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October 07, 2015
Target: Methane
By Timothy P Fagan, Senior Legal Editor - EHS

In June 2013, President Obama introduced his Climate Action Plan and made it clear that addressing climate change would be one of the hallmark issues of his second term.  As part of the action plan, he directed federal agencies to develop strategies to reduce methane emissions, a greenhouse gas (GHG) 25 times more potent than carbon dioxide.

While other climate change initiatives, such as the Clean Power Plan, have been grabbing the headlines, progress in reducing methane emissions steadily moves forward.  In 2014, the President’s Strategy to Reduce Methane Emissions was released, which specifically identified the following target industries, along with the goal of improving the quality of methane emissions data through better monitoring:

  • Landfills
  • Oil and Gas
  • Coal Mines
  • Agriculture
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In August 2015, the EPA issued a supplement to a July 2014 proposed rule for new, modified, or reconstructed sources, along with emissions guidelines for existing sources.  The new New Source Performance Standards (NSPS), 40 CFR 60, Subpart XXX, will apply to all landfills beginning construction, reconstruction, or modification after July 17, 2014, and all others will be existing sources subject to the new emissions guidelines (40 CFR 60, Subpart Cf).  The standards lower the threshold that triggers the installation of landfill gas collection and control systems.

Oil and Gas

In January 2015, the Obama administration announced its goal for methane reductions from the oil and gas (O&G) industry: 40 percent to 45 percent from 2012 levels by 2025.  The EPA followed up this announcement in August 2015, with proposed amendments to the NSPS for Crude Oil and Natural Gas Production, Transmission, and Distribution (40 CFR 60, Subpart OOOO) and a new Subpart OOOOa for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commences after the date of publication in the Federal Register.  Under the proposal:

  • Methane emissions are now regulated.
  • Green completion requirements apply to hydraulically fractured oil wells.
  • The scope of emissions controls has been expanded to cover additional sources, equipment, and components, including methane leak detection and repair.

Agriculture and Coal Mines

The EPA and the U.S. Department of Agriculture are addressing agricultural methane emissions by identifying actions that can be taken to increase the use of biogas as a renewable energy source.  Coal mine methane emissions are being addressed by the U.S. Department of the Interior, which has initiated rulemaking to address the capture, use, sale, or destruction of waste mine methane from mining operations on public lands. 

Impact and Outlook

The methane reductions to be achieved by the aforementioned actions are significant.  The combined impact of the landfill and O&G regulations will reduce methane emissions by approximately 20 million metric tons of carbon dioxide equivalents (CO2e).  The potential impact of biogas as a renewable energy resource could reduce methane emissions anywhere from 4 million to 54 million metric tons of CO2e.  The overall impact of the actions taken in the coal mining sectors is not yet accurately known.

The second part of the methane reduction strategy is to improve the data on methane emissions through improved monitoring technologies, direct measurements, and enhanced modeling.  As the data improve and reveal different trends, expect actions to be taken to further address methane emissions from the aforementioned sources or expand methane control requirements to other sectors.

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