Testimony on Proposed Air Pollution Standards for Oil & Gas Sector

September 29th, 2011

Testimony on Proposed Air Pollution Standards for Oil & Gas Sector

David Weinberg

Executive Director, Texas League of Conservation Voters

EPA Hearing + Arlington, Texas + Sept. 29, 2011

The Environmental Protection Agency’s proposals to address air pollution standards should do much to provide clarity to industry and stakeholders and reduce air pollution from oil and natural gas operations.

It’s a worthy effort, and one that despite some state leaders’ long-running feud with EPA is welcomed here by many in the public, community leaders, conservationists and environmental organizations like mine.  Balancing market needs and demands with public health and safety concerns is an essential role of government.

The National Petroleum Council’s (NPC) recently released report, Prudent Development (Sept. 2011,, suggests that if natural gas development is done right, our state and our nation’s vast natural gas reserves could be – in the words of the NPC itself – “transformative for the American economy, energy sector and environment.”

The pivotal point in this is that we do it right.  Doing it right means leveraging reasonable regulations and effective available technologies to reduce emissions.  Doing so means a truly win-win-win situation for the environment, consumers and industry.

Texas has  been a leader in improving drilling practices from hydraulically fractured wells, passing the nation’s first mandatory disclosure law for hydraulic fracking fluids this year. Improving air quality controls for gas and oil drilling is a necessary next step in advancing drilling practices.

Compared to coal, natural gas, delivers significant benefits for air quality, emitting far less nitrogen oxides, little sulfur dioxide and no mercury per unit of electricity produced.  The cleaner-burning benefits of natural gas in particular also improve as we cut down on fugitive emissions from natural gas production, namely methane emissions.  For these reasons, TLCV strongly supports proposed EPA regulations on improvements for natural gas compressors, pneumatic devices, and storage tanks.

TLCV feels strongly that the EPA’s proposal significantly improves the New Source Performance Standards (NSPS) under the Clean Air Act.  By requiring the use of reduced emission completions, for example, we would be working to reduce the emissions of volatile organic compounds, though further clarity of the specific terminology and applicability of the rule to “workover” wells and liquid unloading would do much to help address the environmental community’s concerns and, no doubt, provide a level of clarity to benefit both public and industry alike.

Regardless of the EPA regulations ultimately adopted, TLCV strongly believes that Texas on the whole must do a better job of policing drilling – which means better funding of the Texas Railroad Commission – and establishing clarity between the Railroad Commission and the Texas Commission on Environmental Quality.  Improved stakeholder and constituent input and response are also needed.

And, it’s a resource with such an abundant supply here in Texas that if it is safely produced and properly regulated, that it’s production could stand to generate significant severance tax revenue—supplying much needed general revenue during very difficult economic times and providing potentially more revenue for the critical state regulatory needs.

TLCV is confident this can be accomplished in a way that benefits and addresses the environmental and public health concerns, while providing reasonable regulatory measures and considerable savings to the industry.

Thank you for the opportunity to testify today.

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