This action is a significant development in a couple of ways. First, it would directly target methane pollution from the oil and gas industry, which has never been proposed before anywhere in the country. Second, it would go much further than the U.S. Environmental Protection Agency’s recently established standards (which we have argued should be significantly improved), in terms of reducing harmful volatile organic compounds (VOCs), hazardous air pollutants and methane, a powerful greenhouse gas. Those are big steps forward in reducing air pollution from oil and gas development in the state, although we think that the standards can and should be further strengthened.
I would be remiss, though, if I didn’t also point out that there are myriad other risks that fracking poses to public health and the environment that the state has yet to sufficiently safeguard Coloradans against. The air pollution reductions should be just the first in a larger effort to better protect the people of Colorado from fracking’s risks—that is something NRDC will continue to push for. And most importantly—as a nation—in order to stop climate change we must move away from all fossil fuels, as quickly as possible, by boosting energy efficiency and renewable energy sources like wind and solar.
All of that said, we commend Colorado for taking the lead here with these proposed air pollution standards, to help lower the environmental footprint of the fossil fuel development that is already underway. A formal rulemaking period will now commence, including public hearings, and the finalized rules are anticipated early next year. While the standards can and should be further strengthened before they are finalized, they are headed in the right direction. Emissions from oil and gas development have been identified as major contributors to elevated ground-level ozone and associated smog in Colorado (particularly in the area around Denver) – pollution that can cause serious respiratory ailments. This is a big problem in Colorado, where the U.S. EPA has already flagged nine counties for violating federal air pollution standards that were established to protect human health.
The standards that Colorado is proposing are based on common-sense measures to reduce harmful pollution. They will help directly reduce emissions of methane – a powerful heat-trapping gas that is at least 28 times more powerful than carbon dioxide – and also VOCs that cause ground-level ozone and smog, and cancer-causing hazardous air pollutants like benzene. In addition, these measures are extremely cost-effective and can actually make the natural gas industry more money—so, there really is no excuse to delay action.
By targeting all hydrocarbon pollution (including methane), here’s what Colorado’s proposed air standards require:
- All new wells and re-stimulated wells must have equipment that reduces all hydrocarbon pollution (including methane) by at least 95%. This includes both gas and oil wells.
- Leak detection and repair programs are required for well production facilities, compressor stations, and storage tanks. The proposal requires use of infrared cameras or other advanced methods of leak detection. Inspection frequency varies from monthly to annual depending on the type of equipment and potential emissions. Upon discovery of leaks above certain levels, repair is required within five days, and repairs need to be tested for efficacy after fifteen days.
- All valves (pneumatic devices) that control the flow of gas are required to have VOC emissions as low or lower than low-leakage devices. This applies to both new equipment, and, after a year-long phase-in, existing devices. When electricity is available, the valves must have no leakage.
- Dehydrators for natural gas, which remove moisture from the gas, meeting certain emission thresholds, must limit hydrocarbon leakage by at least 95%.
- All storage tanks meeting certain emission thresholds must control at least 95% of all hydrocarbon emissions. New tanks must comply immediately and existing tanks must comply within one year.
- During well clean-ups (liquids unloading) and well-maintenance practices that release hydrocarbons, venting gas into the air can only be used as a last resort.
All of these steps would go beyond the current national requirements. They would also make Colorado’s proposed air regulations taken together stronger than any other state regulations in the country.
But, they are not perfect. The proposed rules can, and should, be further improved in at least a few ways. The proposal should:
- Address emission sources downstream of natural gas processing plants, such as compressors at transmission stations, and other equipment in downstream operations.
- Reduce emissions from pipelines and equipment at the distribution end of the supply chain, where natural gas is piped to the customers. One way to accomplish this could be through a more comprehensive leak detection and repair program.
- Require the use of plunger lift systems or similar equipment wherever possible, as a means to reduce the need for well clean-ups and possible consequent venting.
- Have a stronger requirement for well emissions to ensure that more gas is captured and used, rather than flared. Improved waste prevention standards could also help achieve this.
- Address other sources of air pollution from the oil and gas industry, such as diesel and dust.
- Ensure that exceptions are limited and enforcement is rigorous. Additionally, periodic review of emissions reductions will help verify that the standards are performing as intended.
According to the Energy Information Administration, Colorado is the sixth largest natural gas producer in the United States and delivers more than six percent of national production. So, it is good news that such a large producing state has proposed the adoption of strong rules that target air pollution. They should build on this action and address the remaining gaps in protection, in order to make this a true model for reducing air pollution from oil and gas development that the nation can follow. This includes setting an example for other states, as well as for EPA to improve its current standards to better protect our air and the climate.
NRDC is at the forefront of the battle to keep people safe from the perils of fracking around the country. We will continue fighting to protect people of Colorado who have frack-pads in their yards, who worry about water contamination, who lost control of their property because a gas company owned the mineral rights. We will continue to help empower local communities to stand up to industry and say “no” if they don’t want fracking in their backyards, regardless of whether or not their state agrees – something three Colorado towns did earlier this month. And we will push for Colorado’s proposed air regulations to be but the first step towards a broader push in the state to safeguard the public from oil and natural gas production.