Federal Oil and Gas Leases: Opportunities Exist to Capture Vented and Flared Natural Gas, Which Would Increase Royalty Payments and Reduce Greenhouse Gases

According to Interior officials, the Bureau of Land Management (BLM) has drafted a proposed rule to reduce wasteful flaring, venting, and leaking of natural gas from oil and gas production on public lands. BLM submitted the draft proposed rule to the White House Office of Information and Regulatory Affairs (OIRA) for review on September 18, 2015. This rule, according to Interior officials, would update the BLM's 30-year-old venting and flaring rules to require common sense and cost effective measures to reduce the waste of gas, recognizing recent technological advances in oil and gas production. According to Interior officials, the rule aims to increase our nation's natural gas supplies, reduce environmental damage from venting and flaring, and ensure a fair return for federal taxpayers, Tribes, and States. In addition, BOEM officials told us that they had completed a reconciliation of Gulfwide Offshore Activities Data System (GOADS) and Oil and Gas Operations Report (OGOR) data in July 2013 by following up with all 86 companies operating platforms in the Gulf of Mexico and inquiring about the differences between GOADS and OGOR data on venting and flaring.

According to Interior officials, the Bureau of Land Management (BLM) has drafted a proposed rule to reduce wasteful flaring, venting, and leaking of natural gas from oil and gas production on public lands. BLM submitted the draft proposed rule to the White House Office of Information and Regulatory Affairs (OIRA) for review on September 18, 2015. This rule, according to Interior officials, would update the BLM's 30-year-old venting and flaring rules to require common sense and cost effective measures to reduce the waste of gas, recognizing recent technological advances in oil and gas production. According to Interior officials, the rule aims to increase our nation's natural gas supplies, reduce environmental damage from venting and flaring, and ensure a fair return for federal taxpayers, Tribes, and States. In addition, officials told us that Bureau of Safety and Environmental Enforcement's (BSEE) Notice to Lessees (NTL) 2012-NO4, which provides updated guidance for requesting approval to flare or vent natural gas and clarification of the discretionary authority of BSEE for approving such requests, has led to a significant reduction in approvals for venting and flaring. Finally, according to officials, this issue was further examined in a September 2015 joint study conducted by BOEM and BSEE that examined the costs and benefits of efforts to further reduce venting and flaring. The study concluded that the data available are insufficient to support definitive conclusions in this area. Although BSEE's infrared camera pilot study focused on detecting fugitive emissions (i.e., leaks) using infrared camera technology, BSEE would have also detected lease use gas emissions if such emissions had been extensive, which they were not. Given the findings and limitations of the available data described in the report and the results of the BSEE infrared camera pilot study, BSEE and BOEM will not extend gas capture requirements to "lease-use" sources of gas at this time. Both bureaus, however, will remain open to further studies in this area as priorities allow.

According to Interior officials, the Bureau of Land Management (BLM) has drafted a proposed rule to reduce wasteful flaring, venting, and leaking of natural gas from oil and gas production on public lands. BLM submitted the draft proposed rule to the White House Office of Information and Regulatory Affairs (OIRA) for review on September 18, 2015. This rule, according to Interior officials, would update the BLM's 30-year-old venting and flaring rules to require common sense and cost effective measures to reduce the waste of gas, recognizing recent technological advances in oil and gas production. According to Interior officials, the rule aims to increase our nation's natural gas supplies, reduce environmental damage from venting and flaring, and ensure a fair return for federal taxpayers, Tribes, and States. Additionally, BSEE and BOEM officials told us they analyzed production facility methane emissions from venting and flaring and the opportunity to reduce greenhouse gas emissions if vented natural gas is flared. BSEE officials explained that the analysis took this focus after recognizing that there are no longer likely to be significant opportunities to eliminate venting or flaring for economic reasons after restrictions on such circumstances were imposed by BSEE's July 2012 Notice to Lessees (NTL 2012-N04). Instead, according to BSEE officials, the primary type of benefit from regulatory requirements reducing offshore methane emissions would be the social benefit of reduced greenhouse gas emissions. Officials stated that a particularly beneficial step could be flaring gas that is currently vented because the products of flaring (C02) have approximately one-twenty-fifth of the greenhouse warming potential. Moreover, according to officials, a secondary benefit would be the Federal royalty and private revenues resulting from selling captured gas instead of emitting it (due to equipment upgrades or other steps to reduce emission losses). However, agency officials concluded that increased revenues are anticipated to be relatively small due to the moderate incremental sales volumes expected with any equipment upgrades and the low wellhead price of natural gas.

Onshore, BLM conducted a study in May 2013 of infrared camera use at two pilot locations, which found limitations in the usefulness of these cameras. Although the study recommended against full implementation of cameras across BLM at that time, BLM officials told us that Onshore Order Number 9 is expected to further address the use of infrared cameras, and BLM is considering a performance-based approach to inspecting leaks. BLM officials set a time frame of fiscal year 2016 to complete this order. Offshore, although there are no formal policies at BSEE on future infrared camera use, BSEE has acquired two additional cameras and is hoping to hire additional staff to expand offshore camera use. A report on the use of infrared cameras offshore is nearing completion. When completed, BSEE officials stated that it will allow them to decide the need and economic justification, if any, for expanding use of the camera program and/or if formal policies should be developed for implementation by BSEE or for industry compliance under future regulatory oversight.

According to Interior officials, the Bureau of Land Management (BLM) has drafted a proposed rule to reduce wasteful flaring, venting, and leaking of natural gas from oil and gas production on public lands. BLM submitted the draft proposed rule to the White House Office of Information and Regulatory Affairs (OIRA) for review on September 18, 2015. This rule, according to Interior officials, would update the BLM's 30-year-old venting and flaring rules to require common sense and cost effective measures to reduce the waste of gas, recognizing recent technological advances in oil and gas production. According to Interior officials, the rule aims to increase our nation's natural gas supplies, reduce environmental damage from venting and flaring, and ensure a fair return for federal taxpayers, Tribes, and States. Additionally, according agency officials, BSEE and BOEM analyzed the available GOADS data to identify opportunities to reduce methane emissions. The available data, according to officials, suggest flaring currently vented methane and replacing high-bleed pneumatic controllers with zero- or low-bleed pneumatic controllers would likely provide the greatest opportunities for meaningful and cost effective emission reductions. While there may be opportunities for additional methane emission reductions, agency officials stated that the estimated volumes are too small and the data insufficient to provide strong evidence of cost beneficial opportunities in any other equipment categories. Agency officials also pointed out that onshore and offshore venting and flaring practices are quite different. Offshore operators in the Gulf of Mexico are required to install natural gas pipelines so there is an outlet for produced associated gas. Due to this Federal offshore requirement, venting and flaring volumes are generally small, except when necessary for equipment repairs or safety reasons.