Thursday, Feb. 12, 2012 | PERMALINK | PDF

Contact: Jeff Eshelman • 202-857-4774 • jeff@energyindepth.org Chris Tucker • 202-346-8825 • chris@energyindepth.org 

# * * * 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 Universit y of Colorado proves that producers in the DenverJulesburg Basin of northeast Colorado are losing fo ur 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 hims elf. Unfortunately for Prof. Howarth, the deeper you dig into the DJ Basin report, the clearer it becomes t hat the NOAA paper isn’t at all comparable to the Howar th paper – mostly, for starters, because they study two entirely different things. What’s far less clea r: the extent to which NOAA’s conclusions are even relevant anymore in a modern operating context, giv en that most of the agency’s data is nearly half a decade old. Below, we identify a few key facts from the NOAA pa per that, taken together, provide some additional context for those who care to consider it: Key Fact I: Overstates emissions from largest sourc e

• The study claims that large and small condensate t anks 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 eff ect that included requirements on condensate tanks, including the use of surveillance systems an d auto-igniters to dramatically reduce emissions. (Code of Colorado Regulations, 5 CCR 1001-9, XII ).
• Colorado’s Air Pollution Control Division: “New an d 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 not es 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 red ucing 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 equi valent (26 percent) reduction in methane. Clearly there’s a strong correlation between VOC-re ducing technologies and reducing methane emissions.
• Plainly put, the largest source of emissions for W eld County is today, by law, much more tightly controlled, and emissions have been reduced signifi cantly.Key Fact II: Overstates emissions from second large st source

• The study claims that pneumatic devices are respon sible for roughly 13 percent of VOC emissions, the second largest single source (NOAA s tudy, p. 7 ).
• But again, the mobile lab data collected by NOAA i s from 2008. And the state’s regulations, in addition to covering condensate tanks, also require d the utilization of no-bleed or low-bleed pneumatic devices as of February 1, 2009 (with retr ofits 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 devi ces: “ 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 a s any device that emits more than 50 Mcf of methane per y ear, which means these devices reduce methane emissions by as much as (and often more tha n) 90 percent

. • Colorado Department of Public Health and Environme nt, on its proposed air emissions regulations: “While the low end of the emission ran ge is a lower threshold than required for other emission sources, industry is already converting most high-bleed devi ces . 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 emis sions data as recorded from several NOAA observation towers throughout the country. These in cluded 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, a ccording 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-Jules burg 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 t he NOAA study provides no real explanation about why a tower far removed from any industrial a ctivity and located in a federally protected forest would record higher methane emissions.
• The researchers suggest it is difficult to make co nclusions 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 metha ne 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 f all “ roughly in line ” with the Howarth paper, and even solicited input from Howart h 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 stud y, 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 rele ased, followed by production. In the NOAA study, the scie ntists looked at overall emissions for the entire b asin, including new and old wells, producing or being dri lled, as well as sources such as leaks from compressors and gathering pipelines. Pétron agreed that the two studies cannot be direct ly compared .” (E&E News, February 16, 2012 (subs. req’d))