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Wednesday, February 27, 2013

Are shale gas best practices really “best”?


I’ve written extensively on the essential work of The Nature Conservancy in gaining an understanding of the cumulative impacts of natural gas development in Pennsylvania (and elsewhere). Understanding the possible impacts is only half of the equation.  The second half – developing best management practices (BMPs) to avoid, minimize, or mitigate them – will in large measure determine whether Pennsylvania repeats the environmental mistakes of its past history of resource extraction. That requires continual work – development and application of practices, monitoring their results, and continuously improving them.  What is identified as a best practice today may not be six months from now, as more data and better understanding are developed.

TNC continues to do great work in developing both sides of this calculus.

In a peer-reviewed article published in the December 2012 issue of Environmental Practice journal, TNC discusses its analysis of 28 BMPs related to surface impacts of natural gas development on habitat and wildlife and their test of whether each practice was supported in the scientific literature. As TNC writes:

Extensive shale gas development is expected throughout the Appalachian Basin, and implementing effective avoidance and mitigation techniques to reduce ecosystem impacts is essential. Adoption of best management practices (BMPs) is an important approach for standardizing these techniques. For BMPs to be credible and effective, they need to be strongly supported by science.

TNC reached four basic conclusions:
  1. The vast majority of BMPs are broadly written.  This provides flexibility in implementation, “but the lack of site-specific details may hamper effectiveness and potential for successful conservation outcomes”; 
  2. Much more research is needed many BMPs, especially those relating to noise and light pollution; 
  3. The BMPs with the strongest scientific support include landscape-level planning and shared infrastructure; avoidance of sensitive areas, aquatic habitats, and core forest areas; and road design, location, and maintenance; and 
  4. “(A)ctions to enhance the development and implementation of BMPs should include public education, increased communication among scientists, improved data sharing, development of site-specific BMPs that focus on achieving ecological outcomes, and more industry collaboration.”

     TNC recommends that these practices should be central to any set of Shale Gas BMPs:

·        Landscape-Level Planning:
o   Avoid/minimize clearing in large forest patches and sensitive habitats
o   Avoid/minimize crossings of wetland and riparian habitats
·        Stream Crossings:
o   Locate stream crossing structures so they do not decrease channel stability or increase water velocity
o   Design road crossings to allow fish passage at all flow levels
·        Seasonal Restrictions / Timing of Operations:
o   Avoid earth moving operations during wet seasons and wet periods
o   Avoid construction in stream courses during spawning times
·        Road and Pipeline Location, Design, and Maintenance:
o   Manage pipelines for shrub cover rather than grass and create forested linkages at regular intervals to facilitate wildlife movement
o   Provide proper drainage and erosion control for all roads and pipelines

TNC’s essential work so far is presented in this Powerpoint presentation, which can be found on Penn State Extension’s rich natural gas webpage.  That page also links to a recorded webinar on TNC’s work.

TNC's calls for more and better science, specificity in prescriptions, improved communication, and industry collaboration must be heeded.



Monday, February 25, 2013

Report: EPA must improve air emissions data on oil/gas production


The U.S. Environmental Protection Agency Office of Inspector General has issued a report whose conclusion is stated in its title: EPA Needs to Improve Air Emissions Data for the Oil and Natural Gas Production Sector.

According to the report, oil and gas production emit “large amounts of harmful pollutants that impact air quality on local, regional, and global levels.”  Between 1992 and 2010, the report says, about 210,000 new gas wells were drilled in the U.S, and onshore oil and natural gas production is expected to increase 30 and 18 percent, respectively, by 2025.

That high growth underscores the need for EPA to gain a better understanding of emissions and potential risks from oil and gas production.  Quoting at length from the report: 

However, EPA has limited directly-measured air emissions data for air toxics and criteria pollutants for several important oil and gas production processes and sources, including well completions and evaporative ponds. Also, EPA does not have a comprehensive strategy for improving air emissions data for the oil and gas production sector; the Agency did not anticipate the tremendous growth of the sector, and previously only allocated limited resources to the issue.  

In addition to their use in making a variety of key decisions, EPA uses air emissions data to develop emission factors. These are representative values that relate the quantity of a pollutant released with an activity associated with its release. States use EPA’s emission factors to develop emission inventories, issue permits for facilities, and take enforcement actions. Limitations in EPA’s air emissions data for a number of oil and gas production pollutants have contributed to emission factors of
questionable quality.
. 
EPA uses its National Emissions Inventory (NEI) to assess risks, track trends, and analyze envisioned regulatory controls. However, oil and gas production emissions data in the 2008 NEI are incomplete for a number of key air pollutants. For example, only nine states submitted criteria pollutant emissions data for small stationary sources. Because so few states submitted data for this sector, we believe the NEI likely underestimates oil and gas emissions. This hampers EPA’s ability to
accurately assess risks and air quality impacts from oil and gas production activities.

We recommend that EPA develop and implement a comprehensive strategy for improving air emissions data for the oil and gas production sector, prioritize which oil and gas production emission factors need to be improved, develop additional emission factors as appropriate, and ensure the NEI data for this industry sector are complete.

The report says that EPA concurred with the OIG recommendations to develop a comprehensive strategy, improve and prioritize emission factors, and develop default nonpoint emission estimates. EPA did not concur with recommendations to ensure
that states submit required data and develop default calculation guidance.

EPA has already begun an inter-agency study of methane, air toxins and other pollutants released during oil and gas production. 

This is not an esoteric exercise. As I wrote here, there is ample reason for serious concern about air pollution from natural gas development at local and regional levels.  And the impact of methane emissions is global.  EPA, which is doing such thorough and transparent work around other concerns about natural gas development, is being similarly transparent about this issue. 

The report should be read closely.