Report on Pennsylvania’s Methane Reduction Plan, General Permit for Well Pads, and GP-5 Modifications

The agenda for the Air Quality Technical Advisory (AQTAC) meeting on February 11, 2016 included the following informational items pertaining to the natural gas industry.

1. 1. 1. Pennsylvania’s Methane Reduction Strategy
      2. Concepts for the Proposed General Permit for Well Pads
      3. Concepts for the Proposed GP-5 Modifications

Having several clients operating in Pennsylvania within the natural gas production and midstream segments and also serving as an active member of Pennsylvania’s Independent Oil & Gas Association (PIOGA) Air Quality Subcommittee, I was eager to attend this particular AQTAC meeting.  The natural gas topics were scheduled to be the first item of business following the lunch break.  I note the timing of the natural gas topics because the audience chairs were sparsely filled throughout the morning session.  The room had a completely different vibe after I returned from a quick lunch at the nearby pizza shop.  The amount of spectators for the afternoon session (i.e., the natural gas topics) had increased significantly and there was energy not present during the morning.

The afternoon session included the Honorable John Quigley, Pennsylvania Department of Environmental Protection (PADEP) Secretary, presenting Pennsylvania’s Methane Reduction Strategy and Mr. Krishnan Ramamurthy (PADEP) presenting the Concepts for Proposed General Permit of Well Pads and Proposed GP-5 Modifications.  There were also several public commenters that spoke during the public comment period.

The AQTAC meeting written presentation concerning natural gas general permits is available on their website here.  Several other documents related to Pennsylvania’s methane emission reduction strategy can be found on PADEP’s Methane Reduction Strategy website.   In an effort to not rerepeat the Department’s news release and presentations, I decided to provide below a few thought-provoking items that were presented verbally during the meeting.

• Reports were cited that predict that Pennsylvania’s climate change (i.e., warming) will result in the loss of the Commonwealth’s ski industry by 2050.
• Fugitive methane emissions (i.e., leak rate) estimates ranged from <1 % to >90%.
• Voluntary emissions reductions are thought to be ineffective for a nation leading/best in class methane reduction plan.
• There were lessons learned during the application of Exemption No. 38 that will be applied to the development of a new general permit.

• Pigging operations [and associated emissions] are complex.
• PADEP is aiming to issue new and revised GPs in October 2016.

I just effectively reduced 1.75 hour of presentation into six bullet points with approximately 100 words.  If you are interested to learn more about this topic, I can talk details at length.  I plan to closely follow the development of PADEP’s Methane Reduction Strategy.  Give me a call to discuss this meeting or check in for updates.  My contact information is (610) 933-5246, extension 120 or jkleinle@all4inc.com.   I’d love to hear from you.