Esta entrada también está disponible en: Spanish
December 1, 2021. The Center for Human Rights and Environment offered testimony to the EPA on Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review.
You can watch the presentation at the following link:
https://www.youtube.com/watch?v=Hcmwuj8jsaQ (presentation starts at: hour/minute 1:33:39)
The transcript of the oral presentation is below:
Written detailed comments will follow
- My name is Jorge Daniel Taillant, I am the Executive Director of the Center for Human Rights and Environment, working to accelerate fast climate mitigation actions and reduce short lived climate pollutants, including methane.
- Over the past few months, I have worked closely with partners and alongside the current Admin, to craft, promote and now to implement the Global Methane Pledge signed during COP26, to reduce methane emissions 30% by 2030.
- I have also had the pleasure, or should I say displeasure, of taking a FLIR camera around the world visiting over a hundred oil and gas sites to actually “see” methane emissions.
- I emphasize the term “actually see” methane emissions because what you, the EPA staff working on methane “think” you’re addressing in this very rule, is actually an illusion, it’s pure theory.
- As you likely know, methane emissions are calculated using “factor emissions”, a fancy way of saying “we’re guessing”. We’re guessing that what is being emitted by oil and gas companies is in line with what a laboratory test showed that a certain piece of equipment emits. We multiply that guess by the number of pieces of equipment and that’s our total guess on emissions.
- Noone has actually ever done a complete inventory of actual methane emissions from oil and gas. That’s coming soon with emerging satellite technology, but we’re not there yet.
- When we actually do carry out real tests of actual emissions utilizing technology that allows us to see these emissions and not just guess at them, we usually discover that what we “thought” were the emissions, are in order of magnitude, 2 or 3 times higher than we had “guessed”.
- If you, the administrative staff of EPA working on methane have not held a FLIR camera in your hands and actually visited an oil and gas site and pointed it at an emitting source like a storage tank, or a compressor, or an abandoned well, and until you’ve actually looked through that view finder of a FLIR camera, you really don’t know what you’re up against.
- I usually gauge that revelation moment when you do look through that viewfinder with what I call a “wowometer”. At that moment, your jaw drops, your heart skips a beat, and usually, for most people, all they can say is “wow”
- I’ve taken dozens and dozens of people to look at methane emissions through a FLIR camera, including people living near oil and gas sites. After years of seeing clear blue skies and hearing from the oil companies that the air around them is clean, they have an “aha” moment, when they look through that viewfinder, and many things start to make sense, like illnesses over the course of their lives, crop loss, birth defects and cancer
- all of these real impacts suddenly become logical conclusions to their proximity to oil and gas sites.
- This is the methane moment
- And you, the EPA staff working on methane, have the responsibility in your hands to make good of it.
- Methane is 84 times more potent than CO2 in its global warming potential.
- The idea that methane is somehow clean, or a bridge fuel to a zero carbon economy, is pure fantasy
- Reducing methane quickly is the most viable low hanging fruit to slow global warming in the next decade and keep to the 1.5C pathway that scientists are warning us about.
- Not only that, but reducing methane emissions in the oil and gas sector is low to no cost and it actually makes money for oil and gas companies.
- It’s a no-brainer!
- The strictest methane rules are in order and urgently needed.
- And that is on you! Anna, Suzie, and Amy
- I’ve had the pleasure of speaking with the authors of the Global Methane Assessment, which I know you have read because EPA held up its publication until you had thoroughly reviewed this landmark study.
- The good news about the oil sector’s irresponsible reporting on their “theoretical” emissions vs their “actual” emissions which are much worse, is that when we tighten the bolts on the equipment, when we capture vented gas, when we change out technologies to zero bleed, when we cap those orphaned wells, and when we refuse to tolerate the emission of a gas that is 84 times more potent for global warming than CO2 simply because oil and gas companies don’t want to make cost-effective investments, we will actually be reducing methane emissions by much more than we are theoretically calculating.
- When we actually change out this technology, we are likely to achieve 40-50% more reduction than we are guessing we will achieve.
- That’s good for climate, that’s good for the atmosphere, that’s good for fenceline communities that suffer disproportionately from the poor air quality that we know exists at and near neighborhoods that have the misfortune of being located near an oil well or a production or distribution facility
- So my message to you, EPA staff working on Methane, “do the right thing” and do the right thing at every step of the way during your review of methane emissions reduction opportunities in the oil and gas sector.
- Err on the side of caution, and make these rules as stringent as you can.
- We only have one shot at avoiding irreversible climate tipping points in the next few decades.
- Let’s make the most of it. Please do your part!
- Thank you.