EPA’s Costly, Unnecessary Soot Proposal

EPA continues to act tone deaf to the real-world needs of U.S. businesses and regular Americans. Its particle standards proposal issued this week is a good example of the kind of investment-squelching overregulation that ultimately could hurt the country’s energy future.

With the country’s air continuing to improve under the existing fine-particle soot standard, EPA proposed tightening it. The rule is scheduled to be finalized in December. Howard Feldman, API’s directory of regulatory and scientific affairs, says the rule’s benefits aren’t worth its costs:

“Air quality will continue to improve dramatically under the current government standards, but EPA’s proposal could substantially increase costs to states, municipalities, businesses and ultimately consumers without justified benefits. We are concerned that it could come at a significant economic cost and lost investments and limit our ability to produce the energy our nation needs.”

Between 2000 and 2010 concentrations of fine-particle soot fell by 27 percent, according to EPA. Feldman says three-fourths of Americans today live in areas where air quality meets today’s standards, and that the trend will continue – which suggests the new standard is unnecessary.

Feldman also says EPA based its proposal on “faulty scientific analysis,” that important data have been ignored and some of its purported findings are actually misinterpretations. How tightly the standards are set is a policy judgment. Because there is no bright line to guide the standard setting, the impacts of the standards matter. Feldman:

“A more stringent rule will discourage economic investment in counties that fail to meet new federal standards.  It’s in our interest to have both clean air and a vibrant domestic economy. However, the new standards would put many regions out of attainment, and companies considering a place to build a plant or refinery could perceive non-attainment as non-investment.”

Again, in the context of an economy trying to regain its footing, EPA is tossing out banana peels – with potential costs on a number of fronts that ultimately will hit real people. This economic anti-stimulus also is an unnecessary energy impediment.

It illustrates why, if we’re serious about a secure energy future, a common-sense regulatory structure is needed. By that we mean a regulatory process that’s open to all and based on sound science and legitimate cost-benefit analysis. By that standard EPA’s proposal falls well short.

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Graphically Speaking: Fracking and Injection Wells

Last week’s National Research Council report on hydraulic fracturing and earthquakes pretty much ends up where a number of scientists are on the correlation between fracking and quakes: that energy development from shale formations poses a low risk for tremors of significance. The report said more attention should be given to injection wells, which are used for waste disposal by a number of industrial enterprises, not just the oil and natural gas industry. AP science writer Seth Borenstein’s take on the report is here.

API, America’s Natural Gas Alliance and the American Exploration & Production Council have produced a couple of informational tools on hydraulic fracturing and seismic activity and underground injection control (UIC) wells that are especially timely with release of the council’s report. 

Highlights from the fracking document:

Hydraulic fracturing is done with a mixture of more than 99.5 percent water and sand. The other one-half of 1 percent is chemical – including anti-bacterials and lubricants. See the FracFocus.org site for more on fracking fluids.Fracturing that occurs thousands of feet below the surface (and below groundwater aquifers) is carefully mapped with sophisticated equipment to optimize recovery of the oil and/or natural gas and to monitor the well itself. In other words, microseismic activity associated with fracking is thoroughly understood.

One study of several thousand shale fracture treatments across North America showed the largest micro-quake measured about 0.8 or about 2,000 times less energy than a magnitude 3.0 earthquake. The chart below shows that most of the micro-quakes in this study were 10,000 to 1 million times smaller than a 3.0 earthquake, which is roughly equivalent to the passing of a nearby truck:

Highlights from the UIC document:

The U.S. has about 151,000 Class II UIC wells used by the oil and natural gas industry, of which only a handful are being studied for possible links to earthquakes. These wells are a subset of more than 800,000 injection wells nationwide used to dispose of a variety of industrial wastes and for development of various minerals and geothermal energy sources. Here’s a map that shows the state-by-state well distribution:

Injection wells are regulated by EPA under the Safe Drinking Water Act. In many cases EPA has delegated authority for the UIC program to the states, with 39 states having primary authority over 95 percent of all UIC Class II wells.Literature published in the past five years shows that less than 40 incidents of seismic activity felt on the surface were associated with Class II injection wells.

Injection wells pump fluids into deep rock formations (see graphic). It’s unusual, but in some cases a quake can occur when a number of geological and operational factors come together – especially the presence of hard, dense and brittle crystalline “basement rock.”  These quakes are almost always small, below the level that would be felt on the surface.

For more information, check out the Energy From Shale website.

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