ORAL TESTIMONY ON THE PROPOSED POWER PLANT RULE 

BY BRUCE FERGUSON OF CATSKILL CITIZENS FOR SAFE ENERGY 

http://www.catskilicitizens.org/index.cfm 

JULY 29, 2014 DENVER, COLORADO 

Thank you for the opportunity to testify today. I am grateful that EPA is willing to 

use its established regulatory authority to curb harmful emissions at a time when 

it is clear that Congress lacks the will to address this important issue. 

I represent Catskill Citizens for Safe Energy, an all-volunteer grassroots 

organization with 14,000 members in New York State and around the country. 

My community which sits atop the Marcellus Shale, organized in 2008 in 

opposition to high-volume hydraulic fracturing because it was apparent that this 

inherently dangerous industrial process posed a threat to our drinking water, our 

health, and our community character. Today it is clear that fracking is not only a 

local issue, it's an international one, because the extraction, processing and 

transmission of shale gas releases so much heat-trapping methane into the 

atmosphere that if fracking goes unchecked it will be impossible to avoid the 

devastating impacts of climate change. 

While I appreciate EPA's willingness to address power plant emissions, I believe 

the method selected to measure emissions is deeply flawed. If the rule is 

implemented as written, it could produce a result that is, in one important way, 

the exact opposite of what is intended—instead of curtailing total greenhouse gas 

emissions, it may actually increase them and exacerbate climate change. 

The problem with the rule is twofold. First, it addresses only smokestack 

emissions, not all emissions produced by fossil fuels consumed by power plants. 

Second, it addresses only carbon dioxide, not all greenhouse gases. 

It might make sense to focus solely on smokestack emissions of carbon dioxide if 

all fossil fuels had similar patterns of greenhouse gas emission, but that is simply 

not the case. 

Coal releases large quantities of carbon dioxide into the atmosphere when it is 

burned, and these emissions would be regulated by the rule. 

On the other hand natural gas, particularly shale gas that is extracted by 

hydraulic fracturing, releases large quantities of methane during extraction, 

processing and transmission. Under the proposed rule, these lifecycle emissions 

are not measured, and will go unregulated. 
Pound for pound methane traps eighty-six times more heat than carbon dioxide 

when it is released into the atmosphere, and the volume of so-called "fugitive 

emissions" is so great that many scientists have concluded that the greenhouse 

gas footprint of shale gas is actually greater than that of coal over a twenty year 

timeframe. Robert Howarth et at reached this conclusion in 20111, and it has 

been supported by a number of more recent studies2; yet it is utterly ignored in 

this power plant rule. 

A related problem is that EPA only considers the Global Warming Potential 

(GWP) of methane over the 100-year time period, which is much less that its 

GWP over the critical 20-year time period when we must act to avoid the dire 

impacts of climate change. The problem with looking at the 100-year time period 

instead of the 20-year time period was summed up in an article by Joe Romm 

aptly titled By The Time Natural Gas Has A Net Climate Benefit You'll Likely Be 

Dead And The Climate Ruined2 

Despite these major defects, it has been suggested that the proposed rule is a 

good first step, and that fugitive methane emissions can and will be addressed by 

another rule, at a later date. But later is likely to be too late. While EPA continues 

to study fugitive methane emissions, this rule, which is due to be adopted next 

year, explicitly encourages large-scale investment in new gas-fired power 

plants—plants that will be powered by shale gas. 

Once these new power plants are built, the owners will understandably expect to 

amortize construction costs over decades. If, in a year or two, or three, EPA 

determines that the fugitive emissions associated with fracked gas are as 

detrimental as many independent scientists now say they are, and if it turns out 

that curtailing fugitive emissions should prove to be an intractable problem, the 

agency will not be in a position to reverse course and demand that newly 

constructed gas-fired plants be taken offline. 

For this reason, fugitive methane emissions associated with shale gas must be 

addressed now, in the proposed rule, if it is to be an effective tool in fighting 

climate change. When EPA does consider the totality of harmful emissions 

associated with all fossil fuels, it will become apparent that replacing one fossil 

fuel with another makes no sense. A comprehensive assessment of lifecycle 

emissions from fossil fuels will lead to only one conclusion—the only responsible 

course of action is to rapidly develop renewable energy systems that will quickly 

free us from our dependence on all fossil fuels. 

1. Howarth, 'R. W., R. Santoro, and A. Ingraffea. 2011. Methane and the greenhouse gas 

footprint of natural gas from shale formations. Climate. Change Leterst. 106:679-690. 

inr/7' 

2. By The Time Natural Gas Has A Net Climate Benefit You'll Likely Be Dead And The 

Climate Ruined by Joe Romm in CLIMATEPROGRESS, February 19, 2014. 
3. Howarth, R. W., R. Santoro, A. Ingraffea. Venting and leakage of methane from shale 

gas development: reply to Cathles et al. 2012. Clim. Change 113:537-549. 

do 

Howarth, R. W., D. Shindell, R. Santoro, A. Ingraffea, N. Phillips, and A. TownsendSmall. 2012. Methane emissions from natural gas systems. Background paper prepared 

for the National Climate Assessment, Reference # 2011-003, Office of Science & 

Technology Policy Assessment, Washington, DC. Available at 

_:..)–:%20National%20 

Climate%20Assessment.p- (accessed 1 March 2012). 

Hughes, D. 2011. Lifecycle greenhouse gas emissions from shale gas compared to coal: 

an analysis of two conflicting studies. Post Carbon Institute, Santa Rosa, CA. Available 

Howarth, R. W., and A. Ingraffea. 2011. Should fracking stop? Yes, it is too high risk. 

Nature 477:271-273.