Arvind P. Ravikumar Profile picture
Nov 18, 2022 14 tweets 9 min read Read on X
Let's get into one of the most far reaching pieces of regulatory action from @EPA. 3 areas stand out:

1) Comprehensive - every possible #methane source is covered, no loopholes
2) Embraces tech innovation even under uncertainty
3) Acknowledges & corrects for EPA blind spots
🧵
All O&G #methane sources are covered, including low producing sites & often owned by small, independent companies. Research has show these type of sites can be a significant source of emission, and until recently, was exempted from all regs.

Not anymore. nature.com/articles/s4146…
Changing definitions: This may be in the weeds but a huge shift in accounting for #methane. Policy stringency now depends on physical number of equipment on facilities and not arbitrary baseline emissions.

This significantly improves policy effectiveness & compliance monitoring.
Using better models: Instead of assumptions about policy effectiveness, EPA used our FEAST model to empirically assess long-term emissions reductions.

I will publish FEAST technical guidance document by Dec 15 for stakeholders. Stay tuned. arvindravikumar.com/feast
Embrace tech innovation: EPA has develop a tech-agnostic approach using FEAST modeling to allow operators to choose whatever tech they want using a matrix approach we (+others) recommended.

This strikes the right balance between flexibility & need for assurance.
What's game-changing? EPA explicitly included super-emitters in modeling -> this is the only reason alternate techs are cost-effective.

Now,
1) Any tech can apply to be approved by EPA
2) Once approved, any operator can use that tech for compliance pubs.acs.org/doi/abs/10.102…
EPA is also allowing use of fence-line continuous emissions monitoring system (CEMS) based on flexible alarm threshold.

Many questions here since there's much uncertainty in emissions quantification using CEMS. Plus, approval criteria is a bit vague (probably intentional).
Super-emitters is where I give great credit to the EPA. These don't exist in GHG inventory.

Yet, EPA looked at overwhelming evidence & crafted a super-emitter mitigation program for emissions >100 kg/h (so big that satellites can see it). nasa.gov/feature/jpl/me…
Here's the innovation: any entity approved by EPA (researcher, tech, NGO, public) can notify EPA & operator if they find superemitter. Once notified, operator must fix it.

EPA also has mechanism for operator to get approved entity delisted for false alarms. So, stick + carrot.
Finally, flaring! Here again, EPA is requiring no routine flaring, plus continuous monitoring of the flame to ensure it does not go out. Huge impact in terms of emissions reductions!
I believe this is one of the most far-reaching & innovative proposal to address #methane emissions.

The top-line 87% emissions reduction is not only achievable but can be exceeded, especially with the super-emitter & flare reduction program!

Bravo!

epa.gov/controlling-ai…
Two issues I did not cover here.

First, @jasonfurman provides a good overview of the updated Social Cost of Carbon (and methane) estimate EPA used in developing cost-benefit analyses for the #methane rule.
Second issue:

#Methane fee provides important backstop to EPA regulations. Operators are exempt from fee if they comply with EPA regs & demonstrate equivalent emissions reductions. EPA is actively soliciting comments how this equivalency will be determined.

More on this later.

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More from @arvindpawan1

Aug 9, 2022
With the US Senate passing the historic #InflationReductionAct, I want to tell a story at the intersection of fossil-fuel infrastructure and climate goals.

It's a story that touches on emissions, globalization, supply chains, energy security, costs, and the labor market.🧵
This story involves the natural gas transmission network & and compressors that move the gas. Here's why it's important:

The Tennessee Gas Pipeline (blue) supplies >80% of gas to North East & New England & represents one of the most critical energy infrastructure for the US.
To maintain pressure & move gas, you need compressor stations every 60 - 70 miles. You can also use these pipelines as storage by adjusting pressure (higher pressure = more volume) - this is called line packing. A typical station can have 1 - 8 compressor units.
Read 12 tweets
Jul 28, 2022
Here are #methane details:

- $850M to EPA for methane monitoring/mitigation
- Fee at $900/t in 2024 going up to $1500/t in 2026.
- EPA methane regs compliant facilities exempt if equivalence can be demonstrated
- EPA required to update inventory estimates in 2 years
Here's the thing:

$900/t CH4 in 2024 is ~$17/mcf of gas, roughly 2x current Henry Hub price. That's a strong incentive for #methane reductions.

$1500/t CH4 is ~$29/mcf. These high prices will incentivize operational changes (e.g., switch gas engines to electric drive motors).
Fees applied to emissions intensities over:
- Production: 0.2% of gas, 10 mt/mbbl of oil
- Transmission: 0.11%
- LNG & other facilities: 0.05%

Only facilities reporting to EPA (>25000 mt CO2e/year emissions) will be subject to #methane fees.
Read 8 tweets
May 23, 2022
🚨New Paper Alert🚨A common justification for LNG expansion is potential for emissions reductions through coal to gas switching in power sector.

Is this claim true? @LydiaYang21, @S_HastingsSimon & I explore.

Short answer: Yes & No. 1/
iopscience.iop.org/article/10.108…
Near-term (<~2035)
LNG expansion aligned with Paris goals since there is more coal than LNG

Long-term (>2040)
a) Not compatible with 1.5/2°C goals: less coal globally to substitute with LNG
b) Compatible with business-as-usual 3°C trajectory as world still has lot of coal 2/
Caveats: Much of the LNG infrastructure is yet to be built.
1) Large-scale CCS can significantly extend utility of LNG infrastructure.
2) Low supply chain #methane leakage (<1%) critical to maximize benefits of LNG.3/
Read 8 tweets
Dec 9, 2021
🚨Preprint Alert🚨IT'S HERE!

For the first time, we use a large-scale controlled study of O&G #methane emissions to answer a basic question: How effective are commonly used Leak Detection & Repair (LDAR) programs?

There's a LOT we learnt here. Thread: 1/ eartharxiv.org/repository/vie…
EPA has proposed regulations to reduce #methane emissions from O&G sector. If global energy sector methane were a country, it would be the third largest emitter behind only China & US.

Key part of these regs are leak detection & repair (LDAR) programs. 2/ washingtonpost.com/climate-enviro…
LDAR program are where O&G operators survey their facilities with IR cameras to find and fix leaks (see NYT article for videos).

But, we didn't really know if these LDAR programs are effective in reducing #methane, beyond anecdotal evidence. Until now! 3/ nytimes.com/interactive/20…
Read 15 tweets
Oct 26, 2021
I'm out here in WY near the Wind River Range to measure #methane emissions. As I write this, EPA is working on releasing updated methane regulations.

Let me tell you why this is not necessarily bad news. A thread on the complexity of #methane accounting: 1/
First, why is #methane fee a great idea? Recent data show that #methane emissions from operators vary by many orders of magnitude. So it makes sense that under a fee, responsible operators will be rewarded and those with high emissions will be penalized.
So, what's the issue with BBB proposal? Fee is entirely based on self-reporting to EPA GHGRP. 2 problems:

1) Emissions are underestimated in EPA report
2) Only facilities >25000 CO2e required to report

This sets up potential for fraud as it's easy to reduce emissions on paper.
Read 9 tweets
Feb 20, 2021
Good summary of what went wrong with the TX grid. I am going to try to explain what happened on the natural gas supply chain.

TL;DR: Combination of extended cold, unique basin properties, old pipes, and gas/electricity dependence. Thread. 1/
bloomberg.com/news/features/…
First, here's the natural gas supply chain. The parts that failed were in 3 areas:

1) oil & gas wells
2) Gathering lines
3) Equipment malfunction at power plants
4) Outage cut power to compressor stations that moved gas

+Other long-term issues like limited storage in TX. 2/
1) Why did O&G wells fail?

Permian basin is a liquids-rich basin. In addition to gas, wells also produce oil & water. For e.g., for every barrel of oil produced, you bring up 2-3 barrels of water.

In extended cold, water freezes and blocks the flow of gas from the well.
Read 9 tweets

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