Download Oral Testimony on the Proposed Power Plant Rule by Bruce

ORAL TESTIMONY ON THE PROPOSED POWER PLANT RULE
BY BRUCE FERGUSON OF CATSKILL CITIZENS FOR SAFE ENERGY
http://www.catskillcitizens.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 al 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.
doi: 10.1007/s10584-011-0061-5
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.
do10.1007/s10584-012-0401-0
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
http://www.eeb.cornell.edu/howarth/Howarth%20et%20al.%20–%20National%20
Climate%20Assessment.pdf (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
http://www.postcarbon.org/reports/PCI-Hughes-NETL-Cornell-Comparison.pdf
Howarth, R. W., and A. Ingraffea. 2011. Should fracking stop? Yes, it is too high risk.
Nature 477:271–273.