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U.S. Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2021-0295
Article Title: Reducing Emissions of Methane and Other Air Pollutants from the Oil and Natural Gas Sector: Recommendations to the Environmental Protection Agency
Specialization Codes: 8.1 - Climate Change and Greenhouse Gases,
Authors: Robert L. Kleinberg
Publication Date: 6 July 2021
Description: In 2016, the Obama administration pledged to reduce methane emissions from the oil and natural gas sector by 40-45% by 2025, representing a compound annual decline rate of roughly 6%. However, methane emissions have barely changed since the promulgation of natural gas emission control rules in 2012 and 2016, consistent with a compound annual decline rate of about 0.3%. This disappointing outcome is mainly the result of the narrow scope of regulation that has not confronted the realities of oilfield operations. Devised at a time when the technology for the measurement of natural gas emissions was relatively immature, performance-based regulations could not be implemented effectively. Therefore, regulations are either prescriptive or, if performance-based, lack means for verifying performance. Amendments promulgated in 2020 did little to change this situation. Thus merely reverting to the status quo ante will do little to improve the industry's environmental performance. Instead of proposing patchwork amendments to the current rules, which are outdated and ineffective, EPA should entirely rethink natural gas emission control. This document analyzes why the rules were constructed as they were, highlights the inadequacies of present regulations, explores the new technologies that have improved the prospects for effective regulation, and proposes a more efficient and effective regulatory regime.
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