Thursday, Feb. 12, 2012 | PERMALINK | PDF

Contact: Jeff Eshelman • 202-857-4774 • jeff@energyindepth.org

 Chris Tucker • 202-346-8825 • chris@energyindepth.org 

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Four Key Facts on the NOAA Shale Study 

To hear the folks at Nature and the Denver Post tell it, a recent study from the National Oceanic and 

Atmospheric Administration (NOAA) and the University of Colorado proves that producers in the DenverJulesburg Basin of northeast Colorado are losing four percent of their total production of natural gas – 

frittered away, right into thin air. Some have even suggested the study validates the Howarth paper from 

last year, including the discredited professor himself. 

Unfortunately for Prof. Howarth, the deeper you dig into the DJ Basin report, the clearer it becomes that 

the NOAA paper isn’t at all comparable to the Howarth paper – mostly, for starters, because they study

two entirely different things. What’s far less clear: the extent to which NOAA’s conclusions are even 

relevant anymore in a modern operating context, given that most of the agency’s data is nearly half a 

decade old. 

Below, we identify a few key facts from the NOAA paper that, taken together, provide some additional 

context for those who care to consider it: 

Key Fact I: Overstates emissions from largest source

• The study claims that large and small condensate tanks are “estimated to be the largest VOC 

fossil fuel production source category (59% and 9% respectively)” (NOAA study, p. 6-7). 

• The mobile lab samples analyzed for the study were taken in 2008. But in February 2009, new 

regulations for the state of Colorado went into effect that included requirements on condensate 

tanks, including the use of surveillance systems and auto-igniters to dramatically reduce 

emissions. (Code of Colorado Regulations, 5 CCR 1001-9, XII). 

• Colorado’s Air Pollution Control Division: “New and existing condensate tanks emitting 20 tons 

per year or more of VOCs [are] required to control emissions by 95 percent.” In Weld County, 

the area of study for the NOAA report, the APCD notes that VOCs must be controlled by 70 to 

90 percent. (APCD, accessed on February 22, 2012). 

• U.S. EPA: Reducing VOCs will “yield a significant environmental co-benefit by reducing 

methane emissions” as well (EPA, July 2011 [PDF]). The EPA also assessed that its plan to 

reduce VOCs by 25 percent would yield a nearly equivalent (26 percent) reduction in methane. 

Clearly there’s a strong correlation between VOC-reducing technologies and reducing methane 

emissions. 

• Plainly put, the largest source of emissions for Weld County is today, by law, much more tightly 

controlled, and emissions have been reduced significantly. 
Key Fact II: Overstates emissions from second largest source

• The study claims that pneumatic devices are responsible for roughly 13 percent of VOC 

emissions, the second largest single source (NOAA study, p. 7). 

• But again, the mobile lab data collected by NOAA is from 2008. And the state’s regulations, in 

addition to covering condensate tanks, also required the utilization of no-bleed or low-bleed 

pneumatic devices as of February 1, 2009 (with retrofits for existing systems required by May 1, 

2009). (Code of Colorado Regulations, 5 CCR 1001-9, XVIII). 

• U.S. EPA, on impacts from low-bleed pneumatic devices: “Reductions in methane emissions 

can range from 45 to 250 Mcf per device per year, depending on the device and the specific 

application” (EPA, November 2011 [PDF]). The EPA classifies high-bleed pneumatics as any 

device that emits more than 50 Mcf of methane per year, which means these devices reduce 

methane emissions by as much as (and often more than) 90 percent. 

• Colorado Department of Public Health and Environment, on its proposed air emissions 

regulations: “While the low end of the emission range is a lower threshold than required for other 

emission sources, industry is already converting most high-bleed devices. Therefore, this 

proposed regulation represents a reasonably simple means of ensuring further VOC reductions.” 

(CDPHE, November 2008 [PDF]) 

• Once again, the NOAA study is relying on data from an operating environment that no longer 

exists. 

Key Fact III: Reports higher methane emissions in a national forest

• For a basis of comparison, the study included emissions data as recorded from several NOAA 

observation towers throughout the country. These included two in California, two in Colorado (one 

of which, the Boulder Atmospheric Observatory (BAO) was utilized for data collection in this 

particular study), and one each in Texas, Oklahoma, and Wisconsin. 

• The tower in Wisconsin (LEF) – which is located, according to the NOAA study, “in the middle of 

the Chequamegon National Forest” (NOAA study, p. 11) – recorded a higher methane level 

than the BAO tower, which collected air samples from the Denver-Julesburg Basin. Here’s the 

accompanying chart, with the key items highlighted (click the image for a larger version): 

• There could be a legitimate reason for this, but the NOAA study provides no real explanation 

about why a tower far removed from any industrial activity and located in a federally protected 

forest would record higher methane emissions. 

• The researchers suggest it is difficult to make conclusions about methane levels because 

methane is a “long-lived gas” (NOAA study, p. 17). 

o EPA: Methane has a “relatively short atmospheric lifetime” (EPA, accessed on 

February 22, 2012) 

o NOAA, describing methane: “[I]ts lifetime in the atmosphere is brief.” (NOAA, 

accessed on February 22, 2012) 
Key Fact IV: No comparison with Howarth

• Because the NOAA study appeared to show high methane emissions from natural gas systems, 

the press immediately began linking it to the widely discredited Cornell study on shale gas 

emissions. Nature, for example, wrote that the study’s conclusions fall “roughly in line” with the 

Howarth paper, and even solicited input from Howarth on the study. 

• Michael Levi, CFR Senior Fellow for Energy and the Environment: “[T]his comparison doesn’t 

work.” Levi likened such a comparison to one between apples and oranges. (CFR blog, 

February 13, 2012) 

• Gabrielle Pétron, the lead author of the NOAA study, has publicly stated that it cannot be directly 

compared with Howarth’s paper. From E&E News: 

“In the Cornell study, scientists estimate leakage from drilling a well, when a lot of methane is released, 

followed by production. In the NOAA study, the scientists looked at overall emissions for the entire basin, 

including new and old wells, producing or being drilled, as well as sources such as leaks from 

compressors and gathering pipelines. Pétron agreed that the two studies cannot be directly 

compared.” (E&E News, February 16, 2012 (subs. req’d))