah, a great question. So as I mentioned, there is
                                                                              a group of stakeholders, so—and that is industry folks, NGOs, tech-
                                                                              nologists like myself, legal experts, who are together kind of
                                                                              crafting what we call a matrix approach for the rule. And we are
                                                                              very, very hopeful, and I think expecting that the EPA will adopt
                                                                              this in the new rule.
                                                                                 And what that will do is allow for certain kind of technology-neu-
                                                                              tral metrics to be put forth, like how frequently does the technology
                                                                              look, and what sort of detection level does it need to have, what
                                                                              kind of size leaks does it need to be able to find reliably.
                                                                                 And so that is a great first step in terms of kind of—I think that
                                                                              that probably will go in the EPA rule, and I applaud the EPA for
                                                                              opening the door to that type of regulation.
                                                                                 The second thing, I want to emphasize what Dr. Kleinberg said
                                                                              about adaptive regulation. So if the rule right now—and this is
                                                                              going to be more of a struggle because this pushes the EPA rules
                                                                              a little further away from where they have been historically, which
                                                                              is difficult, but getting in place the ability to pick the metrics you
                                                                              want for the long term, pick quantification and build your rule
                                                                              around that. And then, as the years go by, in 3 years, in 5 years,
                                                                              in 7 years, return to the best current science on what emissions are
                                                                              and the best current science on what you want and tune.
                                                                                 Ms. CASTOR. Thank you.
                                                                                 Mr. ARMSTRONG. Thank you. I yield back.
                                                                                 Ms. CASTOR. Representative Huffman, you are recognized for 5
                                                                              minutes.
                                                                                 Mr. HUFFMAN. Thank you, Chair Castor.
                                                                                 And thanks to the witnesses for their very interesting testimony.
                                                                                 Dr. Kleinberg, I would like to start with you. You gave us a lot
                                                                              to think about in terms of methane from the oil and gas sector, but
                                                                              we also hear a lot about methane in agriculture and other sources.
                                                                                 Could you just, in terms of the scale of the problem we are trying
                                                                              to deal with, add that into the context of the conversation?
                                                                                 Dr. KLEINBERG. Yeah, I will be happy to. You know, people talk
                                                                              about oil and gas because, basically, the people that run the oil and
                                                                              gas industry are very well-capitalized, very high-technology, so that
                                                                              looks like a good sector to work on and, indeed, it is.
                                                                                 Nonetheless, the agriculture sector is a bigger problem. And, in
                                                                              fact, in that survey of California that Representative Levin men-




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                                                                              tioned, many of the largest sites turned out to be either agricul-




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                                                                              tural, dairy farms, that sort of thing, or waste management land-
                                                                              fills and so on.
                                                                                 Those are also very big problems that we should not ignore. In
                                                                              some ways, they are sort of easier to deal with because it is a less
                                                                              itinerant industry. You know, there are always new wells here and
                                                                              there and with many possibilities for leaks and high-pressure gas
                                                                              and so on. Agriculture might be easier in a different way or dif-
                                                                              ferent problems, but things that we should be working on right
                                                                              now.
                                                                                 Mr. HUFFMAN. Different solutions, though.
                                                                                 Dr. KLEINBERG. Different solutions, yes.
                                                                                 Mr. HUFFMAN. Appreciate that. So if we achieved total methane
                                                                              control in the oil and gas sector and just did a great job with all
                                                                              these technologies, both detecting the methane and eliminating the
                                                                              leaks, if we are meeting ever-higher amounts of global energy de-
                                                                              mand with natural gas, we are still increasing CO2 in the atmos-
                                                                              phere, aren’t we?
                                                                                 Dr. KLEINBERG. Yes.
                                                                                 Mr. HUFFMAN. So I think it is really important as we think about
                                                                              what do we do with this methane issue. Obviously, we have got to
                                                                              apply the handbrake that Ms. Smith and others have talked about,
                                                                              because it is a super pollutant, 84 times more potent than CO2, and
                                                                              global heating is happening really fast, so we desperately need to
                                                                              get methane under control. But if we are not simultaneously bring-
                                                                              ing CO2 concentrations down, we are in real trouble, aren’t we?
                                                                                 Dr. KLEINBERG. Yeah, definitely in the long term. Methane acts
                                                                              fast and sort of gives you instant gratification, but in the long run,
                                                                              we need to deal with CO2, absolutely.
                                                                                 Mr. HUFFMAN. Yeah. And so I just wonder about the moral haz-
                                                                              ard or the policy hazard of maybe assuming—sometimes I hear it
                                                                              suggested by colleagues across the aisle that we will tackle this
                                                                              methane problem, we will do that, and then we can go out with
                                                                              clean natural gas and everything will be just fine, that innovation
                                                                              will sort of figure out new ways to capture the CO2 emissions. We
                                                                              will use offsets.
                                                                                 Any thoughts about the moral hazard of, you know, giving this
                                                                              clean bill of health to natural gas as we stare down a climate cri-
                                                                              sis?
                                                                                 Dr. KLEINBERG. No. I think your concern is well-founded. But I
                                                                              will say, it has been brought up this morning, that carbon capture
                                                                              and sequestration is another route to taking carbon dioxide out of
                                                                              the atmosphere.
                                                                                 Mr. HUFFMAN. So is time travel, but neither of them are hap-
                                                                              pening at scale right now. I mean, do you disagree?
                                                                                 Dr. KLEINBERG. The technology exists to do it. The problem is,
                                                                              is that CCS costs about $60 a ton. We need a price on carbon to
                                                                              make it work, because nobody takes away your garbage for free.
                                                                                 Mr. HUFFMAN. Yeah. But you don’t disagree that right now CCS
                                                                              is just a hypothetical. All of this additional natural gas we are try-
                                                                              ing to sell all over the world, none of it is being captured.
                                                                                 Dr. KLEINBERG. It is a hypothetical because there is no price on
                                                                              carbon. Yes.




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                                                                                 Mr. HUFFMAN. Thank you.




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                                                                                       You know, the other point, I think, is that methane pollution has
                                                                                    all of these other pollution impacts, the environmental justice im-
                                                                                    pacts that have been discussed.
                                                                                       And so, Ms. Smith, I wonder if you could just speak a little bit
                                                                                    more about the other reasons that we ought to be very, very con-
                                                                                    cerned in terms of public health and environmental justice in re-
                                                                                    ducing methane pollution.
                                                                                       Ms. SMITH. Thank you. Yes, the long-term exposure to hazardous
                                                                                    air pollutants from the oil and gas operations can be life-altering
                                                                                    for communities that live near them. Benzene, a known human car-
                                                                                    cinogen, is released alongside methane in very large amounts, and
                                                                                    then there is the estimated three-quarters of a million asthma at-
                                                                                    tacks in children each year directly attributable to the smog from
                                                                                    the oil and gas industry.
                                                                                       So, again, that is why we need EPA to use its well-established
                                                                                    authority to go as far as it possibly can to reduce methane emis-
                                                                                    sions and the pollution released alongside it. And in addition to the
                                                                                    methane rules, EPA should use its well-established authority to re-
                                                                                    duce air pollution from key sources like power plants and vehicles
                                                                                    to protect communities.
                                                                                       Mr. HUFFMAN. Thanks very much.
                                                                                       I yield back.
                                                                                       Ms. CASTOR. Next, Mr. Palmer, you are recognized for 5 minutes.
                                                                                       Mr. PALMER. Thank you, Madam Chairman.
                                                                                       I always appreciate the opportunity to speak about justice, espe-
                                                                                    cially when it comes to how people are impacted by the policies of
                                                                                    my colleagues across the aisle. And they talk about environmental
                                                                                    justice, but they rarely talk about energy injustice or economic in-
                                                                                    justice.
                                                                                       And I brought this up in this committee and other committees
                                                                                    multiple times about this town in Illinois, Pembroke Township, a
                                                                                    town of about 2,200 people. And I think the population is over 90
                                                                                    percent, 97 percent African American.
                                                                                       These are people who don’t have access to natural gas. They are
                                                                                    forced to heat their homes with propane or wood-burning stoves.
                                                                                    Some of them are cooking on wood-burning stoves.
                                                                                       And I just wonder, Ms. Tomcik, if you would support Pembroke
                                                                                    Township getting access to a natural gas line. It is a yes or no. It
                                                                                    is not a speech. It is a yes or no.
                                                                                       Ms. TOMCIK. Thank you, Representative. I think that it is impor-
                                                                                    tant——
                                                                                       Mr. PALMER. It is a yes or no. Would you support a natural gas
                                                                                    line for these low-income families that live in Pembroke Township
                                                                                    in Illinois? It is a yes or no.
                                                                                       Ms. TOMCIK. I would like to——
                                                                                       Mr. PALMER. I will take that as a no.
                                                                                       The good news is Jesse Jackson disagrees with you and others
                                                                                    in the civil rights movement disagree with you, and they have
                                                                                    worked tirelessly to get a natural gas pipeline and the Illinois Leg-
                                                                                    islature has finally approved it.
                                                                                       So they will be getting access to clean-burning natural gas that




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                                                                                    they can use to heat their homes, cook their food, warm their water
                                                                                    and, hopefully, bring some businesses into their city so that they




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                                                                              can have better jobs. And that is, in my opinion, environmental jus-
                                                                              tice, economic justice, and energy justice.
                                                                                 I also want to point out some things about the research. We love
                                                                              to talk about technology in this committee and in some of our other
                                                                              committees, and we act as though methane is a problem that can’t
                                                                              be solved, and that is just not the case.
                                                                                 The University of Illinois, since we were talking about the State
                                                                              of Illinois, has developed a process to convert methane to methanol.
                                                                              It is a liquid fuel. Pacific Northwest National Laboratory is con-
                                                                              verting methane to hydrogen, with zero CO2 emissions. MIT is con-
                                                                              verting methane to fuel or a chemical feedstock on site at the well-
                                                                              head. That technology is not commercially available yet, but I pre-
                                                                              dict that it will be. We are doing a tremendous job in that area.
                                                                                 And there is also the issue of the research that shows that com-
                                                                              mon clay products, such as what they use in cat litter, can be used
                                                                              to curb methane emissions. And I realize methane is a major
                                                                              greenhouse gas, but it is also one of the most—it is the most vola-
                                                                              tile greenhouse gas.
                                                                                 I want to ask Dr. Alden a couple questions. You mention in your
                                                                              testimony the development of new technology to detect methane
                                                                              leaks is essential for reducing methane emissions. Tell me a little
                                                                              bit about what LongPath is doing to reduce methane leaks without
                                                                              the government mandates.
                                                                                 Dr. ALDEN. Yeah. Well, there has been some pretty great indus-
                                                                              try adoption of trials of these types of technologies. So the industry
                                                                              is interested. I mean, they are testing stuff out. They are looking
                                                                              at the new tech. They are sometimes trialing multiple different
                                                                              types of technology and kind of seeing how emissions can be re-
                                                                              duced.
                                                                                 And so, yeah, I think that, you know, as I mentioned, no one
                                                                              wants to do more—yeah, double up on what they need to do. So I
                                                                              think having the regulations allow that to count will be phe-
                                                                              nomenal, and I expect that to happen.
                                                                                 Mr. PALMER. You know, when you are talking about methane
                                                                              leaks, my colleagues on the other side of the aisle will often make
                                                                              it seem like oil and gas companies are fine with leaks, but the fact
                                                                              of the matter is that is just not true. You have noted that reducing
                                                                              these leaks is a win for industry.
                                                                                 What are the benefits? I think there is a financial benefit for re-
                                                                              ducing these leaks. Would that be accurate?
                                                                                 Dr. ALDEN. Yes, there certainly is. I mean, it is just adding a
                                                                              really powerful tool to the toolkit to be able to track what is going
                                                                              on in their operations. I mean, it is not just the leaks that are a
                                                                              problem. The leaks are generally a sign of a malfunction or an inef-
                                                                              ficiency in the system. And so it is a really powerful tool to add to
                                                                              the toolkit to just drive efficiency in operations.
                                                                                 Mr. PALMER. Thank you.
                                                                                 Ms. Tomcik, I just want you to know, I don’t want you to feel bad
                                                                              about putting you on the spot, but I have yet to have a Democrat
                                                                              say they would support that.
                                                                                 Thank you.
                                                                                 Ms. CASTOR. Okay. Mr. Palmer yields back.




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                                                                                 I recognize myself for 5 minutes for questions.




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                                                                                 So the reason that we have devoted so much time in this com-
                                                                              mittee, two hearings to methane, is because it is a super pollutant.
                                                                              It is super damaging to the climate, and that is driving higher cost.
                                                                              We talked about some of the health impacts.
                                                                                 Dr. Kleinberg, in your testimony, what caught my attention, you
                                                                              said: ‘‘Venting methane into the atmosphere is like throwing gar-
                                                                              bage into the street outside your home. It is worse than that. It is
                                                                              like throwing good food, that could be used elsewhere, into the
                                                                              street outside your home.’’
                                                                                 You know, at the last committee meeting, we had Governors who
                                                                              talked about what they were doing. And Governor Lujan Grisham
                                                                              from New Mexico worked with all stakeholders and has really de-
                                                                              veloped a model. But there is a real patchwork of what is going on
                                                                              across the country.
                                                                                 Is that why it is important to have strong Federal standards here
                                                                              on methane? What is your view?
                                                                                 Dr. KLEINBERG. Well, yes, I think Federal regulations are need-
                                                                              ed. You know, states vary a lot, and I am a big believer in fed-
                                                                              eralism. But there are some states that are very much advanced
                                                                              in adopting new technology, encouraging it. Colorado comes to
                                                                              mind. New Mexico is very good. Canada—actually, Canada came
                                                                              up earlier. Canada has some strong regulations. But other states
                                                                              not so much. And we need a level playing field.
                                                                                 And also with respect to our exports to the rest of the world, par-
                                                                              ticularly Europe, Europe wants to see a low upstream greenhouse
                                                                              gas footprint. That is best done at national scale, especially since
                                                                              so much gas comes out of the Permian Basin through Corpus
                                                                              Christi.
                                                                                 Ms. CASTOR. And, Ms. Smith, do you agree? You said we have
                                                                              the solutions in hand to reduce methane. Then you said this is not
                                                                              rocket science, it is more like modern plumbing.
                                                                                 What is your view on the importance of Federal standards?
                                                                                 Ms. SMITH. Yes, I agree with Dr. Kleinberg. We have a patch-
                                                                              work of state rules and some large emitters like Texas that haven’t
                                                                              acted. So we need those Federal safeguards, and they have to apply
                                                                              to the existing equipment too. That is responsible for about 60 per-
                                                                              cent of the pollution problem in the U.S.
                                                                                 Ms. CASTOR. And, Ms. Tomcik, you really spoke from the heart,
                                                                              your perspective as a mom, the impact of pollution on your chil-
                                                                              dren, and really spoke on behalf of parents everywhere for their
                                                                              hopes.
                                                                                 I mean, this is a massive public health issue. I know we get in-
                                                                              volved in a lot of the technical questions over time, but air pollu-
                                                                              tion is a killer. And this is harmful, harmful stuff, and if there are
                                                                              ways to help reduce the health impacts and the harmful con-
                                                                              sequences to our kids, we should be doing that, right? What is your
                                                                              opinion?
                                                                                 Ms. TOMCIK. Yes, absolutely. The reality is that the oil and gas
                                                                              operations that are in communities today are going to be there for
                                                                              a long time. And the potential to pollute is going to be there for
                                                                              a long time. And so we need Federal rules to protect these commu-
                                                                              nities who are living near them.
                                                                                 And so what we do know is that states like Pennsylvania, it is




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                                                                              the second largest natural gas producer in the nation, and the oil




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                                                                              and gas industry in that state is responsible for emitting over 1
                                                                              million metric tons of methane annually. And strong EPA methane
                                                                              rules could quickly and significantly lower those methane pollut-
                                                                              ants, along with the accompanying VOCs that are really impacting
                                                                              the communities.
                                                                                 The reality is, is that we don’t know exactly what is in the air
                                                                              in communities because there is not widespread community moni-
                                                                              toring, and so that is something that really needs to be addressed
                                                                              in order to protect communities. And I am hoping that the EPA
                                                                              will come out with some really strong solutions to help commu-
                                                                              nities that are living with this oil and gas today.
                                                                                 Ms. CASTOR. And what do your kids say?
                                                                                 Ms. TOMCIK. My kids are worried about climate change. They are
                                                                              worried about the oil and gas wells in their communities. And
                                                                              when we talk about it, they are concerned about what the world
                                                                              will be for their children when they are old enough to have chil-
                                                                              dren. They are teenagers right now.
                                                                                 And I just want to let you know that I told my kids that I was
                                                                              coming here, and my son said, you know, let them know that I am
                                                                              the best lacrosse player in the country and that I won the state
                                                                              championship. And I tell you this because I want you to know that
                                                                              we are people. We are real families. We are individuals that are
                                                                              living here with oil and gas, and we need methane rules to protect
                                                                              our health from air pollution and climate change. Thank you.
                                                                                 Ms. CASTOR. Thank you very much.
                                                                                 Mrs. Miller, you are recognized for 5 minutes.
                                                                                 Mrs. MILLER. Thank you, Chair Castor and Ranking Member
                                                                              Graves. And thank you all for being here today.
                                                                                 In my home state of West Virginia, which I talk about fre-
                                                                              quently, we are abundantly rich in natural resources that power
                                                                              our community and our country and our world. I am a member of
                                                                              this committee because our energy-producing communities deserve
                                                                              a voice in the debate on the future of energy and climate policies.
                                                                                 I am deeply committed to finding the solutions to combat emis-
                                                                              sions. Although our world’s climate has changed and will continue
                                                                              to change since God first created Earth, we have science like never
                                                                              before that we can depend upon to help us solve these problems,
                                                                              to mitigate and reduce the emissions.
                                                                                 I am most concerned not with our ability to find the solutions so
                                                                              much, but the willingness to make sure that we have the ability
                                                                              to do so. This administration and my colleagues across the aisle
                                                                              have tried to make it impossible to invest in the technologies that
                                                                              will reduce emissions from reliable sources of energy. Without fu-
                                                                              ture investment, these technologies won’t even exist, and we will
                                                                              not be able to bring our energy-producing communities along into
                                                                              the next generation of prosperity.
                                                                                 Dr. Alden, thank you for joining us today. I was intrigued read-
                                                                              ing your testimony on the work that LongPath Technologies is
                                                                              doing to track methane emissions. Can you explain a bit on how
                                                                              methane monitoring makes the oil and gas industry more viable for
                                                                              a less carbon-intensive future?
                                                                                 Dr. ALDEN. Thank you, Congresswoman Miller. Yes. So meas-
                                                                              uring methane emissions really does contribute to reductions in




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                                                                              emissions across the supply chain for oil and gas. So I do think it




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                                                                              is important for public and the private sectors to both invest heav-
                                                                              ily in technologies that can help us reduce emissions wherever pos-
                                                                              sible. And, yeah, I think it is a win-win for reducing emissions.
                                                                                 Mrs. MILLER. Well, more generally, can you talk about the impor-
                                                                              tance of continued investment in more traditional forms of energy
                                                                              and the new technologies that will support those types of pro-
                                                                              ducers?
                                                                                 Dr. ALDEN. Yeah. I can’t speak to, you know, sort of the general
                                                                              investment in fuels, because that is not quite my expertise, but I
                                                                              can speak to, you know, helping these technologies continue to
                                                                              evolve and be more responsive, more sensitive, more quantitative
                                                                              is certainly going to help everybody.
                                                                                 Mrs. MILLER. That is true. LongPath currently operates in the
                                                                              Permian Basin, which is quite flat. Does the technology also work
                                                                              in more mountainous areas, like West Virginia, where we have
                                                                              abundant natural gas and oil reserves?
                                                                                 Dr. ALDEN. That is a great question. So LongPath Technologies
                                                                              is a very, very new technology. We are very young. And so, right
                                                                              now, we are at that kind of max inefficiency in terms of kind of our
                                                                              system being able to get to smaller and smaller sites.
                                                                                 So the reason that is is we use one laser to cover many, many,
                                                                              many oil and gas facilities. So, right now, areas like the Permian
                                                                              are ideal for us, because we can kind of spread the cost of the sys-
                                                                              tem out over many, many operators and drive the cost of moni-
                                                                              toring to very, very low levels. Certainly, as our technology con-
                                                                              tinues to evolve, we will be able to kind of shrink down and get
                                                                              out to areas like the Marcellus and where you guys are.
                                                                                 And so, yeah, again, I think just keeping these technologies roll-
                                                                              ing, keeping that American innovation pushing—pushing forward
                                                                              will certainly help get monitoring everywhere it needs to be.
                                                                                 Mrs. MILLER. That is why investing is so very important in inno-
                                                                              vation.
                                                                                 Thank you. I yield back my time.
                                                                                 Ms. CASTOR. Next up, Mr. Crenshaw, you are recognized for 5
                                                                              minutes.
                                                                                 Mr. CRENSHAW. Thank you, Madam Chair.
                                                                                 Okay. I think we all agree that we should detect, we should
                                                                              quantify, and we should limit emissions. And we have been trying
                                                                              to help companies like LongPath get the EPA approval they need
                                                                              to do this kind of very important work.
                                                                                 It should also be said none of us want harmful particulates in
                                                                              the air, but we should also know that these are already well-regu-
                                                                              lated.
                                                                                 I do want to take a step back and note some inescapable facts.
                                                                              Number one, methane is simply a component of natural gas. Num-
                                                                              ber two, natural gas has been and will be a key factor in reducing
                                                                              global emissions as it displaces higher emitting coal. Number three,
                                                                              no matter what we talk about here, the demand for natural gas
                                                                              and energy demand in general around the world will increase dras-
                                                                              tically. Number four, U.S. natural gas is far cleaner than our larg-
                                                                              est competitor, Russia, 41 percent cleaner by life-cycle emissions.
                                                                                 So now we have a cost-benefit question on our hands. Our citi-
                                                                              zens are facing higher energy prices and suffering from the associ-




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                                                                              ated inflation, and this administration can’t stop coming up with




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                                                                              ways to discourage investment in our domestic oil and gas industry
                                                                              to increase production, which is our only hope of reducing prices
                                                                              anytime soon.
                                                                                 So if we want to tell the American people today that they should
                                                                              accept even higher prices, there better be quite the extraordinary
                                                                              benefit awaiting them. But here is the thing: oil and gas methane
                                                                              emissions make up about 20 percent of global methane or global
                                                                              emissions. The U.S. makes up about 7 percent of that global emis-
                                                                              sions. And U.S. oil and gas makes up about 2.8 percent of global
                                                                              methane emissions.
                                                                                 So in the end, we are talking about tackling 2.8 percent. So you
                                                                              have to ask, what will happen? What will reducing a fraction of a
                                                                              fraction at great cost even really accomplish?
                                                                                 Ms. Smith mentioned earlier that this was the fastest way to re-
                                                                              duce global emissions, but this is clearly false, just by the numbers.
                                                                              If we want to be factual, we would recognize that 50 percent of the
                                                                              world’s emissions come from foreign coal. Foreign coal is most like-
                                                                              ly to be displaced by natural gas if we can get our product there.
                                                                                 Our domestic gas producers tell me that they could quadruple ex-
                                                                              ports in the next 10 years. If our export policy was targeted at dis-
                                                                              placing foreign coal, this would have the emissions equivalent of
                                                                              electrifying 100 percent of U.S. passenger cars, powering every
                                                                              home in America with rooftop solar and battery packs, and adding
                                                                              54,000 windmills, which would mean doubling U.S. wind capacity.
                                                                                 That would seem like a better investment to me if reducing glob-
                                                                              al emissions was, indeed, our goal, while also maintaining some
                                                                              kind of price stability and energy reliability. Seems like we can
                                                                              have it all if we want.
                                                                                 So my questions are for Dr. Kleinberg. You talked about Russian
                                                                              gas earlier and some of the problems with measuring their gas and
                                                                              how we can compete with that. Frankly, if a country is looking to
                                                                              purchase natural gas with low methane emissions, should they
                                                                              purchase from the U.S. or from Russia?
                                                                                 Dr. KLEINBERG. Well, you know, to be honest, we don’t actually
                                                                              know the answer to that question. Now, I have studied the Russian
                                                                              statistics very carefully, and they just look fishy. I am not done
                                                                              tracking down exactly how they managed to reduce their reported
                                                                              emissions by a factor of eight.
                                                                                 Mr. CRENSHAW. Yeah, it is suspicious.
                                                                                 Dr. KLEINBERG. It is suspicious. But the real answer is we need
                                                                              to be measuring in both countries. And we have talked about air-
                                                                              craft. We have talked about the continuous monitoring. There are
                                                                              satellites. If the United States does it, other countries will start to
                                                                              do it as well. If the United States doesn’t, I am sure they will not.
                                                                                 Mr. CRENSHAW. I think that is actually what I wanted to get at.
                                                                              I mean, why would we think that? Why would increasing our own
                                                                              regulations encourage the Russians, who are clearly not our friends
                                                                              these days?
                                                                                 Dr. KLEINBERG. Right.
                                                                                 Mr. CRENSHAW. Why would that encourage them to care about
                                                                              the environment all of a sudden? They are busy invading other
                                                                              countries.
                                                                                 Dr. KLEINBERG. Well, yeah. No, Russia is a tough case. But in




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                                                                                 Mr. CRENSHAW. But they are the biggest one. I mean, when we
                                                                              are talking about gas, they are the biggest one.
                                                                                 Dr. KLEINBERG. That is right. So we have to, basically, show that
                                                                              we are doing it right, and the European Union and the other buy-
                                                                              ers are then going to have to determine, well, whose data is more
                                                                              credible? Is it the measurements from the United States or is it the
                                                                              spreadsheet exercise with strange numbers from Russia? I think
                                                                              the Europeans are smart enough to figure that out.
                                                                                 Mr. CRENSHAW. I mean, I would hope so. I mean, they recently
                                                                              canceled a large deal with a Texas oil and gas company for that
                                                                              reason, making up things that just aren’t true. I mean, our na-
                                                                              tional labs have done this work already, and I assume you probably
                                                                              agree with their work or think that that work is unbiased and very
                                                                              thoughtfully done.
                                                                                 But, with that, I am already out of time. But I think we got the
                                                                              point across.
                                                                                 Thank you, Madam Chair.
                                                                                 Ms. CASTOR. Next up, Ranking Member Graves, you are recog-
                                                                              nized for 5 minutes.
                                                                                 Mr. GRAVES. Thank you, Madam Chair.
                                                                                 Dr. Kleinberg, again, I appreciate you being here. And I want to
                                                                              follow up on Congressman Crenshaw’s questioning.
                                                                                 Russia for weeks sat there at the border and said they weren’t
                                                                              going into Ukraine. They said they were performing a special mili-
                                                                              tary operation. Later, they said they were liberating Ukrainians
                                                                              who wanted to be liberated. They denied any human rights viola-
                                                                              tions whenever things were clearly—you know, there was clear evi-
                                                                              dence that that was not the case. And my point is here is that I
                                                                              am not sure that Russia has much credibility.
                                                                                 We can sit here all day long and talk about the lies of Vladimir
                                                                              Putin or methane numbers. I do want to ask you, though, you
                                                                              noted in your testimony that there is likely some distortion. I heard
                                                                              you tell Mr. Crenshaw that some of Russian numbers are fishy.
                                                                                 I did want to ask, what do we do to put a better system in place
                                                                              to actually get more accurate measurement? And can you explain
                                                                              the benefits of the International Methane Emissions Observatory?
                                                                                 Dr. KLEINBERG. Yeah, I will be happy to. You know, Russia is
                                                                              using the same system that was first used in the United States, pi-
                                                                              oneered by the EPA and the Gas Research Institute back in the
                                                                              1990s, which was the best method at the time, which is this emis-
                                                                              sion factor method, which is basically a spreadsheet that involves
                                                                              no measurements. And Russia copied that. Most countries do copy
                                                                              what we do. How they implement it, okay, that is another question.
                                                                                 But I think by the same token, we need to—now that we have
                                                                              these wonderful new instruments, such as LongPath, the aerial
                                                                              surveys that were mentioned and so on, we can do a lot better. And
                                                                              other countries will copy us.
                                                                                 I just want to point out—you are from Louisiana—when I have
                                                                              been around the world talking to petroleum engineers, they are
                                                                              trained at LSU. They are trained at Texas A&M. They are trained
                                                                              in Oklahoma.
                                                                                 Believe me, the American influence is very powerful in this in-




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                                                                              dustry. And once we do it right, other countries will. And then the




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                                                                              purchasing nations, the Europeans, the Japanese, Koreans, are
                                                                              going to say, yes, we want this, it is verifiably cleaner.
                                                                                 Mr. GRAVES. I just want to thank you for listing the universities
                                                                              in order of prominence.
                                                                                 Dr. Alden, when your colleague at LongPath, Dr. Rieker, testified
                                                                              at House Science a few weeks ago, they talked about the impor-
                                                                              tance of EPA regulations and encouraging innovation to provide a
                                                                              path to new technologies to determine methane leaks more effec-
                                                                              tively.
                                                                                 Would you mind expanding on that and just talk a little bit
                                                                              about some of the opportunities and some of the challenges that
                                                                              companies are facing in deploying those technologies?
                                                                                 Dr. ALDEN. Yeah. So a lot of companies are trying out the new
                                                                              technologies right now, and they are seeing what it is all about,
                                                                              testing the waters. And so it is going to be really important to be
                                                                              able to take that next step and have policies and regulations really
                                                                              incentivize and encourage operators to use these new technologies.
                                                                                 Another piece of the puzzle is, you know, if policymakers and de-
                                                                              cisionmakers are interested in the data that comes of that, they are
                                                                              going to need to encourage and incentivize producing that data,
                                                                              and certainly not do that with a stick but, rather, do that with a
                                                                              carrot.
                                                                                 So, yeah, we see a lot of people trying stuff out. We want to see
                                                                              the policies encourage widespread adoption. And we find that the
                                                                              folks who do put the time in to integrate LongPath’s data see pret-
                                                                              ty immediate gains in terms of improved efficiencies.
                                                                                 Mr. GRAVES. Thank you.
                                                                                 Ms. Tomcik, again, I want to thank you for being here. And
                                                                              please know that my opening statement wasn’t an effort to attack
                                                                              you. My opening statement is that I am a parent too, and I care
                                                                              a lot about the environment and the planet that we leave our kids.
                                                                              I just think that the data shows a pretty different outcome than
                                                                              a lot of folks believe the narrative to be.
                                                                                 You know, I was curious. In your testimony, I think you said
                                                                              that—and I think I got this backwards earlier. You said that it is
                                                                              estimated the oil and gas industry emits more than 16 million met-
                                                                              ric tons of methane pollution annually. However, Ms. Smith said
                                                                              that the domestic oil and gas industry emits half of that, or just
                                                                              8 million tons.
                                                                                 Did you understand what the difference is between your testi-
                                                                              mony and Ms. Smith’s testimony?
                                                                                 Ms. TOMCIK. So the 16 million metric tons annually is based off
                                                                              of Environmental Defense Fund’s information. And what they do is
                                                                              they are looking at the measurements that are taken directly from
                                                                              oil and gas and using estimates—mathematical estimates to cal-
                                                                              culate those.
                                                                                 I would be very happy to provide that information to you.
                                                                                 Mr. GRAVES. That would be great if you could. And I also want
                                                                              to ask if you could provide some information on the—you made a
                                                                              comment that minorities are more impacted, in your testimony,
                                                                              and if you could just provide some data on that, because last time
                                                                              someone said that their data actually showed the opposite.
                                                                                 Madam Chair, I want to ask unanimous consent that two letters,




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                                                                              one June 23 from a number of energy companies and another one




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                                                                                                                                  56

                                                                              from June 24 from AXPC, be included in the record of the hearing,
                                                                              both talking about their methane emissions and energy independ-
                                                                              ence efforts.
                                                                                Ms. CASTOR. Without objection, so ordered.
                                                                                [The information follows:]

                                                                                                               Submissions for the Record

                                                                                                           Representative Garret Graves
                                                                                                       Select Committee on the Climate Crisis

                                                                                                                        June 24, 2022
                                                                              ATTACHMENT: Letter from energy companies and associations to President Biden
                                                                                  re: methane emissions and energy independence efforts, June 23, 2022.
                                                                              This letter is retained in committee files and available at:
                                                                                  https://www.api.org/∼/media/Files/News/2022/06/23/Energy-Trades-Open-
                                                                                  Letter-to-President-Biden

                                                                              ATTACHMENT: Letter from AXPC to the Select Committee on the Climate Crisis,
                                                                                 June 24, 2022.

                                                                              June 24, 2022
                                                                              The Honorable Kathy Castor                   The Honorable Garret Graves
                                                                              Chairwoman                                   Ranking Member
                                                                              Select Committee on the Climate Crisis       Select Committee on the Climate Crisis
                                                                              U.S. House of Representatives                U.S. House of Representatives
                                                                              H2–359 Ford House Office Building            H2–359 Ford House Office Building
                                                                              Washington, DC 20515                         Washington, DC 20515
                                                                              Dear Chairwoman Castor and Ranking Member Graves,
                                                                                 The American Exploration and Production Council i (AXPC), a national trade asso-
                                                                              ciation representing large independent oil and natural gas exploration and produc-
                                                                              tion companies in the United States, would like to offer our perspective as part of
                                                                              the record for the House Select Committee on the Climate Crisis’ hearing, ‘‘Cutting
                                                                              Methane Pollution: Safeguarding Public Health, Creating Jobs, and Protecting our
                                                                              Climate.’’ ii
                                                                                 The member companies of AXPC are providing affordable, reliable energy to
                                                                              Americans and the world and are committed to environmentally responsible and
                                                                              safe operations. We are proud of our role in helping author the American Shale Rev-
                                                                              olution, which has unlocked vast reserves of American natural gas, helping our na-
                                                                              tion reduce carbon dioxide emissions in the power generation sector by 32 percent
                                                                              since 2005.iii
                                                                                 Because methane is the primary constituent of natural gas, capturing methane is
                                                                              important to industry from an environmental and business standpoint. AXPC was
                                                                              the first national trade to support the federal regulation of methane,iv and wants
                                                                              to work collaboratively with the administration and Congress to achieve meaningful
                                                                              action to address climate change, including on the critical issue of methane.
                                                                                 Due to industry leadership and investment in new technologies, methane emis-
                                                                              sions from petroleum and natural gas systems fell from 1990–2019, even as produc-
                                                                              tion increased dramatically.v
                                                                                 Notably, AXPC member companies are members of The Environmental Partner-
                                                                              ship (The Partnership or TEP)—a collaboration of oil and natural gas companies
                                                                              working to continuously improve the industry’s environmental performance by ‘‘tak-
                                                                              ing action, learning about best practices and technologies, and fostering collabora-
                                                                              tion to responsibly develop our nation’s essential oil and natural gas resources.’’ vi
                                                                              Flexibility to Allow for Emerging Technologies
                                                                                Consistent with our Climate Policy and Principles,vii AXPC believes federal meth-
                                                                              ane policy should:
                                                                                • Encourage innovation and flexibility, instead of overly prescriptive regulations
                                                                                  that hinder the goal of reducing methane emissions;
                                                                                • Allow and incentivize the development and deployment of technologies to mon-




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                                                                                  itor and mitigate methane emissions for compliance purposes;




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                                                                                                                                  57
                                                                                • Appropriately quantify and assess the feasibility, costs and benefits of imple-
                                                                                   menting new requirements for existing facilities;
                                                                                • Avoid creating duplicative and overlapping regulatory regimes at the federal
                                                                                   and state levels; and
                                                                                • Properly interpret and follow the relevant provisions of the Clean Air Act.
                                                                                Our industry necessarily prioritizes compliance first and foremost, but unfortu-
                                                                              nately regulations today do not allow for use of emerging methane detection tech-
                                                                              nologies to meet compliance requirements—which impedes broad-scale deployment.
                                                                              Still, because of the importance of this issue, our companies have not stopped at
                                                                              minimum compliance, but instead invested heavily in the evaluation, testing, devel-
                                                                              opment, and early utilization of more advanced technologies for leak detection and
                                                                              leak quantification. While driving these innovations forward, industry has similarly,
                                                                              reasonably prioritized finding and fixing leaks over measuring them, until such time
                                                                              as the development of field-reliable quantification technologies could be realized.
                                                                                Industry has spent nearly a decade—from an initial posture of envisioning possi-
                                                                              bilities to having realized many of them today—advocating for EPA regulations to
                                                                              provide greater flexibility to allow the use of emerging technologies that could find
                                                                              bigger leaks faster compared to the site-by-site on the ground surveys required
                                                                              today.
                                                                                The industry has long promoted technology and innovation as the best near-term
                                                                              pathway for significant emission reduction and AXPC member companies have in-
                                                                              vested significant time and resources in improving capabilities and practices for leak
                                                                              detection, repairs, and eventual quantification. As recent as the comments sub-
                                                                              mitted this year for EPA’s November 2021 Methane proposal, we have pushed for
                                                                              the ability to use those technological advancements to meet compliance require-
                                                                              ments and to be able to prioritize finding the larger leaks for greater efficiency in
                                                                              methane reduction.viii
                                                                              Leak Detection and Repair and Emissions Measurements
                                                                                Methane Leak Detection and Repair (LDAR) technologies are rapidly evolving, but
                                                                              there are still challenges to using current LDAR technologies to quantify methane
                                                                              from a particular area, especially in field applications. Though capabilities are ad-
                                                                              vancing, these measurement technologies still have wide margins for error, are
                                                                              largely still in pilot phases.
                                                                                It has only been through partnership with industry, and largely funded by indus-
                                                                              try, that these technologies have been developed and continue to improve. The in-
                                                                              dustry is committed to progressing these technologies so that they can someday
                                                                              quantify emission leak rates in the field in a way that could be reliable enough to
                                                                              be used more broadly across the industry.
                                                                                While our industry recognizes how useful quantification measurements might be
                                                                              in LDAR, the development of that technology will take time, particularly as it moves
                                                                              from the laboratory to field applications. The technology must also yield results that
                                                                              are fully auditable, adding to the complexity of field applications.
                                                                                In the meantime, using all the data we have to address emissions on a daily basis
                                                                              we have not found the lack of precise quantification a hinderance to finding leaks
                                                                              of any size. Additionally, trending data provided by engineering emission-factor
                                                                              based inventories, such as the EPA’s Greenhouse Gas Reporting Program, have been
                                                                              a powerful tool to understand some of the greatest emission reduction opportunities
                                                                              in the sector and are still the most comparable inventories available today.
                                                                              Best Practices
                                                                                AXPC member companies often go above and beyond what is required for regu-
                                                                              latory compliance and are working to ensure the forthcoming EPA methane rule
                                                                              incentivizes and allows for new and emerging technologies to meaningfully reduce
                                                                              emissions.
                                                                                Similarly, companies develop and share best practices and technologies to continu-
                                                                              ously reduce emissions through voluntary coalitions such as TEP. In 2020, The Part-
                                                                              nership collaborated with technology companies to advance the development and im-
                                                                              plementation of new methane detection technologies through substantive engage-
                                                                              ment with Colorado State University, Bridger Photonics, and NASA’s Jet Propulsion
                                                                              Laboratory Methane Source Finder team.
                                                                                Even outside of TEP, companies are actively collaborating on approaches and best
                                                                              practices that can help reduce emissions faster. For example, AXPC has hosted its
                                                                              own ‘‘technology forum’’ to share learnings for piloted technologies that that allow
                                                                              us to find large leaks across a basin more efficiently. AXPC also conducts annual
                                                                              peer benchmarking surveys, including data such as emissions and trends, to help




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                                                                              member companies continuously improve their operational performance.




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                                                                                                                                  58
                                                                              Summary
                                                                                AXPC member companies are committed to providing affordable, reliable energy
                                                                              to America and the world, while continuing to meaningfully reduce emissions. We
                                                                              want to work collaboratively with the administration and Congress to address the
                                                                              critical issue of methane. We believe it is important that legislative and regulatory
                                                                              policy embraces the domestic energy industry, providing needed flexibility to encour-
                                                                              age innovation, and enables meaningful solutions to achieve the dual goals of cli-
                                                                              mate progress and providing energy security and prosperity to the American people.
                                                                                Thank you for your consideration of this important issue.
                                                                              Sincerely,
                                                                              Anne Bradbury
                                                                              CEO
                                                                              American Exploration and Production Council
                                                                              References
                                                                                i https://www.axpc.org/who-we-are/
                                                                                ii https://climatecrisis.house.gov/committee-activity/hearings/cutting-methane-
                                                                              pollution-safeguarding-health-creating-jobs-and-0
                                                                                iii https://www.eia.gov/todayinenergy/detail.php?id=48296
                                                                                iv https://www.houstonchronicle.com/opinion/outlook/article/Opinion-America-s-
                                                                              independent-oil-and-gas-15865139.php
                                                                                v https://www.api.org/∼/media/Files/Policy/Environment/TEP/2021/The-
                                                                              Environmental-Partnership-2021-Annual-Report.pdf
                                                                                vi https://www.api.org/∼/media/Files/Policy/Environment/TEP/2021/The-
                                                                              Environmental-Partnership-2021-Annual-Report.pdf
                                                                                vii https://www.axpc.org/working-responsibly/climateprinciples/
                                                                                viii https://www.regulations.gov/comment/EPA-HQ-OAR-2021-0317-0831


                                                                                Ms. CASTOR. And I want to thank the witnesses today for your
                                                                              very insightful testimony.
                                                                                And also ask unanimous consent to admit to the record a letter
                                                                              from the Evangelical Environmental Network thanking the com-
                                                                              mittee for our hearing; and, let’s see, the Environmental Defense
                                                                              Fund, also a letter from them on recent scientific papers, economic
                                                                              reports highlighting the need for strong Federal rules that com-
                                                                              prehensively target methane waste and pollution; and a third letter
                                                                              from Clarke Valve Company that is encouraging the committee to
                                                                              weigh in with EPA to urge the agency to consider lowering meth-
                                                                              ane emissions beyond the currently proposed levels.
                                                                                [The information follows:]
                                                                                                               Submissions for the Record
                                                                                                            Representative Kathy Castor
                                                                                                       Select Committee on the Climate Crisis
                                                                                                                        June 24, 2022
                                                                              June 22, 2022
                                                                              Chair Kathy Castor
                                                                              Ranking Member Garret Graves
                                                                              The United States of America, House of Representatives
                                                                              Select Committee on the Climate Crisis
                                                                              H2–359 FHOB
                                                                              Washington, DC 20515

                                                                              Ref:    Hearing on the Benefits of Cutting Methane Pollution
                                                                                      Written Testimony Submitted by The Evangelical Environmental Network
                                                                              Dear Chair Castor and Ranking Member Graves,
                                                                                Thank you for your service to our nation. We thank you for your leadership and
                                                                              common commitment to making America’s energy the cleanest in the world—a goal




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                                                                              that every American can be proud of and that is indispensable for giving our chil-




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                                                                                                                                  59
                                                                              dren and grandchildren the bright and healthy future they deserve. Compared to
                                                                              other global energy producers, American energy has made incredible strides in this
                                                                              area, but when it comes to ensuring every child—including the unborn—have a
                                                                              chance at a thriving, fulfilling life, there is still much work to do. That is why we
                                                                              are grateful for the Committee’s hearing on the benefits of cutting methane pollu-
                                                                              tion, including sealing methane leaks that waste our nation’s precious natural re-
                                                                              sources at a time when families cannot afford any wasted drop.
                                                                                 As pro-life evangelicals, we have a special concern for the unborn. We want chil-
                                                                              dren to be born healthy and unhindered by the ravages of pollution even before they
                                                                              take their first breath. The medical community has long known pollution and other
                                                                              environmental impacts harm our unborn children, and we know that fossil fuel com-
                                                                              bustion is the leading environmental threat to children’s health worldwide.1 It was
                                                                              once thought expectant mothers supply a shield of protection to their developing un-
                                                                              born child by filtering out pollutants—medical research repeatedly shows that this
                                                                              is untrue.
                                                                                 Studies show that smog, VOCs, and air toxics have a disproportionate impact
                                                                              upon life in the womb and that living close to oil and gas infrastructure poses a
                                                                              significant threat to unborn life:
                                                                                   • Dr. Lisa M. McKenzie with the Colorado School of Public Health published
                                                                                     peer-reviewed research linking birth defects to methane production.2
                                                                                   • Casey J.A., et al further find that simply living within a half-mile radius of nat-
                                                                                     ural gas development leads to increased brain, spine, or spinal cord birth de-
                                                                                     fects in children.3
                                                                                   • Research by Dr. Shaina L. Stacy and others at the University of Pittsburgh
                                                                                     shows that in Butler County, PA babies born to families living closer to uncon-
                                                                                     ventional gas wells have lower birth weights.4 Babies with low birthweight are
                                                                                     at higher risk for breathing problems, neurologic problems, and sudden infant
                                                                                     death syndrome (SIDS), and have harder time eating, gaining weight, and fight-
                                                                                     ing infection because their tiny bodies are simply not strong enough.
                                                                                This isn’t a small or isolated problem: 3.2 million children attend 12,445 schools
                                                                              located within with 0.5 miles of an oil/gas facility and 17.32 million Americans of
                                                                              all ages live within that same radius.5 Over 85% of the medical studies 6 that have
                                                                              studied the gas industry’s impact on health find that that emissions from oil and
                                                                              gas facilities and infrastructure is highly detrimental to the health of both children
                                                                              and adults—this includes heart failure,7 asthma,8 and the exposure to known car-
                                                                              cinogens.9

                                                                                1 Perera F. Pollution from Fossil-Fuel Combustion is the Leading Environmental Threat to
                                                                              Global Pediatric Health and Equity: Solutions Exist. Int J Environ Res Public Health.
                                                                              2017;15(1):16. Published 2017 Dec 23. doi:10.3390/ijerph15010016
                                                                                2 Lisa M. McKenzie, Ruixin Guo, Roxana Z. Witter, David A. Savitz, Lee S. Newman, and
                                                                              John L. Adgate, Birth Outcomes and Maternal Residential Proximity to Natural Gas Develop-
                                                                              ment in Rural Colorado, Environmental Health Perspectives doi:10.1289/ehp.1306722.
                                                                              downloaded September 28, 2015, http://ehp.niehs.nih.gov/1306722/#tab3
                                                                                3 Casey J.A., et al., ‘‘The association between natural gas well activity and specific congenital
                                                                              anomalies in Oklahoma, 1997–2009,’’ Environment International, Volume 122, January 2019,
                                                                              381–388, https://www.sciencedirect.com/science/article/pii/S0160412018317999?via=ihub
                                                                                4 Stacy SL, Brink LL, Larkin JC, Sadovsky Y, Goldstein BD, Pitt BR, et al. (2015) Perinatal
                                                                              Outcomes and Unconventional Natural Gas Operations in Southwest Pennsylvania. PLoS ONE
                                                                              10(6): e0126425. doi:10.1371/journal.pone.0126425, downloaded September 28, 2015,
                                                                              http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0126425
                                                                                5 https://oilandgasthreatmap.com/threat-map/
                                                                                6 Hays J, Shonkoff SBC (2016) Toward an Understanding of the Environmental and Public
                                                                              Health Impacts of Unconventional Natural Gas Development: A Categorical Assessment of the
                                                                              Peer-Reviewed Scientific Literature, 2009–2015. PLoS ONE 11(4): e0154164. doi:10.1371/journal.
                                                                              pone.0154164
                                                                                7 McAlexander TP, Bandeen-Roche K, Buckley JP, Pollak J, Michos ED, McEvoy JW, Schwartz
                                                                              BS. Unconventional Natural Gas Development and Hospitalization for Heart Failure in Pennsyl-
                                                                              vania. J Am Coll Cardiol. 2020 Dec 15;76(24):2862–2874. doi: 10.1016/j.jacc.2020.10.023. PMID:
                                                                              33303076; PMCID: PMC7735256.
                                                                                8 Rasmussen S.G., et al., ‘‘Association Between Unconventional Natural Gas Development in
                                                                              the Marcellus Shale and Asthma Exacerbations,’’ JAMA Internal Medicine, 2016, 176(9), 1334–
                                                                              1343, https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2534153 Willis, M. D.,
                                                                              et al., ‘‘Unconventional natural gas development and pediatric asthma hospitalizations in Penn-
                                                                              sylvania, Environmental Research, 166, 402–408, October 2018,
                                                                              https://www.ncbi.nlm.nih.gov/pubmed/29936288
                                                                                9 McKenzie, L.M., et al., ‘‘Ambient Nonmethane Hydrocarbon Levels Along Colorado’s North-
                                                                              ern Front Range: Acute and Chronic Health Risks,’’ Environmental Science Technology, April




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                                                                              17, 2018, 52(8):4514–4525, https://pubs.acs.org/doi/10.1021/acs.est.7b05983




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                                                                                 Not only are these leaks spewing methane, benzene, other VOC’s, and toxins that
                                                                              threaten our children’s right to an abundant life, methane is greenhouse gas 86
                                                                              times more potent than CO2 in the first twenty years—making fugitive and leaking
                                                                              methane as an imperative for any hope in keeping temperature below 1.5° C. by
                                                                              2050 or sooner. Methane is responsible for at least one-quarter of the climate warm-
                                                                              ing we are experiencing today.10 Warmer temperatures produce more smog, increas-
                                                                              ing asthma, another serious health concern.
                                                                                 The level of emissions from leaks from these facilities is grossly underestimated,
                                                                              with research showing it is very likely to be 60% greater than current EPA esti-
                                                                              mates.11 Reducing methane emissions by least 65% below 2012 levels—either
                                                                              through Congressional Legislation or regulation—is necessary to sufficiently safe-
                                                                              guard our children’s health from pollution and the growing threats of climate
                                                                              change. This must include addressing leaks across the complete supply chain from
                                                                              production to transportation and distribution for all existing wells and new produc-
                                                                              tion.
                                                                                 Reducing emissions from low producing wells represents a great opportunity for
                                                                              high return on investment. According to a recent report published in Nature, the
                                                                              oil and gas industry’s lowest producing wells turn out to be the largest source of
                                                                              leaked methane. While they are only 6% of total U.S. methane and oil production,
                                                                              these low-producing wells release 50% of all methane emissions.12 As an example
                                                                              out of a total of 81,500 total wells in all of Appalachia, there are over 70,000 low-
                                                                              producing wells alone in the state of Pennsylvania where EEN is based—making
                                                                              Pennsylvania based oil and gas companies the region’s primary offenders.
                                                                                 Nationally these porous wells spew enough methane to supply over 3.6 million
                                                                              homes in the U.S. every year. That’s $1.3 billion in wasted energy. Put another way,
                                                                              this leakage amounts to more than 10% of the gas these wells produce. And this
                                                                              wasted methane does not disappear harmlessly into the wind. It drifts up to our at-
                                                                              mosphere where it worsens climate change, and it settles into the lungs, hearts, and
                                                                              brains of our children and grandkids. With industry representatives and politicians
                                                                              now demanding more drilling in the name of ‘‘energy security,’’ it seems smarter to
                                                                              capture this wasted gas first before sinking fortunes into drilling new wells that will
                                                                              only continue to harm our children and contaminate God’s amazing creation.
                                                                                 Here’s the good news: these leaks sprout from fixable sources. With the advances
                                                                              of technology and new monitoring techniques, we have the tools at hand to stop
                                                                              methane gas leaks. Better routine maintenance, innovative new equipment, and reg-
                                                                              ular site monitoring could capture this wasted methane and could even pay for the
                                                                              repairs since more methane will make it to market.
                                                                                 And we are not alone when it comes to calling for robust controls on methane gas
                                                                              leaks. We collected over 135,000 comments from pro-life Christians in 2022 in sup-
                                                                              port of a new EPA rulemaking on methane asking for regular inspection and repair
                                                                              at these low-production wells.
                                                                                 In addition to the Evangelical community, leading oil/gas corporations and organi-
                                                                              zations like Shell, Equinor, BP, EQT, Jonah Energy, Equitrans Midstream, and the
                                                                              Interstate Natural Gas Association of America all support methane leak standards.
                                                                              Industry actually stands to increase their bottom lines by plugging wasteful meth-
                                                                              ane leaks and recapturing fugitive methane emissions, making cutting methane pol-
                                                                              lution is a win-win-win.
                                                                                 Yet many in oil and gas industry has so far refused to address this critical health
                                                                              risk, and our children suffer the consequences.
                                                                                 With little or no willingness from these industry players to do the right (and eco-
                                                                              nomical) thing, Congress has a critical role to play in encouraging wise stewardship
                                                                              of the American economy, our precious natural resources, and protection of our chil-
                                                                              dren’s health and future. Before allowing more methane drilling or further funding
                                                                              for methane expansion into hydrogen, plastics, or other potential uses, Congress
                                                                              must secure a commitment from industry reduce this leakage problem.
                                                                                 In addition to defending our children and their future, this is also a matter of fair-
                                                                              ness for the American People who foot the added tax burdens (not to mention the
                                                                              health care costs) that we already pay to clean up the messes of oil/gas industry.

                                                                                   10 lissa B Ocko et al 2021 Environ. Res. Lett. 16 054042.
                                                                                11 Alvarez, RA et al. (2018), ‘‘Assessment of Methane Emissions from the U.S. Oil and Gas
                                                                              Supply Chain,’’ Science 361, 186 (available at
                                                                              https://science.sciencemag.org/content/361/6398/186).
                                                                                12 Mark Omara, Daniel Zavala-Araiza, David R. Lyon, Benjamin Hmiel, Katherine A. Roberts,
                                                                              and Steven P. Hamburg https://doi.org/10.1038/s41467-022-29709-3, Nature Communications:




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                                                                              April 19, 2022.




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                                                                              Today’s bonding structure and royalty fees to access resources owned by the Amer-
                                                                              ican People is unjust and needs an overhaul.
                                                                                Our common book, the Bible is clear on fairness, justice, and righteous as the He-
                                                                              brew Bible prophet Amos 5:24 (NIV) states,

                                                                                                         ‘‘But let justice roll on like a river,
                                                                                                     righteousness like a never-failing stream!’’
                                                                                 Infrastructure Investment and Jobs Act provided $4.5 for the remediation of
                                                                              orphaned oil/gas wells. These billions in taxpayer dollars that will only cover part
                                                                              of the problem of orphaned wells 13 that companies have left to the U.S. This is a
                                                                              problem that would not exist if proper bonding requirements were in place from the
                                                                              start or had been updated since the 1950’s.14 Without adequate bonding require-
                                                                              ments, we are doomed to repeat these mistakes yet again and saddle the next gen-
                                                                              eration with despoiled land, water, and air and a billion-dollar price tag for a mess
                                                                              they didn’t make.
                                                                                 We urge the Committee to defend our children’s health and the American Tax-
                                                                              payer by demanding that new bonding requirements that fully cover real remedi-
                                                                              ation. This includes actual third-party bonding per permit—not self or blanket bond-
                                                                              ing. These issues are correctly and thoroughly discussed in an outstanding white
                                                                              paper entitled Broken Promises by Conservatives For Responsible Stewardship.15
                                                                                 EEN President, The Rev. Mitch Hescox, knows firsthand of our government’s fail-
                                                                              ure to ensure proper land restoration after energy and mineral extraction. His child-
                                                                              hood playground was left blighted and barren by un-reclaimed strip mines less than
                                                                              100 yards from his Cambria County, PA backdoor. Even today acid mine drainage
                                                                              erodes his family’s traditional hunting area.
                                                                                 Another opportunity for fiscal responsibility and wise stewardship of our resources
                                                                              is securing fair payment for lost, leaked, or vented methane and associated gases.
                                                                              A methane fee guarantees that just and fair royalties are paid to mineral-rights
                                                                              owners—whether they be an individual landowner or the Federal Government. Put-
                                                                              ting a fiscal incentive to encourage good practices and adequate maintenance rein-
                                                                              forces good stewardship of our precious natural resources and benefits all of us. It
                                                                              is simply wrong not to demand proper accounting for the all the valued product ex-
                                                                              tracted.
                                                                                 Another failure in stewardship for the American people has been not increasing
                                                                              the royalty rate for commodities extracted on Federal lands. Royalty rates have not
                                                                              changed for Federal Leases for over 100 years, since before the Great Depression
                                                                              and the presidency of Harding. According to the Government Accountability Office,
                                                                              our failure to increase royalties adequately and properly has cost the American peo-
                                                                              ple up to $300 million dollars per year by 2025 with a maximum 2% decrease in
                                                                              Federal production.16
                                                                                 Failure to increase royalties still is just another example of putting the oil/gas in-
                                                                              dustry before the health our children. This amounts to another handout to one of
                                                                              the most subsidized industries in the U.S.
                                                                                 Even with today’s high energy prices, analysis shows that changing bonding, insti-
                                                                              tuting a methane fee, and increasing royalties will not increase costs for Americans
                                                                              but is necessary to hold industry accountable.17
                                                                                 Our past and current tax system incentivizes profits for the fossil fuels industry
                                                                              while the costs have been borne in the hearts, lungs, minds, and even lives of our
                                                                              children and passed along as tax burden to the American people.
                                                                                 It is time to incentivize the well-being of our children and the American taxpayer
                                                                              instead of the fossil fuel industry. It’s past time for the American People to stop pay-
                                                                              ing to clean-up the fossil fuels industries’ messes. Our children’s health and the
                                                                              American economy cannot afford for us to repeat the mistakes of the past. We can-
                                                                              not levy the same burdens upon the next generation that earlier generations have
                                                                              levied upon us.

                                                                                13 IOGCC, Idle and Orphan Oil and Gas Wells 14 (2019), available at
                                                                              https://iogcc.ok.gov/sites/g/files/gmc836/f/iogcc_idle_and_orphan_wells_2021_final_web.pdf.
                                                                                14 GAO, BLM Should Address Risks from Insufficient Bonds to Reclaim Wells 11 (Sept. 2019),
                                                                              available at https://www.gao.gov/assets/gao-19-615.pdf.
                                                                                15 https://www.conservativestewards.org/wp-content/uploads/2021/10/CRS-bonding-
                                                                              analysis_FINAL.pdf.
                                                                                16 Oil, Gas, and Coal Royalties: Raising Federal Rates Could Decrease Production on Federal
                                                                              Lands but Increase Federal Revenue, https://www.gao.gov/products/gao-17-540
                                                                                17 Oil & Gas Reform Won’t Raise Prices at the Pump,




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                                                                                         Now is the time to exercise sound fiscal responsibility through good economic and
                                                                                       environmental stewardship. It’s time to defend our children’s health and future by
                                                                                       reducing methane leaks, stop wasting taxpayer money by cleaning up the fossil fuels
                                                                                       legacy, and supply real bonding and royalty reform.
                                                                                       Sincerely,
                                                                                       Rev. Dr. Jessica Moerman
                                                                                       Vice President, Science and Policy
                                                                                       Evangelical Environmental Network

                                                                                                                                       +++

                                                                                                                                 June 22, 2022
                                                                                       The Honorable Kathy Castor
                                                                                       Chair
                                                                                       House Select Committee on the Climate Crisis
                                                                                       H2–359 Ford Building
                                                                                       Washington, DC 20515
                                                                                       Dear Chair Castor:
                                                                                          Please accept the three recent scientific papers and economic reports included
                                                                                       herein for the record. These papers and reports highlight the need for strong federal
                                                                                       rules from the U.S. Environmental Protection Agency and Bureau of Land Manage-
                                                                                       ment that comprehensively target methane waste and pollution.
                                                                                          As these reports illustrate, strong action can both help protect frontline commu-
                                                                                       nities and create American jobs in the growing methane mitigation industry. These
                                                                                       regulations should include important safeguards, like phasing out intentionally-pol-
                                                                                       luting equipment by requiring zero emitting pneumatic controllers; address pollu-
                                                                                       tion and waste from unlit flares; and require frequent inspections of smaller wells
                                                                                       with leak-prone equipment. can both help protect frontline communities and create
                                                                                       American jobs in the growing methane mitigation industry.
                                                                                          EDF appreciates the opportunity to provide input into this critical issue. Thank
                                                                                       you for your consideration.
                                                                                       Sincerely,
                                                                                       Elizabeth Gore
                                                                                       Senior Vice President, Political Affairs


                                                                                       1. SpringerLink. ‘‘The demographic characteristics of populations living near oil and
                                                                                          gas wells in the USA,’’ a report by Jeremy Proville, Katherine A. Roberts, Adam
                                                                                          Peltz, Lisa Watkins, Elizabeth Trask, Dustin Wiersma. May 9, 2022.
                                                                                       Report available at:
                                                                                       https://www.edf.org/media/study-explores-demographics-communities-living-near-
                                                                                       oil-and-gas-wells
                                                                                       ABSTRACT
                                                                                         This study documents the prevalence of historically marginalized populations
                                                                                       (across age, income, education, race-ethnicity, and language) living near active oil
                                                                                       and gas wells throughout the USA, at both local and aggregated scales. This is per-
                                                                                       formed by way of areal apportionment using well location data and population char-
                                                                                       acteristics from the American Community Survey. A clustering analysis of
                                                                                       marginalized populations living near a high density of wells reveals four distinct re-
                                                                                       gions of high prevalence: southern California, southwest Texas, Appalachia, and
                                                                                       northwest New Mexico. At the nationwide scale, we find large absolute numbers of
                                                                                       people living near wells, including marginalized groups: nearly 18 million people in
                                                                                       total across the USA, many of which are Hispanic (3.3 million), Black (1.8 million),
                                                                                       Asian (0.7 million), and Native American (0.5 million), live below the poverty line
                                                                                       (3 million), older individuals (3 million), or young children (over 1 million). In cer-
                                                                                       tain states, this represents a large share of the total population—over 50% in the
                                                                                       case of West Virginia and Oklahoma. Estimates are subsequently compared to coun-




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                                                                                       ty level control groups to assess patterns of disproportionality. Wide variations are
                                                                                       found across regions and metrics, underscoring the locally specific nature of these
                                                                                       data. Our research contributes to the field of environmental justice by describing the
                                                                                       populations living near oil and gas wells.




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                                                                                    2. Datu Research. ‘‘Find Measure Fix: Jobs in the U.S. Methane Emissions Mitiga-
                                                                                       tion Industry,’’ a report by Marcy Lowe and Robin Lowe-Skillern. September 17,
                                                                                       2021.
                                                                                    Report available at:
                                                                                    https://www.edf.org/sites/default/files/content/FindMeasureFixReport2021.pdf
                                                                                    EXECUTIVE SUMMARY
                                                                                       The following report introduces policy makers, firms, researchers, and the general
                                                                                    public to the growing methane emissions mitigation industry, describing its recent
                                                                                    innovations, growth potential, and ability to provide U.S. jobs. These manufacturing
                                                                                    and service firms offer solutions to oil and gas companies across the United States
                                                                                    by finding, measuring, and mitigating methane emissions. Recent advances in
                                                                                    emerging technology and advanced data analytics are making it possible to do so
                                                                                    in ways never before possible.
                                                                                       Our research updates and builds upon two similar reports released in 2014 and
                                                                                    2017—demonstrating that this growing industry:
                                                                                       Creates U.S. Jobs. Firms in the industry offer well-paid employment opportuni-
                                                                                    ties across the country that provide upward mobility and often involve fieldwork
                                                                                    that cannot be offshored.
                                                                                       Saves Operators Money. Methane emissions mitigation reduces waste by keep-
                                                                                    ing otherwise lost product in the sales line.
                                                                                       Improves Environment and Climate. Addressing natural gas leaks across the
                                                                                    country reduces emissions of a highly potent greenhouse gas, while contributing to
                                                                                    cleaner air in surrounding areas.
                                                                                    SEVEN KEY RESEARCH FINDINGS ABOUT THE METHANE EMISSIONS
                                                                                       MITIGATION INDUSTRY
                                                                                     1) The industry is growing rapidly. Today it includes at least 101 manufacturing
                                                                                        firms (a 33-percent increase over our 2014 count) and 114 service firms (a 90-
                                                                                        percent increase over our 2017 count). Together, these firms have at least 748
                                                                                        employee locations nationwide.
                                                                                     2) The industry comprises dozens of job types, with annual salaries ranging from
                                                                                        $37,150 to $140,960 (as compared to the U.S. annual mean wage of $56,310
                                                                                        for all occupations).1 Common entry-level jobs such as assemblers and fabrica-
                                                                                        tors offer opportunity for upward mobility.
                                                                                     3) Most of the firms (70 percent) are small businesses, known to serve as an eco-
                                                                                        nomic engine for new job growth.
                                                                                     4) Nearly 25 percent of the manufacturing firms and over 40 percent of the serv-
                                                                                        ice firms were founded in the past 12 years, indicating a fast-growing industry.
                                                                                     5) Firms are adding new U.S. employee locations. In 2021, we identified a total
                                                                                        of 748 employee locations for manufacturing and service firms, an increase of
                                                                                        26 percent over the number previously identified.
                                                                                     6) Firms anticipate growing jobs. Of 57 firms that responded to our survey, 75
                                                                                        percent of the manufacturing firms and 88 percent of the service firms re-
                                                                                        ported that if future state or federal methane emission rules were put in place,
                                                                                        they would anticipate hiring more employees.
                                                                                     7) These jobs appear poised to grow soon, since the current Administration and
                                                                                        at least eight states are preparing either to introduce new methane rules or
                                                                                        expand the scope of existing ones.

                                                                                    3. Nature Communications. ‘‘Methane emissions from US low production oil and
                                                                                       natural gas well sites,’’ a report by Mark Omara, Daniel Zavala-Araiza, David
                                                                                       R. Lyon, Benjamin Hmiel, Katherine A. Roberts & Steven P. Hamburg. 2022.
                                                                                    Report available at:
                                                                                    https://www.nature.com/articles/s41467-022-29709-3
                                                                                    ABSTRACT
                                                                                       Eighty percent of U.S. oil and natural gas (O&G) production sites are low produc-
                                                                                    tion well sites, with average site-level production ≤15 barrels of oil equivalent per
                                                                                    day and producing only 6% of the nation’s O&G output in 2019. Here, we integrate
                                                                                    national site-level O&G production data and previously reported site-level CH4
                                                                                    measurement data (n = 240) and find that low production well sites are a dispropor-




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                                                                                    tionately large source of U.S. O&G well site CH4 emissions, emitting more than 4
                                                                                    (95% confidence interval: 3–6) teragrams, 50% more than the total CH4 emissions
                                                                                    from the Permian Basin, one of the world’s largest O&G producing regions. We esti-




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                                                                                                                                        64
                                                                                       mate low production well sites represent roughly half (37–75%) of all O&G well site
                                                                                       CH4 emissions, and a production-normalized CH4 loss rate of more than 10%—a fac-
                                                                                       tor of 6–12 times higher than the mean CH4 loss rate of 1.5% for all O&G well sites
                                                                                       in the U.S. Our work suggests that achieving significant reductions in O&G CH4
                                                                                       emissions will require mitigation of emissions from low production well sites.
                                                                                                                                        +++
                                                                                                                                  June 24, 2022
                                                                                            The Honorable Kathy Castor                        The Honorable Garret Graves
                                                                                            Chairwoman, House Select                          Ranking Member, House Select
                                                                                                Committee on the Climate Crisis                   Committee on the Climate Crisis
                                                                                            H2–359 Ford House Office Building                 H2–359 Ford House Office Building
                                                                                            Washington, DC 20515                              Washington, DC 20515
                                                                                            Dear Chairwoman Castor and Ranking Member Graves:
                                                                                          Clarke Valve (Clarke) commends you for holding this hearing on ‘‘Cutting Meth-
                                                                                       ane Pollution: Safeguarding Health, Creating Jobs, and Protecting Our Climate’’
                                                                                       and for drawing attention to this critical issue. Clarke appreciates the opportunity
                                                                                       to submit this letter to the Committee.
                                                                                          Control valves are the leading cause of methane emissions from oil and gas pro-
                                                                                       duction sites. Clarke has invested in American jobs and manufacturing, along with
                                                                                       its ingenuity, to eradicate 98 percent of these emissions. Headquartered in Rhode
                                                                                       Island, Clarke is a company that manufactures an innovative and efficient control
                                                                                       valve technology, called the Dilating Disk,1 that can capture, or prevent the release
                                                                                       of, methane emissions from pipelines and from every piece of equipment across all
                                                                                       aspects of oil and gas operations for which a control valve is required. Clarke’s Di-
                                                                                       lating Disk technology is certified to reduce virtually all control valve methane
                                                                                       leaks and emissions. So, when talking about reducing methane emissions from oil
                                                                                       and gas operations, the technology exists to achieve far greater reductions.
                                                                                          Such technology currently is being manufactured in the United States and being
                                                                                       sold both domestically and abroad. Clarke also will make the case that, while the
                                                                                       Environmental Protection Agency’s (EPA) recent Proposed Rule to reduce methane
                                                                                       emissions from new and existing oil and gas operations 2 represents progress, its
                                                                                       proposed 500 parts per million (ppm) leak definition (or detection limit) 3 will not
                                                                                       reduce methane emissions to a level that otherwise could be achievable and is there-
                                                                                       fore insufficient—and problematic.
                                                                                       Context
                                                                                          Control valves are essential equipment to the oil and gas industry: they regulate
                                                                                       pressure, temperature, and flow rates of liquids and gases. Unlike the pipes that
                                                                                       control valves are installed in, the control valve is the natural point of leakage for
                                                                                       any pressurized pipeline carrying methane or other greenhouse gases. Individual oil
                                                                                       and gas facilities can have hundreds or thousands of control valves, so there are
                                                                                       millions of valves installed today. As a reference point, the global market for control
                                                                                       valves is projected to reach $10.6 billion by 2025.4
                                                                                          Importantly, not all valves are the same. Most ‘‘typical’’ existing, or legacy, control
                                                                                       valves are certified to meet an international standard, referred to as the ISO 15848 5
                                                                                       ‘‘Class C,’’ or 500 parts per million (ppm), tightness rating (meaning these valves
                                                                                       are certified to prevent emissions above, or limit emissions to, 500 ppm).

                                                                                         1 The Dilating Disk meets the category definitions of industry control valve standards but is
                                                                                       referred to specifically as a Dilating Disk herein to prevent confusion with legacy control valve
                                                                                       designs.
                                                                                         2 Standards of Performance for New, Reconstructed, and Modified Sources and Emissions
                                                                                       Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review (Proposed Rule),
                                                                                       86 Fed. Reg. 63110 (Nov. 15, 2021).
                                                                                         3 EPA’s proposed performance standards for new and existing sources define 500 parts per
                                                                                       million (ppm) as a leak.
                                                                                         4 GlobeNewswire News Room, Report Linker, ‘‘The Global Control Valve Market Size Was Val-
                                                                                       ued at USD 5.5 Billion in 2020 and is Projected to Reach USD 10.6 Billion by 2025,’’ October
                                                                                       2, 2020, available at: www.globenewswire.com/news-release/2020/10/02/2102781/0/en/The-global-
                                                                                       control-valve-market-size-was-valued-at-USD-5-5-billion-in-2020-and-is-projected-to-reach-USD-
                                                                                       10-6-billion-by-2025-It-is-expected-to-grow-at-a-CAGR-of-14-2.html.




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                                                                                         5 International Organization for Standardization (ISO), ISO 15848–1:2015, Industrial valves—
                                                                                       Measurement, test and qualification procedures for fugitive emissions—Part 1: Classification sys-
                                                                                       tem and qualification procedures for type testing of valves, June 2015, available at: https://
                                                                                       www.iso.org/standard/61441.html.




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                                                                                       The ISO Standard’s ‘‘Class B’’ tightness rating is 100 ppm, and its ‘‘Class A’’ tight-
                                                                                    ness rating is 50 ppm.6 Several mature valve products meet both the ‘‘Class B’’ and
                                                                                    ‘‘Class A’’ tightness ratings. High grade seals that enable valves to achieve emis-
                                                                                    sions of 50 ppm or less typically cost less than $5.00 each.
                                                                                       Using such widely-available seal material as a standard feature, Clarke’s control
                                                                                    valves not only meet, but exceed, the ‘‘Class A’’ tightness rating. More specifically,
                                                                                    Clarke Valves reduce or limit emissions to 2 ppm, that is, they achieve 25
                                                                                    times greater emissions reductions than the most stringent current inter-
                                                                                    national standard.
                                                                                    The Problem and What is at Stake
                                                                                       EPA estimates that the oil and gas industry has a leak rate of 1.4 percent, which
                                                                                    equates to an estimated 8 million metric tons of methane emissions per year.7 The
                                                                                    Environmental Defense Fund (EDF) estimates a leak rate of 2.4 percent, or 13 mil-
                                                                                    lion metric tons per year of methane emissions.8 This latter amount of gas would
                                                                                    be enough to power up to 10 million homes for one year and would be worth ap-
                                                                                    proximately $2 billion.9 Despite efforts over time by EPA and by the oil and gas in-
                                                                                    dustry to mitigate emissions from harmful pollutants, reducing fugitive emissions
                                                                                    remains a major challenge. In fact, fugitive emissions—or leaks—from control
                                                                                    valves are estimated to account for approximately 60 percent of total fugitive
                                                                                    emissions.10




                                                                                      Clarke has used EPA’s methodology 11 to estimate methane emissions from exist-
                                                                                    ing—and prevalent—‘‘Class C,’’ or 500 ppm, control valves at well sites and com-
                                                                                    pressor stations. Based on an estimate that a single company would have, on aver-
                                                                                    age, more than 2,300 control valves in gas lift applications for its upstream oper-

                                                                                         6 Ibid.
                                                                                      7 Environmental Defense Fund (EDF), ‘‘Major Studies Reveal 60% More Methane Emissions,’’
                                                                                    available at: www.edf.org/climate/methane-studies.
                                                                                      8 Ibid.
                                                                                      9 Ibid.
                                                                                      10 Mackay, James E., and Kevin J. Smith. Monitoring and Containment of Fugitive Emissions




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                                                                                    from Valve Stems—Electrical Conductivity and Gas Adsorption Measurements on Metal Oxides.
                                                                                    Department of Chemical and Biological Engineering, University of British Columbia.
                                                                                      11 EPA’s correlational methodology.




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                                                                                                                                  66
                                                                              ations, the ‘‘Class C’’-rated valves would emit approximately 30 tons or 85 percent
                                                                              higher mass emissions (i.e., kilograms/hour (kg/hr)) over ten years than a Clarke
                                                                              Valve, which restricts emissions to 2 ppm. At the well pads, where at least 3 control
                                                                              valves are installed on more than 2,000 separators per company, emissions would
                                                                              exceed those of Clarke Valves by 73 tons per year.
                                                                                 Similarly, again using EPA’s correlation method, Clarke estimates that a single
                                                                              site with, on average, 30 compressor stations that have 6 control valves each (i.e.,
                                                                              180 valves total) would emit 2 tons more methane emissions over ten years than
                                                                              if Clarke Valves were used. To appreciate the magnitude of the impact, these values
                                                                              must be multiplied by tens of thousands of sites, from which methane emissions are
                                                                              affecting the health of employees and those in nearby communities, many of which
                                                                              are underserved.
                                                                              EPA’s Recent Proposed Rule to Reduce Methane Emissions from Oil and
                                                                                 Gas Operations
                                                                                 EPA’s recent Proposed Rule seeks to reduce fugitive methane and VOC emissions
                                                                              from new, modified, or reconstructed (hereinafter collectively referred to as new)
                                                                              sources and from existing sources at specified new well sites and at specified exist-
                                                                              ing well sites and compressor stations.
                                                                                 While commendable, Clarke encourages EPA to continue to further explore all op-
                                                                              tions to reduce these emissions, with a particular emphasis on control valves, where
                                                                              an immediate and significant impact can be achieved in the reduction of fugitive
                                                                              emissions.
                                                                                 Moreover, EPA’s proposal would only require companies to address leaks or emis-
                                                                              sions above 500 ppm.12 This 500 ppm definitional leak limit will lead to a significant
                                                                              amount of methane emissions accruing over time, thereby diminishing the
                                                                              robustness of EPA’s proposal, at least to some extent. It also would accommodate
                                                                              aging seal technology, while significant scientific and material advances have been
                                                                              available for the last few decades that easily enable manufacturers to meet a more
                                                                              stringent standard, as noted above. In fact, several valve manufacturers already are
                                                                              using widely-available, mature seal technology, such that their valves are achieving
                                                                              emissions below 50 ppm even after 100,000 cycles, which equates to 10 years of sim-
                                                                              ulated use. On the other hand, some of the largest valve manufacturers, and oil and
                                                                              gas companies who use the valves, will only adhere to the minimum requirements
                                                                              in law, which is why the new requirements must be as stringent as possible to
                                                                              achieve maximum emissions reductions.
                                                                                 Notably, EPA has issued Consent Decrees that contain a 100 ppm leak threshold
                                                                              for equipment repairs or replacements.13
                                                                              The Time is Now to Change Course
                                                                                 For these reasons and more, Clarke is urging the Committee and Congress to
                                                                              weigh in with EPA to urge the Agency to consider lowering methane emissions be-
                                                                              yond the currently-proposed levels and especially to change the definition of a
                                                                              ‘‘leak’’ from 500 parts per million to 50 parts per million (ppm). Fifty (50)
                                                                              ppm is consistent with the existing international ISO Standard’s ‘‘Class A’’ tightness
                                                                              rating for control valves and is readily achievable.
                                                                                 To the extent practicable, another important step would involve you and your col-
                                                                              leagues working to preserve the methane incentives that are contained in the
                                                                              House-passed Budget Reconciliation package.14
                                                                                 Clarke appreciates the opportunity to share this information and stands ready to
                                                                              be a resource at any time.
                                                                              Sincerely,
                                                                              /s/ Kyle Daniels
                                                                              Founder and CEO, Clarke Valve
                                                                              42 Whitecap Drive
                                                                              North Kingstown, RI 02852
                                                                              (401) 667–7880
                                                                              Email: Kyle.Daniels@clarkevalve.com

                                                                                 12 The proposed performance standards for new and existing sources define 500 parts per mil-
                                                                              lion (ppm) as a leak.
                                                                                 13 E.g., United States of America v. WRB Refining LP and Phillips 66 Co. (Consent Decree),
                                                                              No. 3:18-cv-01484.
                                                                                 14 H.R. 5376, Rept. No. 117–130, November 19, 2021, available at:




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                                                                              https://www.congress.gov/bill/117th-congress/house-bill/5376/text.




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                                                                                Ms. CASTOR. Thanks again. This is a critical topic, and we appre-
                                                                              ciate the insightful testimony, again, and the participation of mem-
                                                                              bers.
                                                                                The committee is adjourned.
                                                                                [Whereupon, at 10:38 a.m., the committee was adjourned.]
                                                                                                       United States House of Representatives
                                                                                                       Select Committee on the Climate Crisis

                                                                                                         Hearing on June 24, 2022
                                                                                                       ‘‘Cutting Methane Pollution:
                                                                                      Safeguarding Health, Creating Jobs, and Protecting Our Climate’’

                                                                                                                Questions for the Record

                                                                                                                    Patrice Tomcik
                                                                                                             Senior National Field Manager
                                                                                                                 Moms Clean Air Force
                                                                                                               THE HONORABLE KATHY CASTOR

                                                                                1. Could you please tell us about why you are concerned about oil and
                                                                              gas operations so close to your children’s schools?
                                                                                 Children who live, learn, or play near oil and gas operations face a higher risk
                                                                              of exposure to the oil and gas industry’s harmful air pollution. In my children’s
                                                                              Mars Area school district located in Mars, Pennsylvania, there are five unconven-
                                                                              tional gas well pads with multiple gas wells on them and many gathering pipelines.
                                                                              The closest wells that have been fracked are approximately a half mile away from
                                                                              the school campus that puts 3,200 students’ health at risk. Across our nation, more
                                                                              than 3.9 million children go to school within a half mile of oil and gas operations
                                                                              and more than 17 million people live within a half mile of active oil and gas oper-
                                                                              ations. Parents like me and community members are very concerned about the pol-
                                                                              lution that can be emitted by these oil and gas operations and what their families
                                                                              might be exposed to. I know wherever oil and gas is being drilled, compressed, and
                                                                              processed, you can find methane leaking along with harmful volatile organic com-
                                                                              pounds (VOCs). Air pollution from the oil and gas operations can cause respiratory
                                                                              diseases, asthma attacks, reproductive problems, blood disorders, neurological prob-
                                                                              lems, cancer, and contribute to climate change, which further harms health. Chil-
                                                                              dren are especially vulnerable to air pollution because their lungs and brains are
                                                                              still developing until early adulthood. In our family, my boys both play outdoor
                                                                              sports for school. I am very concerned about what they are breathing into their still-
                                                                              developing lungs. Comprehensive EPA rules would cut methane pollution and have
                                                                              the benefit of reducing associated harmful VOCs, such as benzene, that can cause
                                                                              cancer. As a parent of a child who is a cancer survivor, I don’t want any parent
                                                                              to have to suffer the anguish of watching a child battling through cancer.
                                                                                2. How can we best protect communities from the harmful air pollution
                                                                              from the oil and gas industry?
                                                                                 Oil and gas production comes at a high cost to public health and climate stability.
                                                                                 There is never a time when it is acceptable to knowingly compromise the health
                                                                              of communities living on the frontlines of oil and gas. And there is a real cost associ-
                                                                              ated with climate change as communities’ health and safety are impacted by wild-
                                                                              fires, drought, flooding and extreme heat. Children across the nation need strong
                                                                              federal standards to create baseline methane protections, especially for states that
                                                                              have failed to enact meaningful oil and gas methane protections. This is why it is
                                                                              so important that the EPA finalize a comprehensive methane rule to eliminate rou-
                                                                              tine flaring, require the use of non-polluting equipment, take into account third-
                                                                              party air monitoring, and include frequent inspections for smaller wells with leak-
                                                                              prone equipment.
                                                                                 Communities need protections from routine flaring. When companies rush to ex-
                                                                              tract oil, some forgo investments necessary to capture and sell gas and instead burn
                                                                              it as a waste product through flaring, emitting a host of climate and health-harming
                                                                              pollutants. Many flares have been found to malfunction or fail entirely, spewing




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                                                                              methane directly into the atmosphere. EPA must follow the lead of states like Colo-




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                                                                              rado and New Mexico and move to eliminate pollution from routine flaring except
                                                                              in emergency situations.
                                                                                 Communities need protections from intentionally-polluting equipment. Inten-
                                                                              tionally-polluting equipment like pneumatic controllers are a big source of methane
                                                                              pollution that needs to be phased out in favor of zero-emitting alternatives in the
                                                                              EPA methane rule.
                                                                                 Communities need monitoring in their neighborhoods to be acknowledged by the
                                                                              EPA. Having the EPA recognize third party methane emissions estimates based on
                                                                              data rather than relying on oil and gas operator’s self reported estimated emissions
                                                                              would give a more accurate picture of the methane pollution problem. The use of
                                                                              accessible proven monitoring technologies such as frequent aerial surveys and infra-
                                                                              red technology (FLIR) would allow the EPA to accept and prioritize monitoring re-
                                                                              sults to ensure major leaks that are harming nearby communities are fixed more
                                                                              quickly.
                                                                                 Communities need protections from small wells with leak prone equipment. A new
                                                                              study published in the journal Nature Communications reveals that small oil and
                                                                              gas wells that have leak prone equipment are responsible for approximately half of
                                                                              the methane emitted from all well sites in the United States while accounting for
                                                                              only 6% of the nation’s oil and gas production.(1) Pollution from small wells has a
                                                                              very real impact on the climate and on the health of communities who live near
                                                                              these facilities. Nearly 8 million people across the country live within half a mile
                                                                              of these well sites. Not only do these facilities emit significant volumes of the potent
                                                                              greenhouse gas methane, they also leak other pollution that is toxic to human
                                                                              health and can severely deteriorate air quality. A new mapping tool from the Envi-
                                                                              ronmental Defense Fund shows how a disproportionately large number of commu-
                                                                              nities of color, people living below the poverty line, older individuals and young chil-
                                                                              dren live near small wells.(2)
                                                                                 3. Do you think Congress should invest to help states reduce their green-
                                                                              house gas pollution and adapt to the climate changes we can no longer
                                                                              avoid?
                                                                                 Because we know that climate impacts will continue to unfold in the coming dec-
                                                                              ades, we do need Congress to invest in helping states create robust adaptation plans
                                                                              and infrastructure. At the same time, we need to prioritize mitigation efforts, be-
                                                                              cause everything we do to limit methane pollution and other forms of greenhouse
                                                                              gas emissions now can help prevent future harm to our children and later genera-
                                                                              tions. Investment in adaptation and mitigation are both essential in our response
                                                                              to the climate crisis. We need Congress, the White House, the EPA and other
                                                                              change agents to work together to solve our methane pollution problem.
                                                                                 The oil and gas industry is the largest industrial emitter of methane pollution.
                                                                              And the industry has readily available, cost-effective solutions for significantly cut-
                                                                              ting pollution. Industry leaders acknowledge they can do much better, but only gov-
                                                                              ernment action can ensure that all of the industry cleans up the wide-spread meth-
                                                                              ane pollution for which they are responsible. The historic Infrastructure Investment
                                                                              and Jobs Act passed by Congress in November 2021 provided $4.7 billion to help
                                                                              states and tribes plug and remediate orphaned oil and gas wells. Millions of Ameri-
                                                                              cans live within one mile of hundreds of thousands of orphaned oil and gas wells
                                                                              that jeopardize public health and safety by emitting harmful pollutants including
                                                                              methane and volatile organic compounds (VOCs). In addition, the Methane Emis-
                                                                              sions Reduction Program (MERP) in the Inflation Reduction Act of 2022 includes
                                                                              much-needed investments to curb methane pollution and puts a price on emissions
                                                                              to incentivize operators to deploy common sense solutions to stop them. The pro-
                                                                              gram would complement and reinforce the enforceable methane pollution standards
                                                                              currently being developed by EPA. Each tool plays an important role in tackling
                                                                              methane pollution. Strong and comprehensive pollution standards from EPA are es-
                                                                              sential to ensure protective, broad and equitable reductions for all communities. A
                                                                              charge on especially wasteful levels of methane emissions can discourage pollution
                                                                              and hold industry accountable for its impacts. The charge on methane pollution,
                                                                              working in conjunction with strong and protective EPA standards, will drive deep
                                                                              and equitable methane pollution reductions for all communities and to ensure that
                                                                              polluters—not the public—bear the costs of controlling their own pollution.
                                                                                 4. How would strong Federal rules on methane pollution help commu-
                                                                              nities like yours in Pennsylvania?
                                                                                 Pennsylvania is the second largest natural gas producer in the nation. The oil and
                                                                              gas industry in the state is responsible for emitting over 1 million metric tons of
                                                                              methane annually from both unconventional and conventional wells. Wherever there




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                                                                                                                                  69
                                                                              being emitted that are impacting public health and contributing to climate change.
                                                                              Over the past ten years there has been a significant increase in the scientific knowl-
                                                                              edge about the health risks from living in close proximity to oil and gas operations
                                                                              with many studies coming from Pennsylvania data. In Butler county where I live,
                                                                              a health study found that living in close proximity to natural gas wells was associ-
                                                                              ated with having lower birth weight babies.(3) Low birth weight babies are at in-
                                                                              creased risk of early death, infections, and learning disabilities. Research has also
                                                                              found that living close to oil and gas operations is linked to other adverse birth out-
                                                                              comes, such as preterm birth, congenital heart defects, and neural tube defects.(4)
                                                                              Strong methane protections would help to protect babies from harmful oil and gas
                                                                              pollution. In Pennsylvania, we also have many small wells that have equipment
                                                                              prone to leaks. A recent study found that small wells account for only 6% of produc-
                                                                              tion, but half of methane emissions in the U.S. The EPA needs to require frequent
                                                                              inspections of these small wells that account for an outsized amount of methane
                                                                              emissions.
                                                                                 A strong EPA methane rule could quickly and significantly reduce methane pollu-
                                                                              tion and other harmful air pollutants from oil and gas operations. This is one of the
                                                                              best levers we have to slow the rate of climate change now and help clean up the
                                                                              air to protect the health of children living near oil and gas operations. There are
                                                                              already existing technologies to find methane leaks, which can be as simple as fix-
                                                                              ing a leaking pipe or closing a tank hatch. Some states like New Mexico and Colo-
                                                                              rado have acted to put strong methane rules in place but other states have not, like
                                                                              Pennsylvania. This is why we need EPA to act and create a strong federal regu-
                                                                              latory baseline for all states.
                                                                                5. Why is it important for frontline and EJ communities to have an active
                                                                              role in decisions related to the design and implementation of regulations
                                                                              and legislation?
                                                                                 As regulations and legislation are being considered, frontline and environmental
                                                                              justice communities must have an active role in decisions related to the design and
                                                                              implementation of regulations and legislation that impact their communities
                                                                              throughout the entire process. This stakeholder engagement is more important than
                                                                              ever with EPA methane rules because—as a new mapping tool by the Environ-
                                                                              mental Defense Fund reinforces—a disproportionate number of communities of
                                                                              color, people living below the poverty line, older adults and young children live in
                                                                              counties near oil and gas wells.(5) Prioritizing protections for environmental justice
                                                                              and frontline communities is imperative as they have historically shouldered an
                                                                              outsize burden from the impacts of air pollution and the climate crisis. We cannot
                                                                              have a country that includes ‘‘sacrifice zones.’’ Oil and gas air pollution adds to the
                                                                              burden of existing pollution problems in underserved, low-income communities, ex-
                                                                              acerbating inequities and putting families at increased risk of serious health issues.
                                                                              Strong and comprehensive oil and gas methane pollution standards from EPA are
                                                                              essential to ensure protective, broad and equitable reductions for all communities.
                                                                              And once methane rules are finalized, it is important that Congress properly funds
                                                                              the EPA to carry out the enforcement of rules in order to protect the health of com-
                                                                              munities. Enforceable pollution limits are needed to ensure pollution reductions ben-
                                                                              efit all communities.
                                                                              References Page
                                                                                   (1) https://www.nature.com/articles/s41467-022-29709-3
                                                                                (2) https://blogs.edf.org/energyexchange/2022/07/19/interactive-map-who-is-

                                                                              impacted-most-by-overlooked-pollution-from-americas-small-oil-and-gas-wells/#more-
                                                                              21927
                                                                                (3) https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0126425
                                                                                (4) https://www.momscleanairforce.org/resources/how-oil-and-gas-operations-impact-

                                                                              your-babys-health/
                                                                                (5) https://blogs.edf.org/energyexchange/2022/07/19/interactive-map-who-is-

                                                                              impacted-most-by-overlooked-pollution-from-americas-small-oil-and-gas-wells/#more-
                                                                              21927




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                                                                                                                Questions for the Record

                                                                                                             Dr. Robert L. Kleinberg
                                                                                                            Senior Research Scholar
                                                                                                Columbia University Center on Global Energy Policy
                                                                                                               THE HONORABLE KATHY CASTOR

                                                                                1. Dr. Kleinberg, in your testimony, you mentioned that reducing harmful
                                                                              methane pollution is cost effective and you described the suite of new tech-
                                                                              nologies that are available. Could you please elaborate on how new tech-
                                                                              nologies enable cost-effective reduction of methane pollution?
                                                                                 Achieving net zero carbon dioxide emissions will require a multi-decadal, multi-
                                                                              trillion dollar reorganization of the ways we use energy, which will have profound
                                                                              economic and social consequences [IEA, 2021]. In contrast, while anthropogenic
                                                                              methane emissions from the oil and gas industry are responsible for a substantial
                                                                              part of our climate change problem, reducing that part of the greenhouse gas inven-
                                                                              tory is relatively simple and surprisingly inexpensive. In the context of the oil and
                                                                              gas industry, methane emission reduction consists of two distinct phases. First,
                                                                              emitters must be detected and quantified. Second, they must be remediated.
                                                                              (a) Detection and Quantification
                                                                                 Detection of gas leaks from petroleum and natural gas systems is not trivial.
                                                                              Intermittent super-emitters are responsible for a large fraction of methane losses to
                                                                              the atmosphere [House Committee on Science, Space and Technology, 2022]. Re-
                                                                              peated rounds of measurements and repairs will eventually reduce emissions, but
                                                                              persistence is required [Kemp, 2021].
                                                                                 Quantification is important because emission rates from individual sources span
                                                                              the range from less than 30 grams per hour to more than 100 tons per hour, more
                                                                              than three million times larger. It is a poor use of resources to focus attention on
                                                                              tiny leaks when vents thousands of times larger are allowed to persist. Yet, this is
                                                                              the situation today [Kleinberg, 2021].
                                                                                 Due to technological advances in aerial surveillance, mostly pioneered by U.S. re-
                                                                              searchers and companies, overflights of oil- and gas-productive basins are effective
                                                                              and inexpensive ways to detect and quantify methane emitters [Kleinberg 2022a,
                                                                              Section 3.1.1]. As pointed out in my written testimony to the Select Committee, a
                                                                              survey of 45,000 Permian Basin wells, during which methane emissions were quan-
                                                                              tified and operators were identified, cost about the same as drilling and fracking a
                                                                              single well [Kleinberg, 2022b].
                                                                                 Continuous monitoring of oil and gas infrastructure combined with prompt repair
                                                                              dramatically reduces the amount of methane entering the atmosphere [LongPath,
                                                                              2022]. While aerial surveillance, with its considerable economies of scale, is usefully
                                                                              employed over all oil and gas infrastructure, continuous monitoring is best suited
                                                                              for sites with emission-prone equipment. These include gas processing plants, refin-
                                                                              eries, biogas and biomethane production facilities, liquefied natural gas terminals,
                                                                              and well sites or other facilities with storage vessels. Simple wells with minimal an-
                                                                              cillary hardware, which constitute the majority of upstream sites, are unlikely to
                                                                              need this service. Therefore, continuous monitoring services can be deployed selec-
                                                                              tively, where they are most likely to be useful.
                                                                              (b) Remediation
                                                                                The most current and authoritative estimates of the cost of remediating methane
                                                                              emissions are provided by the International Energy Agency [IEA, 2022a]. These esti-
                                                                              mates are more reliable for the United States than for other nations [IEA, 2022b].
                                                                              According to the IEA, 13,824 kilotons (kt) of methane was lost from U.S. oil and
                                                                              gas operations in 2021, of which the estimated technical abatement potential is
                                                                              9,648 kt, 70% of the total. The share of emissions that could be avoided at no net
                                                                              cost is about 2,500 kt or 18% [IEA, 2022a].
                                                                                The IEA marginal abatement cost curve is shown in Figure 1. Unlike nations such
                                                                              as China or Russia, most abatement measures that have not already been imple-
                                                                              mented in the U.S. impose a net cost on the industry. This is consistent with the
                                                                              widely held belief within the U.S. oil and gas industry that ‘‘we don’t leave money
                                                                              on the table’’. According to IEA estimates, the net cost of eliminating 9,648 kt of
                                                                              methane would be approximately $1.7 billion, or $176/ton of methane. This is far
                                                                              less than the most recent estimate of the social cost of methane, $1500/ton of meth-




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                                                                              ane [IWG, 2021]. It is also far smaller than the LDAR-focused regulation 40 CFR




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                                                                              60 OOOOa of 2016, which proposed to reduce U.S. oil and gas methane emissions
                                                                              from regulated segments by 2% at a cost of $1340/ton of methane [Kleinberg, 2021].
                                                                                At a cost of $1.7 billion, eliminating 70% of our oil and gas methane emissions
                                                                              would not have a material impact on our oil and gas industry, or on energy prices.
                                                                              U.S. oil and gas revenue in the United States averaged $157 billion per year be-
                                                                              tween 2010 and 2020 [Statista, 2021] and capital expenditures are expected to ex-
                                                                              ceed $100 billion in 2022 and each of the years thereafter [AOGR, 2021].
                                                                              (c) Summary
                                                                                 The U.S. oil and gas industry has already remediated almost all the methane
                                                                              emitters that reduce operating efficiency and profitability. Additional incentives or
                                                                              regulatory measures are required to reduce emissions further. Improved methods for
                                                                              finding and quantifying methane emissions sources will enable operators and serv-
                                                                              ice providers to find emitters more efficiently, and to prioritize repairs so that the
                                                                              largest emitters are fixed first. Quick detection and prioritized repairs will result
                                                                              in less methane entering the atmosphere.
                                                                                 2. How could U.S. leadership on cutting methane pollution influence
                                                                              other countries to adopt similar technologies and strategies?
                                                                              (a) American Petroleum Engineering Practice is Considered Standard Around the
                                                                                  World.
                                                                                There are a number of reasons why American engineering practice is followed
                                                                              widely around the world:
                                                                                • The United States is the world’s leading producer of both crude oil and natural
                                                                                  gas [EIA, 2021].
                                                                                • From my personal experience of forty years in the international oil and gas in-
                                                                                  dustry, I have found the leading schools of petroleum engineering, educating pe-
                                                                                  troleum engineers from all over the world, are largely in the United States.
                                                                                  These include Louisiana State University, the University of Texas at Austin,
                                                                                  Texas A&M, and the University of Tulsa, among many others.
                                                                                • The professional societies which set engineering standards and disseminate
                                                                                  technical information are mostly based in the United States. These include the
                                                                                  Society of Petroleum Engineers, the American Association of Petroleum Geolo-
                                                                                  gists, and the American Petroleum Institute.
                                                                                This does not imply that American practice is automatically adopted everywhere,
                                                                              but it is the baseline against which local practices are compared. This is particularly
                                                                              true in the health, safety, and environment (HSE) arena. Over the course of my ca-
                                                                              reer, HSE standards have been globally upgraded, largely led by U.S.- and Euro-
                                                                              pean-based international oil companies (IOCs) such as ExxonMobil, Chevron, and
                                                                              Shell.
                                                                              (b) The United States has been the Global Leader in the Detection and Characteriza-
                                                                                   tion of Methane Emissions in the Oil and Gas Industry.
                                                                                In 1996 the U.S. Environmental Protection Agency published the monumental fif-
                                                                              teen volume Methane Emissions from the Natural Gas Industry [EPA, 1996]. These
                                                                              documents are the foundation of the emission factor inventories universally used to
                                                                              report national methane emissions to the Secretariat of the United Nations Frame-
                                                                              work Convention on Climate Change [UNFCCC, 2022].
                                                                                Not every nation matches the meticulous record keeping of the United States. The
                                                                              reports of the Russian Federation are particularly egregious examples of the incon-
                                                                              sistent application of the emission factor method [Kleinberg, 2022a]. The advantage
                                                                              of a measurement-based reporting system is that nations will not be able to report
                                                                              superior performance by merely changing a multiplier on a spreadsheet, as per-
                                                                              mitted by the present reporting system.
                                                                              (c) The United States Continues to be the Global Leader in the Detection and Charac-
                                                                                   terization of Methane Emissions in the Oil and Gas Industry.
                                                                                 Remarkably, in the absence of government regulation or an established market,
                                                                              a methane emission characterization industry has sprung up, which is dominated
                                                                              by U.S. technology and service providers. This is detailed in my written testimony
                                                                              to the Select Committee [Kleinberg, 2022b].
                                                                                 Diffusion of these technologies to other nations is in its early stages. Measure-
                                                                              ment campaigns aligned with American principles have already been undertaken in
                                                                              Canada [MacKay, 2021], Mexico [Zavala-Araiza, 2021], and China [Zhang, 2021].




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                                                                              Technology diffusion will accelerate if markets for the new methods are encouraged




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                                                                              to grow. Emission reduction incentives and smart regulation encourage the dissemi-
                                                                              nation of new technology, with associated start-up business formation, small busi-
                                                                              ness vitality, and economies of scale. As technology improves and costs decline,
                                                                              methane reduction methods will spread to other countries. This story is common in
                                                                              the petroleum industry. My own oilfield innovations have benefited from this dy-
                                                                              namic.
                                                                                 The adoption of a Carbon Border Adjustment Mechanism by the European Union,
                                                                              if extended to fossil fuels, would also provide powerful encouragement to oil, gas,
                                                                              and coal exporting nations to extend and routinize the use of these technologies.
                                                                              (d) Summary
                                                                                There is no guarantee that other nations will follow our example should the
                                                                              United States adopt new technologies and strategies for finding and reducing meth-
                                                                              ane emissions. However, logic and experience provide evidence that the United
                                                                              States can set a standard for responsible practices in the oil and gas industry.
                                                                              Based on my long experience in this industry, I am fairly certain that if the United
                                                                              States does not set a good example, most other nations will see no need to do any
                                                                              better.
                                                                              References
                                                                                AOGR, 2021. U.S. Spending Rebound Sets Stage for Higher Costs. American Oil
                                                                              & Gas Reporter, November 2021.
                                                                              https://www.aogr.com/web-exclusives/exclusive-story/us-spending-rebound-sets-stage-
                                                                              for-higher-costs
                                                                                EIA, 2021. United States continued to lead global petroleum and natural gas pro-
                                                                              duction in 2020. U.S. Energy Information Administration, Today in Energy, 19 July
                                                                              2021.
                                                                              https://www.eia.gov/todayinenergy/detail.php?id=48756
                                                                                EPA, 1996. Methane Emissions from the Natural Gas Industry, EPA—600/R–96–
                                                                              080a, 15 volumes, U.S. Environmental Protection Agency, June 1996.
                                                                              https://www.epa.gov/natural-gas-star-program/methane-emissions-natural-gas-industry
                                                                                EPA, 2022. Coal Mine Methane Units Converter. U.S. Environmental Protection
                                                                              Agency, 28 July 2022.
                                                                              https://www.epa.gov/cmop/coal-mine-methane-units-converter
                                                                                House Committee on Science, Space and Technology, 2022. Seeing CH4 Clearly:
                                                                              Science-Based Approaches to Methane Monitoring in the Oil and Gas Sector. U.S.
                                                                              House of Representatives Committee on Science, Space, and Technology, Majority
                                                                              Staff Report, June 2022.
                                                                              https://science.house.gov/imo/media/doc/science_committee_majority_staff_report_
                                                                              seeing_ch4_clearly.pdf
                                                                                House Select Committee on the Climate Crisis, 2022. Cutting Methane Pollution:
                                                                              Safeguarding Health, Creating Jobs, and Protecting Our Climate, Hearing, 24 June
                                                                              2022.
                                                                              https://climatecrisis.house.gov/committee-activity/hearings/cutting-methane-pollution-safe-
                                                                              guarding-health-creating-jobs-and-0
                                                                                ICF, 2016. Economic Analysis of Methane Emission Reduction Potential from Nat-
                                                                              ural Gas Systems. ICF International, May 2016.
                                                                              https://onefuture.us/wp-content/uploads/2018/07/ICF-Study.pdf
                                                                                IEA, 2021. Net Zero by 2050: A Roadmap for the Global Energy Sector. Inter-
                                                                              national Energy Agency, May 2021.
                                                                              https://www.iea.org/reports/net-zero-by-2050
                                                                                IEA, 2022a. Methane Tracker Data Explorer, Methane Abatement Potential in Oil
                                                                              and Gas, United States. International Energy Agency, 23 February 2022.
                                                                              https://www.iea.org/articles/methane-tracker-data-explorer
                                                                                IEA, 2022b. Global Methane Tracker Documentation, 2022 Version. International
                                                                              Energy Agency, 23 February 2022.
                                                                              https://www.iea.org/reports/global-methane-tracker-2022
                                                                              https://iea.blob.core.windows.net/assets/b5f6bb13-76ce-48ea-8fdb-
                                                                              3d4f8b58c838/GlobalMethaneTracker_documentation.pdf
                                                                                IWG, 2021. Technical Support Document: Social Cost of Carbon, Methane, and Ni-
                                                                              trous Oxide: Interim Estimates under Executive Order 13990, Interagency Working
                                                                              Group on Social Cost of Greenhouse Gases, February 2021.
                                                                              https://www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_




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                                                                                 C.E. Kemp, A.P. Ravikumar, 2021. New Technologies Can Cost Effectively Reduce
                                                                              Oil and Gas Methane Emissions, but Policies Will Require Careful Design to Estab-
                                                                              lish Mitigation Equivalence, Environmental Science and Technology, 55, 9140–9149.
                                                                              https://doi.org/10.1021/acs.est.1c03071
                                                                                 Kleinberg, R.L., 2021. Reducing Emissions of Methane and Other Air Pollutants
                                                                              from the Oil and Natural Gas Sector: Recommendations to the Environmental Pro-
                                                                              tection Agency. Comment submitted by Robert L. Kleinberg, Posted by the Environ-
                                                                              mental Protection Agency on July 6, 2021.
                                                                              https://www.regulations.gov/comment/EPA-HQ-OAR-2021-0295-0035
                                                                              Data File: Public submission posted by the EPA. August 2, 2021.
                                                                              https://www.regulations.gov/comment/EPA-HQ-OAR-2021-0295-0071
                                                                                 Kleinberg, R.L., 2022a. Methane Emissions from the Fossil Fuel Industries of the
                                                                              Russian Federation, EarthArXiv, 22 July 2022.
                                                                              https://eartharxiv.org/repository/view/3342/
                                                                              https://doi.org/10.31223/X57D13
                                                                                 Kleinberg, R.L., 2022b. Testimony of Dr. Robert L. Kleinberg. House of Represent-
                                                                              atives Select Committee on the Climate Crisis, ‘‘Cutting Methane Pollution: Safe-
                                                                              guarding Health, Creating Jobs, and Protecting Our Climate,’’ 24 June 2022.
                                                                              https://docs.house.gov/meetings/CN/CN00/20220624/114942/HHRG-117-CN00-
                                                                              Wstate-KleinbergR-20220624.pdf
                                                                                 LongPath, 2022. Comment submitted by LongPath Technologies, Inc. et al. Posted
                                                                              by the Environmental Protection Agency on Feb 2, 2022.
                                                                              https://www.regulations.gov/comment/EPA-HQ-OAR-2021-0317-0759
                                                                                 MacKay, K., et al., 2021. Methane emissions from upstream oil and gas produc-
                                                                              tion in Canada are underestimated, Scientific Reports, 11, 8041.
                                                                              https://doi.org/10.1038/s41598-021-87610-3
                                                                                 Statista, 2021. Oil and gas industry revenue in the United States from 2010 to
                                                                              2020. Statista, 13 October 2021.
                                                                              https://www.statista.com/statistics/294614/revenue-of-the-gas-and-oil-industry-in-the-
                                                                              us
                                                                                 UNFCCC, 2022. National Inventory Submissions 2003–2022; 2022 Annex I Party
                                                                              GHG Inventory Submissions, United Nations Framework Convention on Climate
                                                                              Change.
                                                                              https://unfccc.int/ghg-inventories-annex-i-parties/2022
                                                                                 Zavala-Araiza, D., 2021. A tale of two regions: methane emissions from oil and
                                                                              gas production in offshore/onshore Mexico. Environmental Research Letters, 16,
                                                                              024019.
                                                                              https://doi.org/10.1088/1748-9326/abceeb
                                                                                 Zhang, Y., et al., 2021. Assessment of 2010–2017 methane emissions from China
                                                                              with satellite observations, American Geophysical Union, 2021, Oral Presentation
                                                                              A32A–03.




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                                                                                                                Questions for the Record

                                                                                                               Dr. Caroline Alden
                                                                                                Co-Founder and Vice President, Product and Markets
                                                                                                           LongPath Technologies, Inc.
                                                                                                               THE HONORABLE KATHY CASTOR

                                                                                   1. How would strong Federal rules complement state regulations?
                                                                                 Currently, several states are leaders in regulating methane monitoring and emis-
                                                                              sions reductions. However, other states have not implemented methane rules, re-
                                                                              sulting in a hodgepodge of regulations across state lines. Operators therefore must
                                                                              keep track of different combinations of rules in different areas of operation.
                                                                                 If strong Federal rules for methane monitoring and emissions mitigation were put
                                                                              into place, it would create a more homogenized compliance landscape for operators.
                                                                              A key element of a strong Federal regulation that could encourage broad adoption
                                                                              (and removal of duplication) by states would be for regulations to be performance-
                                                                              based rather than prescriptive.
                                                                                 Currently, we believe that EPA can push much further in the direction of per-
                                                                              formance-based specifications, and much further away from rule language that pre-
                                                                              scribes either operation of equipment or methods for deployment. A performance-
                                                                              based rule would, for example, specify the frequency with which all regulated equip-
                                                                              ment must be ‘‘scanned’’ (whether by aircraft, OGI camera, continuous monitoring
                                                                              device or other technology) and the size of emission that must be ‘‘seeable’’ (thresh-
                                                                              old of detection). A performance-based rule would include a technology-neutral ma-
                                                                              trix of options, each with an equivalent set of specifications (frequency of scanning
                                                                              all equipment and threshold of detection) and each with an equivalent work practice
                                                                              or set of follow-up requirements. A performance-based rule would not carve out spe-
                                                                              cific technologies or work practices into separate categories but would instead in-
                                                                              clude all modes of monitoring under the same umbrella, with separate work prac-
                                                                              tices and follow-up requirements to achieve equivalency in emissions reductions and
                                                                              operator obligations.
                                                                                 The U.S. is at a pivotal and very exciting moment, with an opportunity for mean-
                                                                              ingful regulation that can provide measurable and demonstrable emissions reduc-
                                                                              tions while simultaneously offering industry and technological innovation. To
                                                                              achieve sustained emissions reductions, rules should use performance-based metrics
                                                                              and require measurements to demonstrate reductions.

                                                                                                                Questions for the Record

                                                                                                                    Sarah Ann Smith
                                                                                                                   Chief of Programs
                                                                                                                  Clean Air Task Force
                                                                                                               THE HONORABLE KATHY CASTOR

                                                                                1. Abandoned wells can contribute to methane pollution and plugging
                                                                              them has health and safety benefits as well. The Bipartisan Infrastructure
                                                                              Law invests $4.7 billion in helping states and tribes and our federal agen-
                                                                              cies plug abandoned wells across the country, and it will likely create thou-
                                                                              sands of jobs, especially in traditional energy producing communities. How
                                                                              would efforts to plug abandoned wells help create good paying jobs? More
                                                                              generally, how would cutting harmful methane pollution from the oil and
                                                                              gas industry could help create jobs?
                                                                                Actions to reduce methane provide a multitude of high-quality jobs, in addition
                                                                              to the climate and public health benefits from such actions. In an upcoming report,
                                                                              Clean Air Task Force analyzed the jobs that would be created in two cases: 1) a
                                                                              plan to reduce methane from the oil and gas sector by 65%,1 and 2) the Environ-
                                                                              mental Protection Agency’s November 2021 proposed updated standards for new and


                                                                                1 Clean Air Task Force (‘‘CATF’’), Oil & Gas Methane: Mapping the Path to a 65% Reduction




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                                                                              modified sources and emissions guidelines for existing sources.2 In each case, Clean
                                                                              Air Task Force (CATF) estimated the jobs that would be created by measures to ad-
                                                                              dress the four most important emissions sources covered by the proposed rules:
                                                                              leaks, pneumatic equipment, storage vessels, and compressors. Overall, CATF has
                                                                              found that strong actions that would reduce methane by 65% would create nearly
                                                                              220,000 total jobs, including manufacturing jobs from upfront capital investment as
                                                                              well as continuing jobs for maintenance, repair, and inspection needs.
                                                                                 2. In your testimony, you described the importance of rapid action to
                                                                              stop climate tipping points or feedback loops. Could you please elaborate
                                                                              on the role of methane mitigation in avoiding climate tipping points or
                                                                              feedback loops?
                                                                                 Methane is a highly potent climate pollutant. Over the twenty years after it is
                                                                              emitted into the atmosphere, methane warms Earth’s climate over eighty times
                                                                              more than an equivalent amount of carbon dioxide.3 Fortunately, methane remains
                                                                              in the atmosphere for just a few decades, a relatively short period of time in the
                                                                              atmosphere compared to carbon dioxide. Combined, this means that aggressively
                                                                              cutting methane pollution can lead to significant, meaningful decreases in the
                                                                              warming we will experience over the next 15 to 30 years.
                                                                                 As a result, slowing down warming by cutting methane pollution is an essential
                                                                              tool to avoid crossing climate tipping points and feedback loops. Tipping points are
                                                                              situations when climate change causes a shift in the Earth’s system that will not
                                                                              be reversible. The loss of ice sheets and the collapse of rainforest ecosystems and
                                                                              the protective weather patterns that the rainforests create are examples of tipping
                                                                              point changes that will increasingly threaten humanity over the next decades. Feed-
                                                                              back loops happen when a heating climate makes heating accelerate—for example,
                                                                              when a warming climate increases wildfires and those wildfires produce more cli-
                                                                              mate warming pollution, or when the warming climate increases methane emissions
                                                                              from wetlands and thawing permafrost.
                                                                                 Both tipping points and feedback loops get worse as the temperature rises. Since
                                                                              methane reductions are perhaps the most effective way to reduce climate heating
                                                                              over the coming decades, they are also a very good way to avoid crossing tipping
                                                                              points or initiating feedback loops.
                                                                                 3. Which specific measures do you think that the Environmental Protec-
                                                                              tion Agency should include to strengthen the proposed oil and gas methane
                                                                              regulations?
                                                                                 The Environmental Protection Agency’s November 15, 2021 proposal required
                                                                              owners and operators of facilities with a ‘‘potential to emit’’ (‘‘PTE’’) of less than 3
                                                                              tons per year to just perform a single, one-time instrumental inspection for fugitive
                                                                              emissions (or leaks), with no requirements for future instrumental inspections. This
                                                                              could allow for any leak that occurs after the required inspection to emit in per-
                                                                              petuity without any requirement to inspect or repair it. The EPA should strengthen
                                                                              the leak detection and repair provisions in the proposed regulations and require all
                                                                              facilities to perform regular inspections at all facilities, including smaller well sites.
                                                                                 Additionally, the November 2021 proposal from the Environmental Protection
                                                                              Agency banned the venting of associated gas—the natural gas that is released with
                                                                              oil production—and prohibited flaring, if a sales line is available. Leading states like
                                                                              New Mexico have shown that lack of pipeline capacity or availability is not a valid
                                                                              excuse for oil producers to flare gas: operators there are prohibited from venting or
                                                                              flaring gas if they lack sufficient capacity to capture it. Operators must plan devel-
                                                                              opment to ensure that proper gas gathering infrastructure is in place or use alter-
                                                                              natives such as utilizing the gas onsite or trucking it offsite. EPA should strengthen
                                                                              its proposal by prohibiting routine flaring of associated gas, regardless of the pipe-
                                                                              line availability.
                                                                                 4. Could you please elaborate on how the Environmental Protection
                                                                              Agency’s existing methane regulations have benefitted public health and
                                                                              the climate?
                                                                                 Environmental Protection Agency regulations on methane and volatile organic
                                                                              compound (VOC) emissions from the oil and gas industry have provided important

                                                                                2 Standards of Performance for New, Reconstructed, and Modified Sources and Emissions
                                                                              Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review, 86 Fed. Reg.
                                                                              63,110 (Nov. 15, 2021).
                                                                                3 Intergovernmental Panel on Climate Change (‘‘IPCC’’), AR6 Working Group I (‘‘WGI’’), Full
                                                                              Report Table 7.15 (2021),




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                                                                              benefits to both the climate and public health. In the short-term, methane is more
                                                                              than 80 times more potent than carbon dioxide as a climate pollutant. Methane ac-
                                                                              counts for nearly 0.5 degree C of the 1 degree C warming we’ve experienced to
                                                                              date,4 and levels in the atmosphere are surging.5 Quickly and significantly reducing
                                                                              methane pollution is one of the most important opportunities we have to quickly
                                                                              slow the rate of, and damage from, climate change.
                                                                                 In addition to the harms we experience from a warming climate, pollutants from
                                                                              oil and gas harm our health. Methane is a precursor for ground-level ozone smog,
                                                                              raising concentrations of ozone around the globe—hurting people and crops, and
                                                                              making it tougher for communities to meet clean air standards. Moreover, other pol-
                                                                              lutants which harm public health are released alongside methane. Nationally, more
                                                                              than 17 million people, including nearly 3.2 million children, live within a half mile
                                                                              health threat radius of active oil and gas production.6
                                                                                 Toxic air pollutants that are often co-released alongside methane from oil and gas
                                                                              facilities have been linked to increased risk of cancer and respiratory disorders. For
                                                                              example, benzene, one of the constituents of raw natural gas, has been linked to
                                                                              cancer, anemia, brain damage, birth defects, and is associated with respiratory tract
                                                                              irritation. In total, 236 counties in 21 states face cancer risk that exceeds the EPA’s
                                                                              one-in-a-million threshold due to toxic pollution from oil or gas sources, placing ap-
                                                                              proximately 14 million people at risk. Some of the areas with the greatest health
                                                                              risk are in Texas, Louisiana, Oklahoma, North Dakota, Pennsylvania, and Colo-
                                                                              rado.7
                                                                                 Even in areas far from oil and gas production, air pollution from oil and gas facili-
                                                                              ties has a significant impact on public health. Volatile organic compounds (VOCs),
                                                                              methane, and nitrogen oxides all react together in the presence of sunlight to form
                                                                              ozone smog. When inhaled, ozone smog can impair lung function, trigger asthma at-
                                                                              tacks, aggravate diseases like bronchitis and emphysema, and even cause premature
                                                                              death. Children, the elderly, and people with existing respiratory conditions are the
                                                                              most at risk from ozone pollution. Ozone smog that results from oil and gas industry
                                                                              pollution has a significant and harmful impact on the lives of Americans. In total,
                                                                              ozone smog attributable to oil and gas contributes to more than 750,000 summer-
                                                                              time asthma attacks in children every year, causes children to miss 500,000 days
                                                                              of school each year, and forces adults to take approximately 1.5 million personal
                                                                              days to rest or reduce activity due to high smog levels.8
                                                                                 By reducing emissions of harmful methane, toxic air pollutants, and volatile or-
                                                                              ganic compounds from the new and modified sites that are covered by EPA’s exist-
                                                                              ing standards, EPA has reduced these harmful impacts.
                                                                                5. Methane leaks are likely underestimated by as much as 50 percent and
                                                                              satellite data shows that certain U.S. oil and gas basins are ultra-emitters
                                                                              of methane, especially the Permian Basin. The oil and gas industry fails to
                                                                              quantify and address super-emitting methane leaks. How could the United
                                                                              States cost-effectively do much better in developing and deploying tech-
                                                                              nologies and strategies to reduce harmful methane pollution?
                                                                                 While many innovative and exciting technologies have been developed to detect
                                                                              methane emissions, most operators are not utilizing these technologies. Standards
                                                                              are needed so that all operators are required to regularly inspect each one of their
                                                                              sites for leaks and problems that lead to harmful emissions. These standards should
                                                                              allow operators to use alternative technologies and methodologies to find leaks, pro-
                                                                              vided that the alternative technology and methodology is proven to reduce emissions
                                                                              as much as traditional inspections. These standards will incentivize deployment of
                                                                              currently existing technologies, and development of new technologies, that can effec-
                                                                              tively and quickly find all leaks and unintended emissions.

                                                                                 4 IPCC, WGI, Summary for Policymakers 7 (2021),
                                                                              https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_SPM.pdf.
                                                                                 5 United Nations Environment Programme and Climate and Clean Air Coalition, Global Meth-
                                                                              ane Assessment: Benefits and Costs of Mitigating Methane Emissions (2021),
                                                                              https://www.unep.org/resources/report/global-methane-assessment-benefits-and-costs-mitigating-
                                                                              methane-emissions.
                                                                                 6 Oil & Gas Threat Map, https://oilandgasthreatmap.com (last accessed June 21, 2022).
                                                                                 7 Heny Patel and Lesley Feldman, Fossil Fumes: A Public Health Analysis of Toxic Air Pollu-
                                                                              tion from the Oil and Gas Industry, CATF (Sept. 2022), https://www.catf.us/resource/fossil-
                                                                              fumes-public-health-analysis/ (report update forthcoming).
                                                                                 8 CATF, Gasping for Breath (Aug. 2016),




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                                                                                 6. Could you please describe the environmental justice benefits of cutting
                                                                              methane pollution from U.S. oil and natural gas infrastructure?
                                                                                 Preventing air pollution across the natural gas supply chain has significant bene-
                                                                              fits for those communities that bear the brunt of the gas industry’s localized im-
                                                                              pacts. Policy action is needed to immediately rein in these emissions across the gas
                                                                              supply chain, from the well head to the point of use or the export facility. The meth-
                                                                              ane and VOC rules currently being promulgated by EPA will provide important
                                                                              health benefits to communities located near gas development as well as commu-
                                                                              nities in smog-laden areas far from gas development.
                                                                                 Furthermore, oil and gas companies routinely site highly polluting facilities near
                                                                              or in communities of color. This creates an unequal distribution of health impacts,
                                                                              with African American communities facing particularly serious health risks as a re-
                                                                              sult of disproportionate exposure to air pollution. More than 51⁄2 million people of
                                                                              color live within a half mile from existing natural gas facilities.9 More than half a
                                                                              million people live within 5 km (3.1 miles) of flaring sites, including a dispropor-
                                                                              tionate number of black, indigenous, and other people of color.10 Flaring from oil
                                                                              and gas facilities nationwide released approximately 16,000 tons of black carbon, re-
                                                                              sulting in dozens of premature deaths and other adverse health impacts.11 Taking
                                                                              measures to reduce methane emissions from leaking and flaring is an important
                                                                              step towards redressing these harms which disproportionately impact communities
                                                                              of color.
                                                                                 7. How would developing countries benefit from deployment of renewable
                                                                              energy? How would developing countries benefit from oil and methane gas
                                                                              producers eliminating methane pollution?
                                                                                 Both the deployment of renewable energy and mitigation of methane pollution
                                                                              from the oil and gas sector will provide benefits for developing countries and par-
                                                                              ticularly for frontline communities within those countries. First, the lack of access
                                                                              to modern electricity and energy stifles development, and the expansion of modern
                                                                              energy sources, including renewable energy, are critical factors for development.
                                                                              Second, many developing countries are at a higher risk of climate-induced harm
                                                                              compared to developed countries. The IPCC Sixth Assessment Report from Working
                                                                              Group II on Impacts, Adaptation, and Vulnerability found that hot spots of high
                                                                              human vulnerability to climate risk are found particularly in West-, Central-, and
                                                                              East Africa, South Asia, Central and South America, Small Island Developing
                                                                              States, and the Arctic.12 The IPCC report indicated that between the years of 2010
                                                                              and 2020, human mortality from floods, droughts, and storms was fifteen times
                                                                              higher in these high-vulnerability regions compared to regions with low vulner-
                                                                              ability.13 Reducing methane emissions can lead to significant, meaningful decreases
                                                                              in the rate of climate change over the next 15 to 30 years, which will reduce the
                                                                              climate-induced risks faced by developing countries which may not have access to
                                                                              the same adaptation capabilities as more developed countries.
                                                                                 Additionally, reducing methane emissions from the oil and gas sector often re-
                                                                              duces other air pollution that causes adverse health effects. Reducing these air pol-
                                                                              lutants provides important benefits to the overall public health of communities near
                                                                              oil and gas development in developing and developed countries alike.
                                                                                 Finally, the mitigation of methane emissions provides more natural gas supply
                                                                              overall. Particularly if mitigation occurs within the borders of a developing country,
                                                                              this provides a near-term cleaner energy supply that can improve the quality of life
                                                                              for people that live there. Importantly, methane mitigation provides these benefits
                                                                              to developing countries in a cost-effective way, allowing these countries to accelerate
                                                                              development while protecting their citizens. This is particularly important consid-
                                                                              ering the risk that the use of wood fuels poses to public health in many developing
                                                                              countries, where wood fuel combustion is a major driver of local air pollution and
                                                                              respiratory illness as well as deforestation and loss of carbon sinks.14 The transition
                                                                              to cleaner alternatives such as gas and away from wood fuels can provide a signifi-
                                                                              cant benefit to indoor air quality in many developing countries. Furthermore, spe-

                                                                                9 Oil & Gas Threat Map, https://oilandgasthreatmap.com (last accessed August 12, 2022).
                                                                                10 Lara Cushing et al., Up in smoke: characterizing the population exposed to flaring from un-
                                                                              conventional gas development in the contiguous US, 16 Env’t Rsch. Letters 3 (2021).
                                                                                11 Chen Chen et al., Black carbon emissions and associated impacts of gas flaring in the
                                                                              United States, 13 Atmosphere 3 (2022).
                                                                                12 IPCC, AR6 Working Group II, Summary for Policymakers B.2.4. (2022), https://
                                                                              www.ipcc.ch/report/ar6/wg2/downloads/report/IPCC_AR6_WGII_SummaryForPolicymakers.pdf.
                                                                                13 Id.
                                                                                14 World Health Organization, Household Air Pollution and Health (July 26, 2022), https://




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                                                                              www.who.int/news-room/fact-sheets/detail/household-air-pollution-and-health.




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                                                                              cifically in Africa, the bulk of climate-warming emissions result from land-use
                                                                              change and agriculture, rather than from the energy sector. The use of wood fuel
                                                                              is a key driver of these land-use change emissions. Switching to cleaner alternatives
                                                                              for cooking and heating, such as natural gas that would otherwise have been wasted
                                                                              through methane leaks or flaring, presents an opportunity to limit these emissions.
                                                                              Eliminating methane pollution is key to enabling clean energy access in developing
                                                                              countries.


                                                                                                                                  Æ




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