The People of America's Oil and Natural Gas Indusry

Message to EPA: Haste Makes Waste

Jane Van Ryan

Jane Van Ryan
Posted October 26, 2010

The staff at the Environmental Protection Agency (EPA) has a whip snapping at its heels. For more than a decade now, the agency has been developing and refining its methodology for a "top down" inventory of greenhouse gas (GHG) emissions in the United States based on macroeconomic information. With that, the agency's career professionals have been rushing for the past two years to establish a "bottoms up" process for inventorying GHGs, including carbon dioxide and methane, and have ordered large and small facilities all over the country to collect emissions data and file reports.

If you thought the government already had a good handle on the GHG emissions generated in the United States, you'd be mistaken. The fact is, this reporting rule is designed to gather detailed emissions data to inform future policy. This means that the Waxman-Markey bill, the Kerry/Lieberman/Graham bill and other efforts to legislate or regulate GHGs have been based largely on macroeconomic assumptions and estimates, not factual data. Needless to say, it's hard to regulate something when the government doesn't know its precise size, source, or scope. It would be like passing an ordinance to control fishing in a pond when no one knows how many fish it contains.

At any rate, EPA is trying to remedy the lack of data by requiring the reporting of GHG emissions from a wide variety of industries, including the oil and natural gas industry. Refineries have been collecting the data for several months and are preparing to report them. At present they are waiting for the tools that will allow them to submit data online starting in January 2011.

But the exploration and production (E&P) sector of the oil and natural gas business, which is spread out over a wide swath of the country and not as easily defined or accessible as refineries, is waiting for EPA to release its rule on what facilities need to collect data, what kind of data to collect, and how to submit them. The rule was expected this month, but so far nothing has been issued. Yet, the data are supposed to be submitted next year sometime.

In a series of webinars on electronic GHG data reporting, EPA has announced that it will not test the reporting system or allow users to run a few reports to check on the integrity of the online tools. No, it doesn't have time for that. Nor does it have time to carefully examine the entire process of data collection. Instead, it is rushing forward to meet a timetable that appears to be driven by politics, not common sense.

And where will the E&P portion of the oil and natural gas business have to gather GHG emission data? Potentially everywhere. From the smallest stripper well in a remote part of Wyoming, where a pump is lifting a barrel or two of oil a day, to natural gas wells on mountain ridges in West Virginia accessible only on foot, to the individual pipeline pumping stations all along the Trans Alaskan Pipeline. And the cost is monumental - estimated at $1.8 billion for personnel, equipment, and laboratory expenditures among others.

Further, none of this expense will reduce GHG emissions; it will only measure them. A couple of years ago, EPA and the industry had worked together to look at ways to gather reliable data, but that initiative was abandoned in the rush to issue a mandatory reporting rule. Under this administration, there's not enough time to do it right.

The administration should slow down and examine GHG emissions carefully and thoughtfully. Rushing to collect data and using tools that haven't been tested are likely to provide a flawed GHG inventory that results in bad public policy. Random, hastily collected data will be of no use to develop and inform any future U.S. climate change policy. As the old adage says, haste makes waste.