Originally published by Charles Sartain.
Gas flaring, especially in the Permian and the Eagle Ford, is coming in hot these days at the Texas Railroad Commission. Presented here are viewpoints from several stakeholders in the discussion. My comments are summaries. For a fuller understanding please read the reports for yourself.
The players are in general agreement on several points:
- There needs to be an end to routine gas flaring.
- Texas flares a lot of gas: About as much annually as all of its residential users combined, or maybe as much as the seven largest cities, or maybe Houston. It depends on who’s talking. Values vary but in the Permian it ranges from $450 Million to $750 Million.
- Progress is being made, plenty for some, not enough for others.
The Texas Methane and Flaring Coalition
These seven trade associations and 40 operators are members of the Railroad Commission’s Blue Ribbon Task Force for Oil Economic Recovery. Their positon, among others:
- More detailed data submissions from operators will result in more effective operational and regulatory decisions that will reduce flaring.
- A proposed flaring matrix (see the report) identifies situations where flaring is necessary and makes recommendations for the application of Rule 32 that will result in overall flaring reductions because of the shortened time frame for administrative approvals.
- Methane emissions from oil and gas systems are down 23 percent since 1990.
- Texas flaring intensity is well below that of comparable countries according to the World Bank.
It is worth noticing that during the RRC’s recent prorationing discussions a substantial number of industry players advocated for curtailment of flaring.
Statewide Rule 32 is the mechanism by which the RRC regulates flaring. For its part, the RRC is heeding recommendations of the task force.
- A revised and significantly more robust Exception Data Sheet is in the public comment process requiring operators to more thoroughly document the circumstances surrounding the need to flare; providing accurate information to assess compliance; and encouraging transparency in understanding the broader reasons for flaring and/or venting.
- New processes should result in substantial reduction in flaring periods.
The Environmental Defense Fund
- There are problems. Across the Permian, one out of every 10 flares surveyed in June 2019 were either unlit, venting or combusting methane straight into the atmosphere, or only partially burning the gas they were releasing.
- Flaring is on the rebound after a steep slide from February through May 2019.
- Three separate surveys show no improvement in flare performance over time.
- The industry and regulators need to get much more serious about the problem.
- They encourage investors to ask tough guestions of operators.
- Several investment firms are pressuring operators to eliminate all flaring by 2025.
- The Commission’s proposed rules require operators to provide more information but set no targets, and the Commission has resisted calls for an outright ban.
Technology
- As one would expect from a dynamic industry, technological advances will curb flaring. For example, portable LNG plants are being deployed in West Texas. One such technology is Cryobox (see the photo above), by Galileo Technologies.
The Candidates
This is election season, and the RRC candidates have their viewpoints:
- Straight from the web site of Democrat Chrysta Castaneda. Her position is pretty close to the industry’s.
- Straight from the web site of Republican Jim Wright. Not a lot there.
The Professor
Gunnar Schade, atmospheric scientist at Texas A&M, observes in a paper entitled The Problem with Natural Gas Flaring:
- The US is one of the world’s top five flaring nations, just behind Russia, Iran, and Iraq.
- Gas flaring contributes 1%+/- of man-made atmospheric CO2 emissions globally.
- Flaring can be the dominant source of nitrogen oxides in rural areas where flaring occurs.
A musical interlude: Barbara Lynn, competing in the ’60’s black left-handed women guitar player/singer category (not to be confused with Her Honor of the U. S. Northern District).
Curated by Texas Bar Today. Follow us on Twitter @texasbartoday.
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