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.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“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.Full text
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
dkrause on LAP5T8D0R2PROD with $$_JOB
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00001 Fmt 5011 Sfmt 5011 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
SELECT COMMITTEE ON THE CLIMATE CRISIS
ONE HUNDRED SEVENTEENTH CONGRESS
KATHY CASTOR, Florida, Chair
SUZANNE BONAMICI, Oregon GARRET GRAVES, Louisiana,
JULIA BROWNLEY, California Ranking Member
JARED HUFFMAN, California GARY PALMER, Alabama
A. DONALD MCEACHIN, Virginia BUDDY CARTER, Georgia
MIKE LEVIN, California CAROL MILLER, West Virginia
SEAN CASTEN, Illinois KELLY ARMSTRONG, North Dakota
JOE NEGUSE, Colorado DAN CRENSHAW, Texas
VERONICA ESCOBAR, Texas ANTHONY GONZALEZ, Ohio
ANA UNRUH COHEN, Majority Staff Director
SARAH JORGENSON, Minority Staff Director
climatecrisis.house.gov
dkrause on LAP5T8D0R2PROD with $$_JOB
(II)
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00002 Fmt 5904 Sfmt 5904 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
(III)
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00003 Fmt 5904 Sfmt 5904 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
dkrause on LAP5T8D0R2PROD with $$_JOB
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00004 Fmt 5904 Sfmt 5904 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
(1)
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00005 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
and replace leaking natural gas distribution pipelines.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00006 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
methane fee to address this wasteful pollution. And the House-passed Bipartisan In-
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00007 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
stopped it—stopped it and replaced it with U.S. gas, do you know
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00008 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
5
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
dkrause on LAP5T8D0R2PROD with $$_JOB
near her children’s schools.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00009 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
6
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
dkrause on LAP5T8D0R2PROD with $$_JOB
are gas wells and a spiderweb network of gathering pipelines. The
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00010 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
7
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
[The statement of Ms. Tomcik follows:]
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00011 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
rsuess on LAP9Q1F4G3PROD with CLIMATECRISIS
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-
VerDate Sep 11 2014 00:57 Nov 02, 2022 Jkt 048849 PO 00000 Frm 00012 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
same amount of gas in 2050.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00013 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
10
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
dkrause on LAP5T8D0R2PROD with $$_JOB
than that of the United States. If left unchallenged, the Russian re-
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00014 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
[Scheutz, 2019].
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00015 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
12
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
dkrause on LAP5T8D0R2PROD with $$_JOB
of emission limitation, EPA has to date approved only two methods for natural gas
48849A.001
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00016 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
waste sectors) were identified and quantified [Duren, 2019].
48849A.002
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00017 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
14
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/
dkrause on LAP5T8D0R2PROD with $$_JOB
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00018 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
Russian reports.
48849A.003
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00019 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
this section with respect to such pollutant. [42 USC 7411(h)(3)]
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00020 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
Alvarez, R.A., et al., 2018. Assessment of methane emissions from the U.S. oil and
gas supply chain, Science 10.1126/science.aar7204
https://science.sciencemag.org/content/361/6398/186
Berman, E.S.F. & Deiker, S., 2020. Source-attributable, quantitative results from
a basin-wide survey of New Mexico Permian methane emissions, MIT A+B Applied
Energy Symposium #280. 13–14 August 2020
https://www.youtube.com/watch?v=ySDjZdHMYBA
http://kairosaerospace.com/wp-content/uploads/2021/02/Source-Attributable-Quantitative-
Results-from-a-Basin-Wide-Airborne-Survey-of-Methane-Emissions.mp4
Bridger, 2021. Why is it Important that ExxonMobil Submitted Gas Mapping
LiDARTM for EPA Approval?, 8 April 2021
https://www.bridgerphotonics.com/blog/why-it-important-exxonmobil-submitted-gas-
mapping-lidartm-epa-approval
Chen, Y., et al., 2022. Quantifying Regional Methane Emissions in the New Mex-
ico Permian Basin with a Comprehensive Aerial Survey. Environmental Science and
Technology, 56, 4317–4323. https://doi.org/10.1021/acs.est.1c06458
CleanConnect.AI, 2022.
https://www.regulations.gov/comment/EPA-HQ-OAR-2021-0317-0762
Cusworth, D.H., et al., 2021. Intermittency of Large Methane Emitters in the Per-
mian Basin, Environmental Science & Technology Letters, 8, 567–573.
https://pubs.acs.org/doi/abs/10.1021/acs.estlett.1c00173
Duren, R.M., et al., 2019. California’s methane super-emitters, Nature, 575, 180–185.
https://www.nature.com/articles/s41586-019-1720-3
EDF, 2021a. PermianMAP, Flaring, Aerial Survey Results, Environmental De-
fense Fund, Accessed 31 January 2021
https://www.permianmap.org/flaring-emissions/
EDF, 2021b. PermianMAP, Operator Emissions, Environmental Defense Fund,
Accessed 3 June 2021. https://data.permianmap.org/pages/operators
EDF, 2021c. Find, Measure, Fix: Jobs in the U.S. Methane Emissions Mitigation
Industry. Datu Research.
dkrause on LAP5T8D0R2PROD with $$_JOB
https://www.edf.org/sites/default/files/content/FindMeasureFixReport2021.pdf
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00021 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
18
EIA, 2021. Drilling and completion improvements support Permian Basin hydro-
carbon production. Energy Information Administration, Today in Energy, 19 October
2021. https://www.eia.gov/todayinenergy/detail.php?id=50016
EPA, 2021. Standards of Performance for New, Reconstructed, and Modified
Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector
Climate Review, Environmental Protection Agency, 86 Federal Register 63110–
63263, 15 November 2021
https://www.federalregister.gov/documents/2021/11/15/2021-24202/standards-of-
performance-for-new-reconstructed-and-modified-sources-and-emissions-guidelines-for
EPA, 2022a. Inventory of U.S. Greenhouse Gas Emissions and Sinks. U.S. Envi-
ronmental Protection Agency, 2022.
https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks
EPA, 2022b. Natural Gas and Petroleum Systems in the GHG Inventory: Addi-
tional Information on the 1990–2020 GHG Inventory (published April 2022).
https://www.epa.gov/ghgemissions/natural-gas-and-petroleum-systems-ghg-inventory-
additional-information-1990-2020-ghg
European Commission, 2021. International Methane Emissions Observatory
launched to boost action on powerful climate-warming gas. Press Release, 31 Octo-
ber 2021. https://ec.europa.eu/commission/presscorner/detail/en/IP_21_5636
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
IEA, 2021. World Energy Outlook 2021. International Energy Agency.
https://www.iea.org/reports/world-energy-outlook-2021
Johnson, F., et al., 2021. Airborne methane surveys pay for themselves: An eco-
nomic case study of increased revenue from emissions control. EarthArXiv, 15 July
2021. https://eartharxiv.org/repository/view/2532/
Kleinberg, R.L. 2021a. EPA Methane Emission Controls, Obama vs Trump vs
Biden: What Needs to Be Fixed and What Should be Left Alone, Social Science Re-
search Network, 22 March 2021.
https://ssrn.com/abstract=3810337 or http://dx.doi.org/10.2139/ssrn.3810337
Kleinberg, R.L., 2021b. 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., 2022. Methane Emissions from the Fossil Fuel Industries of the
Russian Federation. EarthArXiv, 19 May 2022.
https://eartharxiv.org/repository/view/3342/
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
Lyon, D.R., et al., 2021. Concurrent variation in oil and gas methane emissions
and oil price during the COVID–19 pandemic. Atmospheric Chemistry and Physics,
21, 6605–6626. https://doi.org/10.5194/acp-21-6605-2021
OGMP, 2020. Mineral Methane Initiative OGMP 2.0 Framework. Oil and Gas
Methane Partnership, 19 November 2020.
https://www.ogmpartnership.com/ogmp-20-reporting-framework
OGMP, 2022a. Oil & Gas Methane Partnership 2.0. Accessed 20 June 2022.
https://www.ogmpartnership.com/
OGMP, 2022b. Oil & Gas Methane Partnership 2.0. Guidance document: Rec-
onciliation and Uncertainty (U&R) in methane emissions estimates for OGMP2.0.
Accessed 22 June 2022.
https://www.ogmpartnership.com/uncertainty-and-reconciliation-guidance
https://www.ogmpartnership.com/sites/default/files/files/OGMP%202.0%20U%26R
%20Guidance%20document%20-%20SG%20approved.pdf
Rashid, K., et al., 2020. Optimized inspection of upstream oil and gas methane
emissions using airborne LiDAR surveillance, Applied Energy 275, 115327.
dkrause on LAP5T8D0R2PROD with $$_JOB
https://www.sciencedirect.com/science/article/abs/pii/S0306261920308394
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00022 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
19
Rutherford, J.S., et al., 2021. Closing the gap: Explaining persistent underesti-
mation by U.S. oil and natural gas production-segment methane inventories, Nature
Communications, 12: 4715. https://www.nature.com/articles/s41467-021-25017-4
Scheutz, C. and Fredenslund, A.M., 2019. Total methane emission rates and
losses from 23 biogas plants. Waste Management, 97, 38–46.
https://doi.org/10.1016/j.wasman.2019.07.029
Shindell, D., et al., 2012. Simultaneously Mitigating Near-Term Climate Change
and Improving Human Health and Food Security. Science 335, 183–189
https://www.science.org/doi/abs/10.1126/science.1210026
Sridharan, S., et al., 2020. Long Term, Periodic Aerial Surveys Cost Effectively
Mitigate Methane Emissions, Society of Petroleum Engineers Paper SPE 201312.
https://onepetro.org/SPEATCE/proceedings-
abstract/20ATCE/3-20ATCE/D031S034R004/449845
UNFCCC, 2022a. United States of America. 2022 National Inventory Report (NIR)
https://unfccc.int/documents/461948
UNFCCC, 2022b. Fourth Biennial Reports—Annex I. Accessed 19 June 2022
https://unfccc.int/BRs
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
dkrause on LAP5T8D0R2PROD with $$_JOB
being met.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00023 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
20
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
[The statement of Dr. Alden follows:]
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00024 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
21
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
nology Letters, 8(7), pp. 567–573.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00025 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
plex emissions scenarios. https://arxiv.org/abs/2009.10853
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00026 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
rsuess on LAP9Q1F4G3PROD with CLIMATECRISIS
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
48849A.004
VerDate Sep 11 2014 03:33 Nov 01, 2022 Jkt 048849 PO 00000 Frm 00027 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
24
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
dkrause on LAP5T8D0R2PROD with $$_JOB
and Gas Wells.’’
48849A.005
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00028 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
in Realistic Controlled Conditions.’’
48849A.007
48849A.006
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00029 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
26
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
dkrause on LAP5T8D0R2PROD with $$_JOB
rampaging wildfires, the impacts of our warming climate are being
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00030 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
27
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
dkrause on LAP5T8D0R2PROD with $$_JOB
methane here at home.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00031 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
28
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
global-methane-pledge-energy-pathway/.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00032 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
29
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),
dkrause on LAP5T8D0R2PROD with $$_JOB
https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator#results.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00033 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
30
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://
dkrause on LAP5T8D0R2PROD with $$_JOB
www.eia.gov/dnav/ng/ng_cons_num_a_EPG0_VN4_Count_a.htm (last accessed June 21, 2022)].
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00034 Fmt 6633 Sfmt 5601 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
31
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
24 N.M. Code R. § 20.2.50.123 (approved 27 May 2022, publication pending).
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00035 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
32
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).
dkrause on LAP5T8D0R2PROD with $$_JOB
32 Build Back Better Act, H.R. 5376, 117th Congress (2022).
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00036 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
33
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’’).
dkrause on LAP5T8D0R2PROD with $$_JOB
37 Oil & Gas Threat Map, https://oilandgasthreatmap.com (last accessed June 21, 2022).
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00037 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
48 CATF, Fossil Fumes (forthcoming report update).
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00038 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
35
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
49 Based on CATF conversations with OGI camera manufacturers.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00039 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
36
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
Ms. BROWNLEY. Thank you. Thank you for that.
48849A.008
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00040 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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.
rsuess on LAP9Q1F4G3PROD with CLIMATECRISIS
Ms. CASTOR. Next, Representative Gonzalez, you are recognized
for 5 minutes.
VerDate Sep 11 2014 00:57 Nov 02, 2022 Jkt 048849 PO 00000 Frm 00041 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
38
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
dkrause on LAP5T8D0R2PROD with $$_JOB
that utmost, you know, highest quality.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00042 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
39
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
gering irreversible climate change.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00043 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
40
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
ronmental indicators.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00044 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
41
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
dkrause on LAP5T8D0R2PROD with $$_JOB
countries, because they are using fossil fuels, and they are going
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00045 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
42
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
And thank you to the witnesses.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00046 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
43
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
dkrause on LAP5T8D0R2PROD with $$_JOB
online, they are going to need monitoring too. Because if you are
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00047 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
44
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
dkrause on LAP5T8D0R2PROD with $$_JOB
market.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00048 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
45
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
dkrause on LAP5T8D0R2PROD with $$_JOB
a more advanced burner control unit doesn’t.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00049 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
46
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
tioned, many of the largest sites turned out to be either agricul-
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00050 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
47
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
Mr. HUFFMAN. Thank you.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00051 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
48
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
rsuess on LAP9Q1F4G3PROD with CLIMATECRISIS
they can use to heat their homes, cook their food, warm their water
and, hopefully, bring some businesses into their city so that they
VerDate Sep 11 2014 03:33 Nov 01, 2022 Jkt 048849 PO 00000 Frm 00052 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
49
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
I recognize myself for 5 minutes for questions.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00053 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
50
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
dkrause on LAP5T8D0R2PROD with $$_JOB
the second largest natural gas producer in the nation, and the oil
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00054 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
51
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
dkrause on LAP5T8D0R2PROD with $$_JOB
emissions across the supply chain for oil and gas. So I do think it
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00055 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
52
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
ated inflation, and this administration can’t stop coming up with
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00056 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
53
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
dkrause on LAP5T8D0R2PROD with $$_JOB
general——
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00057 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
54
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
dustry. And once we do it right, other countries will. And then the
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00058 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
55
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,
dkrause on LAP5T8D0R2PROD with $$_JOB
one June 23 from a number of energy companies and another one
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00059 Fmt 6633 Sfmt 6602 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
itor and mitigate methane emissions for compliance purposes;
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00060 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
member companies continuously improve their operational performance.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00061 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
that every American can be proud of and that is indispensable for giving our chil-
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00062 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
17, 2018, 52(8):4514–4525, https://pubs.acs.org/doi/10.1021/acs.est.7b05983
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00063 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
60
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:
dkrause on LAP5T8D0R2PROD with $$_JOB
April 19, 2022.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00064 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
61
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,
dkrause on LAP5T8D0R2PROD with $$_JOB
https://www.taxpayer.net/wp-content/uploads/2021/10/OG-Reform-and-Gas-Prices-Primer.pdf.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00065 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
62
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-
kcroghan on LAP7511N33PROD with CLIMATE CRISIS
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.
VerDate Sep 11 2014 01:42 Nov 03, 2022 Jkt 048849 PO 00000 Frm 00066 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
63
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-
rsuess on LAP9Q1F4G3PROD with CLIMATECRISIS
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-
VerDate Sep 11 2014 03:33 Nov 01, 2022 Jkt 048849 PO 00000 Frm 00067 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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.
kcroghan on LAP7511N33PROD with CLIMATE CRISIS
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.
VerDate Sep 11 2014 01:42 Nov 03, 2022 Jkt 048849 PO 00000 Frm 00068 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
65
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
rsuess on LAP9Q1F4G3PROD with CLIMATECRISIS
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.
48849A.009
VerDate Sep 11 2014 00:57 Nov 02, 2022 Jkt 048849 PO 00000 Frm 00069 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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:
dkrause on LAP5T8D0R2PROD with $$_JOB
https://www.congress.gov/bill/117th-congress/house-bill/5376/text.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00070 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
67
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
dkrause on LAP5T8D0R2PROD with $$_JOB
methane directly into the atmosphere. EPA must follow the lead of states like Colo-
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00071 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
68
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
dkrause on LAP5T8D0R2PROD with $$_JOB
are oil and gas operations you can find methane and volatile organic compounds
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00072 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
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
dkrause on LAP5T8D0R2PROD with $$_JOB
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00073 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
70
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-
dkrause on LAP5T8D0R2PROD with $$_JOB
ane [IWG, 2021]. It is also far smaller than the LDAR-focused regulation 40 CFR
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00074 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
71
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].
dkrause on LAP5T8D0R2PROD with $$_JOB
Technology diffusion will accelerate if markets for the new methods are encouraged
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00075 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
72
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_
dkrause on LAP5T8D0R2PROD with $$_JOB
SocialCostofCarbonMethaneNitrousOxide.pdf
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00076 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
73
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.
dkrause on LAP5T8D0R2PROD with $$_JOB
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00077 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
74
dkrause on LAP5T8D0R2PROD with $$_JOB
48849A.010
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00078 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
75
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
dkrause on LAP5T8D0R2PROD with $$_JOB
(June 2021), https://www.catf.us/resource/oil-gas-methane-mapping-the-path-to-a-65-reduction/.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00079 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
76
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),
dkrause on LAP5T8D0R2PROD with $$_JOB
https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00080 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
77
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),
dkrause on LAP5T8D0R2PROD with $$_JOB
http://www.catf.us/wp-content/uploads/2018/10/CATF_Pub_GaspingForBreath.pdf.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00081 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
78
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://
dkrause on LAP5T8D0R2PROD with $$_JOB
www.who.int/news-room/fact-sheets/detail/household-air-pollution-and-health.
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00082 Fmt 6633 Sfmt 6621 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
79
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
dkrause on LAP5T8D0R2PROD with $$_JOB
VerDate Sep 11 2014 12:29 Oct 27, 2022 Jkt 048849 PO 00000 Frm 00083 Fmt 6633 Sfmt 6611 E:\CLIMATE_CRISIS\48849\48849A.XXX 48849A
File and source
- File
- CHRG-117hhrg48849.pdf
- Size
- 9,695,468 bytes
- SHA-256
- 702ad6346dbb0cf3f7fdb146e8e8ee92129250ae71557974e35b41ca9be4dd42
- Our copy
- CHRG-117hhrg48849.pdf
- Original
- www.govinfo.gov