Friday, April 25, 2025

Conventional Oil & Gas Facility Owners Must Now File A Methane Emissions Compliance Report By June 1, 2025 Required By A 2022 DEP Methane Pollution Reduction Rule As A Result Of Court Settlement

The Department of Environmental Protection
published notice in the April 26 PA Bulletin conventional oil and gas facility owners must now submit a compliance report on their methane emissions by June 1, 2025 as required by a 2022 DEP methane pollution reduction rule as a result of a court settlement with the industry.

Conventional facility owners are required to report information on their wells and specific types of equipment, including storage tanks, pneumatic controllers, diaphragm pumps, reciprocating compressors, closed venting systems and other control devices.

Air emissions for the facilities were to be submitted separately to DEP’s Air Quality Emission Inventory.

Compliance with the regulation had been on hold since December 2022 when the conventional oil and gas industry filed a challenge to the regulation in Commonwealth Court.  Read more here.

During the process of adopting the 2022 regulations, DEP estimated conventional oil and gas facilities would account for 80 percent of the total methane emission reductions expected under the regulations which covered both conventional and unconventional shale gas facilities.  Read more here.

Visit DEP’s Annual Reporting For Oil & Natural Gas Sources webpage for more information on reporting requirements.

Background

Both conventional and unconventional shale gas oil and gas facility owners were required to file a compliance report by June 1, 2024 to cover calendar year 2023 as required by 25 Pa Code 129.140(k)(1).

This was actually an extension of the original reporting deadline which was December 2, 2023 that was intended to cover calendar year 2022 information.  This first report was eliminated by DEP under its “enforcement discretion” in a January 24, 2024 PA Bulletin notice.

Conventional facility owners were required to report information on their wells and specific types of equipment, including storage tanks, pneumatic controllers, diaphragm pumps, reciprocating compressors, closed venting systems and other control devices.

Click Here for a copy of DEP’s suggested Excel reporting template.

Air emissions for the facilities were submitted separately to DEP’s Air Quality Emission Inventory.

As a result of a Right To Know request, DEP said as of January 21, 2025 only 27 conventional well facility owners out of an estimated 4,719 owners who were required to submit reports did submit those reports-- less than 1%.

Of those 27, DEP’s Air Quality Emission Inventory [select conventional gas well as facility type and 2023] includes methane and VOC emissions reported by only four companies with conventional facilities-- Blackhawk Energy, LLC; Consol PA Coal Co. LLC; Diversified Production, LLC; and Iron Cumberland LLC.

Together they reported only 1,901 tons of methane and 204.3 tons of VOCs in 2023.

In contrast, 112 of the 130 unconventional shale gas facility owners required to submit compliance reports did comply-- 86%-- 18 shale gas owners have still not submitted reports or contacted DEP.

Of those 112, 63 unconventional shale gas companies reported emissions in DEP’s Air Quality Emission Inventory [select unconventional gas well as facility type and 2023] which shows methane emissions of 47,486.2 tons and VOC emissions of 2,393.1 tons.

DEP expected up to a 175,788 ton reduction of methane from conventional sources [Read more here.] and a 45,278 ton reduction in methane from unconventional shale gas sources [Read more here], according to the Regulatory Analysis Forms for the regulations. 

DEP estimated total 2020 methane emissions from conventional sources to be 365,103 tons and 102,297 tons from unconventional shale gas sources, according to the Regulatory Analysis Forms.

New Oil & Gas Methane Emissions Rule

DEP is now developing a new oil and gas methane emissions reduction program to cover conventional and unconventional shale gas facilities to comply with a new methane regulation adopted by the U.S. Environmental Protection Agency.

EPA has placed a hold on this regulation pending its review under the President’s deregulation executive orders.

On April 24, DEP told members of DCED’s PA Grade Crude [Oil] Development Advisory Council the agency will continue to develop a program to meet these new requirements as long as the federal regulation is on the books.

Representatives of the conventional oil and gas industry at this meeting and one on December 12 asserted conventional well owners cannot comply with the new EPA regulation.

They said, “A very large proportion, perhaps as high as 95% of Pennsylvania conventional gas wells and Pennsylvania conventional oil wells and oil/gas wells which are constructed with a production string of casing, are purposely constructed as to allow the release of methane which methane may not be a steady flow and are constructed that way by regulation.”

After the December meeting, the Advisory Council sent questions to DEP about the new methane reduction program and DEP responded.  Read more here.

At the April 24 CDAC meeting, the group passed a resolution to form a special committee to discuss the new program with DEP calling on the Air Quality Program to meet with members of the conventional industry to discuss how the program will impact the agency.

Resource Link:

-- Conventional Oil & Gas Industry Compliance With 2022 DEP Methane Reduction Regulation Put On Hold Pending Outcome Of Litigation  [PaEN] 

A Oil & Gas Industry Public Notice Dashboards:

-- PA Oil & Gas Weekly Compliance Dashboard - April 12 to 25: Another Abandoned Shale Gas Water Impoundment; 18 More Abandoned Conventional Wells; Exposed Gas Pipeline Crosses Stream  [PaEN] 

-- DEP: Abandoned Shale Gas Water Impoundment Not Used For 7 Years Cited For Not Being Restored In Clarion County  [PaEN] 

-- Conventional Oil & Gas Facility Owners Must Now File A Methane Emissions Compliance Report By June 1, 2025 Required By A 2022 DEP Methane Pollution Reduction Rule As A Result Of Court Settlement   [PaEN]

-- DEP To Hold May 1 Virtual Update On State Response To Energy Transfer/Sunoco Twin Oaks Pipeline Leak In Bucks County  [PaEN]  

-- KDKA: PECO Says Damage To Natural Gas Main That Forced Closure Of I-95 In Philadelphia Appears To Be ‘Purposeful’

-- PA Oil & Gas Industrial Facilities: Permit Notices, Opportunities To Comment - April 19 [PaEN]

-- PA Oil & Gas Industrial Facilities: Permit Notices, Opportunities To Comment - April 26 [PaEN] 

-- DEP Posted 96 Pages Of Permit-Related Notices In April 19 PA Bulletin  [PaEN]  

-- DEP Posted 77 Pages Of Permit-Related Notices In April 26 PA Bulletin  [PaEN]   

Related Articles This Week:

-- DCED Conventional Oil & Gas Well Owner Advisory Group Meets April 24 To Discuss Disposal Options For Wastewater; Updates On Well Plugging, New Methane Reduction Program  [PaEN]

-- PublicSourceNews.org:  Setback On Setbacks: PA Environmental Quality Board Tables Consideration Of New Limits On Drilling Near Building, Water Sources

-- Farm & Dairy: PA Environmental Board Delays Vote On Petition To Increase Shale Gas Well Setbacks

-- Post-Gazette Letter: I Applaud Bucks County Commissioners Who Had The Guts To Challenge The Natural Gas Industry For Contributing To Climate Crisis - Cat Lodge, Washington County Resident

-- Susquehanna River Basin Commission: Low Stream Flows Trigger Restrictions On 29 Shale Gas Water Withdrawals  [PaEN] 

-- Susquehanna River Basin Commission Approved 58 Shale Gas Well Pad Water Use General Permits In March; 142 In 2025  [PaEN] 

-- Environmental Health Project Launches AirView Public, New App To Help Communities Protect Residents From Oil & Gas Pollution; Communities Can Join Today  [PaEN] 

-- PUC Hearing On Data Center Growth Impacts Finds 30-40% Of Utility Demand Could Be From Data Centers; Concerns About Stranded Costs; Major Commitments To Net-Zero Carbon Emissions Energy Use  [PaEN]

-- Reuters: FERC Denies Rehearing On Colocated Amazon Data Center Energy Pact In Luzrne County

-- House, Senate Members Introduce Gov. Shapiro's 'Lightning' Energy Plan To Lower Energy Costs, Create Jobs, Protect Pennsylvania From Global Energy Instability  [PaEN]

-- Gov. Shapiro: FERC Approves Settlement With PJM To Prevent Unnecessary Prices Hikes, Save Consumers Over $21 Billion On Electric Bills  [PaEN] 

-- Utility Dive: Ratepayer Advocates: FERC Should Order PJM To Rerun Last Electricity Capacity Auction; Could Lead To $5 Billion In Consumer Savings 

-- New Report: Fixing PJM’s Broken Electric Generation Approval Process Can Lower Energy Costs, Create Jobs Across The Mid-Atlantic  [PaEN] 

-- North American Electric Reliability Corp. Files Proposed Cold Weather Standard To Improve Reliability For Natural Gas-fired, Other Electric Generators  [PaEN]

-- DEP Releases 2024 Climate Change Action Plan Update; 2024 Climate Impacts Assessment Report [PaEN]

-- DCNR Unveils Solar Energy Facility At Gifford Pinchot State Park In York County Cutting Costs, Climate-Changing Emissions On Public Land; Celebrating 30 Years Of Stewardship  [PaEN] 

-- Eleven Coal, Coal-Waste Power Plants In Pennsylvania Now Covered By Presidential Exemption From 2024 Mercury, Hazardous Air Pollutant Regulation For 2 Years  [PaEN]

-- AP-Marc Levy: Big Tech’s Soaring Energy Demands Are Making Coal-Fired Power Plant Sites Attractive [Not Necessarily The Plants Themselves] 

-- PUC Commissioners Urge Congressional Action To Preserve $19 Million In Remaining LIHEAP Funds For PA This Year  [PaEN] 

-- Energy Association Of PA [Utilities] Calls For Protection Of LIHEAP Low-Income Home Energy Assistance Program

-- PUC Announces May 6, 7 Hearings On Proposed 15.7% Rate Increase For Philadelphia Gas Works  [PaEN]

-- PUC To Investigate Proposed 11.4% Increase In Columbia Gas Natural Gas Rate  [PaEN]  

-- Warren Times: Instead Of ‘Drill, Baby, Drill,’ US Rig Counts Falling, Layoffs Increasing 

-- Financial Times: President’s Tariff Talk Roils US Oil, Gas Industry In Bedrock Republican Territory

-- The Economist: America Won’t Be Able To Bully The World Into Buying More US Natural Gas

-- E&ENews/Politico: President’s Push For More LNG Gas Exports Risks Domestic Price Surge  

-- Financial Times: Growth In Oil Demand Expected To Slow Sharply As A Result Of President’s Tariffs 

-- Financial Times: China Stopped Buying US LNG Gas Feb. 6 Due To Trade War

-- Marcellus Drilling News: EIA Annual Energy Outlook: Oil And Natural Gas Demand Peaks In 2027 and 2032  [PDF of Article]

[Posted: April 25, 2025]  PA Environment Digest

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