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ICYMI: API Previews Industry’s Comments on EPA’s Proposed Amendments to NSPS OOOOa

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Today, November 13, 2018, API Senior Director of Regulatory and Scientific Affairs Howard Feldman held a press call to preview comments that will be delivered for the record on Wednesday, November 14, in Denver during the EPA’s public hearing on the proposed rule, titled  “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration.” 

Text as prepared for delivery:

Good morning, thank you for joining our call.

Many of our members are directly impacted by the proposed regulations being discussed at tomorrow’s hearing in Denver on EPA’s proposed revisions to the NSPS OOOOa rule. Technical corrections to federal regulations are essential to ensure that the rules reflect current technologies and accurately reflect operations to provide clarity for compliance.  In this case, the rule will continue to effectively reduce volatile organic compound and methane emissions from all emission sources addressed in the previous administration’s rule. Methane is the primary constituent of natural gas, and the natural gas and oil industry is incentivized to minimize its release, as a top priority from both an environmental and business standpoint.

Recent data, including the EPA’s air quality reports confirm that U.S. air quality has improved dramatically, and that industry’s commitments and efforts are working. The U.S. oil and natural gas industry has invested an estimated $339 billion from 1990 – 2016 toward improving the environmental performance of its products, facilities and operations — $1,045 for every man, woman and child in the United States.

To these ends, the natural gas and oil industry has invested in the reduction of methane emissions from U.S. natural gas production and our investments are the driving force behind this success. The Environmental Partnership a program that has brought more than 50 of the nation’s oil and gas producers together – both large and small and operating across the entire nation – is a strong example of our industry’s many forward-looking commitments to take concrete actions to reduce emissions.  

The results of these combined efforts on natural gas and oil operations are remarkable:

    • Methane emissions from hydraulically-fractured natural gas well completions have fallen more than 85 percent since 1990
    • the increased use of natural gas to fuel the power sector has played the most significant role in achieving 30-year lows in carbon dioxide emissions from power generation that we see today 
    • America leads the world in natural gas production – natural gas output has doubled  as overall methane emissions from U.S. natural gas production have fallen significantly, 16 percent, since 1990

During our oral comments in Denver tomorrow, we will communicate three important messages to EPA:

    • The protection and safety of our workers and the communities in which we operate is the top priority for our member companies. We are committed to identifying sound regulatory policies that lead to cost-effective solutions that provide environmental benefits
    • The emission trends for the oil and gas production sector are positive. Emissions have continued to decline over a period that oil and natural gas production has increased significantly
    • The proposed rule is a missed opportunity to promote the development and use of new, innovative, detection technologies, reduce the burden of overlapping regulatory requirements that have little environmental benefit, and make sensible revisions based on real world field data 

Unfortunately, the proposed rule includes several missed opportunities. There are significant capital investments and scientific studies underway to advance the development and use of new emission detection technologies. The agency’s insistence on requiring site-specific approval for each new technology will only stifle this positive development. We hope the EPA significantly streamlines this process in the final rule.

The rule also fails to reduce the burden of overlapping regulatory requirements that have no environmental benefit. While the agency agrees that many state leak detection and repair programs are equally effective, significant and duplicative record keeping and reporting remains. Duplicative and costly regulations with little or no environmental benefit could increase the cost of energy for Americans, undermine our competitiveness, and hinder our ability to provide the energy our nation will continue to demand for many years to come.

We also encourage the EPA to recognize the value of the field data measurements that have been shared with the agency. API collected data during normal operations that demonstrate much lower incidence of leaks when compared to the EPA estimates in the rule. Real world leak survey findings from over 4000 well sites and representing more than 2 million components should be valuable to the agency and considered in its final rulemaking.

API and its members recognize the importance of developing oil and gas resources responsibly. The combined technologies of hydraulic fracturing and horizontal drilling have elevated the United States to global prominence as an energy superpower. Because of the advanced application of these technologies, the United States is now the world’s largest producer of oil and natural gas while, at the same time, emissions from the industry are declining.

This positive trend will continue as many companies engage in multiple voluntary programs such as The Environmental Partnership and other individual efforts to further reduce emissions from oil and gas production.

The U.S. economy is energized by driving domestic investment in energy projects, creating jobs, and enhancing U.S. energy and national security interests.

I will now take your questions. Thank you.


API is the only national trade association representing all facets of the natural gas and oil industry, which supports 10.3 million U.S. jobs and nearly 8 percent of the U.S. economy. API’s more than 600 members include large integrated companies, as well as exploration and production, refining, marketing, pipeline, and marine businesses, and service and supply firms. They provide most of the nation’s energy and are backed by a growing grassroots movement of more than 47 million Americans.