On January 20^thPennsylvania Department of Environmental Protection Secretary John Quigley hosted a webinar to announce the steps his department will take to control methane emissions associated with unconventional natural gas activities in the Commonwealth. He outlined an aggressive plan he and Governor Wolf believe is necessary to reduce Pennsylvania’s contribution of greenhouse gas emissions. He noted that Pennsylvania currently ranks second behind Texas in natural gas production so they feel the emissions must be addressed sooner rather than later. The Secretary offered some immediate steps that will help address what they believe are the unaccounted for emissions from shale gas wells and support facilities.

He identified the scope of their concern by noting that Pennsylvania has over 3,000 unconventional gas well pads, over 500 unconventional gas compressors stations and 12,000 miles of pipelines to move the gas. They believe the combined annual methane leaks from these facilities are equivalent to the annual emissions of five coal fired power plants. Secretary Quigley noted that while efforts have been undertaken by the industry and some companies to identify and reduce methane emissions, not enough has been done on a statewide basis. DEP therefore offered a four point plan that will surpass the EPA’s New Source Performance Standards for controlling methane emissions.

The four point plan includes:

• A new general permit for well pads that will require the use of Best Available Technology, more detailed record keeping and quarterly inspections by the operator.

• A new general permit for compressor stations also requiring the use of Best Available Technology including Tier 4 diesel or electric engines.

• The use of Best Available Technology for pipelines and gathering lines, including the recommendations of the PA Pipeline Infrastructure Task Force, to monitor, identify and repair leaks.

• New rules for existing facilities. These rules have apparently already been drafted, and will be reviewed in February by the DEP’s Air Quality Technical Advisory Committee with the hope of final promulgation in 2017. They will require the use of Reasonably Available Control Technology for all existing sites.

Based on DEP’s calculations, the cost to the industry for implementing these new requirements will be minimal – the recovered gas will pay for the increased costs to comply and implement. DEP anticipates a 40 percent reduction in statewide emissions from these measures.

Sadly, Secretary Quigley failed to give the natural gas industry any credit for the significant gains it has made in reducing methane emissions while increasing natural gas production. He noted that industry figures represent only one study and industry needs to provide some proof that the stated reductions have occurred. No mention was made of the 2015 EPA data that show an 81 percent reduction in methane emissions from hydraulic fracturing operations or 2015 PA DEP data that show a 13 percent reduction in methane emissions from gas development activities in Pennsylvania.

The revised general permits for well pads and compressor stations will be released in the near future and the industry will be assessing what impacts these will have on site requirements and permit timing. The existing facility rules will be subject to rulemaking procedures and will certainly be reviewed and commented on by industry.