Michael L. Krancer
The key is what the Inventory does not report because of its odd way of reporting on a per facility basis. In fact, methane emissions per unit of production have been going down very measurably over the years. Here’s the story on CH4 emissions per million cubic feet gas produced (Tons CO2e/MMcf)
That’s a 59 percent reduction from 2012 to 2015. That I have not seen reported in the news media. (Also, let’s not forget the reduction in CH4 per million cubic feet of production of 94 percent which happened between 2008 and 2013).
This raises real questions about what science is behind the so-called “Methane Strategy” for unconventional oil and gas operations that was unveiled back in January 2016 and on what data DEP could have based its General Permit-5A approach. The GP-5A is the newly-proposed first time ever, pre-construction permit for unconventional gas well sites. The answer looks like “no data”.
No question that reduction of methane emissions is a worthy goal. But the advancing technology and practices on the ground have been and are doing a great job on that already without any government imposed “strategy” or General Permit.
DEP’s GP-5A approach declined to calculate emissions as a function of production, thus ignoring the increasing efficiency in the industry. In addition, DEP’s decision to lead with the “per facility” calculation ignores the reductions achieved at well sites—thus is totally contradictory to DEP’s supposed reasons for the GP-5A.
I know that the phrase “a solution in search of a problem” is used a lot but it’s a dead-on description of this particular part of the “Methane Strategy” and the GP-5A.