October 12, 2014 Leave a comment
July 26, 2014 Leave a comment
Notes from Bruce Ferguson
The IG assigns a GWP of 25 (over a 100 year time period) to methane, which is more than the figure of 21, which EPA has used in the past, but still well below the figure of 34 used by the IPCC.
2. Everything in the IG report couched in terms of the 100-year time period; the critical 20-year time period is (once again) ignored by EPA.
Reading the report it’s apparent that converting to the 20-year time period (and using a GWP of 86 instead of 25) would not only provide a sound basis for setting energy policy, but would also trigger regulatory actions. How many more local distribution companies would have to obtain CAA Title V operating permits and/or PSD’s if methane was assigned a GWP potential of 86?
No Local Distribution Companies Have Obtained GHG Permits From EPA
No local distribution companies (LDCs) have obtained GHG permits from the EPA. In general, any facility with potential to emit 100,000 tons per year (tpy) or more of GHG (measured on a CO2e basis) must obtain a CAA Title V operating permit. Additionally, new facilities with the potential to emit 100,000 tpy or more of GHGs (measured on a CO2e basis)—and greater than or equal to the applicable major source threshold (i.e., 100 or 250 tpy, depending on the source category) on a mass basis—must generally obtain a Prevention of Significant Deterioration (PSD) pre-construction permit before it can commence construction.Also, existing facilities that plan to undertake modifications that substantially increase their potential to emit GHG’s may also be required to obtain a PSD permit for GHG emissions before they can make the modifications.15
Fugitive emissions are ignored by EPA.
Thirty-six LDCs reported more than 100,000 tpy of methane emissions to the EPA in 2011.However, none of these companies has obtained a GHG permit. In our view, this is likely due to the fact that methane emissions from distribution pipelines are generally “fugitive” emissions resulting from leaks. Under current EPA policy, fugitive emissions from these facilities are not counted toward the thresholds for determining whether a source is subject to GHG permitting provisions, except for major modifications at sources under PSD requirements per the EPA’s 2013 permitting guidance that cites CAA Section 302(j) and relevant regulatory provisions.16
15 EPA provides a thorough discussion of the various GHG permitting requirements in PSD and Title V Permitting Guidance for Greenhouse Gases (March 2011), at http://www.epa.gov/nsr/ghgdocs/ghgpermittingguidance.pdf.
16 Counting GHG Fugitive Emissions in Permitting Applicability (December 12, 2013); EPA guidance document addressing questions about GHG permitting at http://www.epa.gov/nsr/ghgqa.html.
5. And there’s this:
EPA Has Not Partnered With PHMSA to Control Methane Leaks
Historically, PHMSA has regulated LDCs’ pipeline infrastructure with a public safety focus rather than an environmental protection focus.17 PHMSA’s regulations were not designed to mitigate the environmental impacts of leaks. PHMSA requires LDCs to repair or replace leaking pipelines that:. . . represent an existing or probable hazard to persons or property and requires immediate repair or continuous action until the conditions are no longer hazardous.PHMSA regulations leave the repair of non-hazardous leaks to the discretion of the LDC.
According to the Executive Director of BlueGreen Alliance,18 when LDCs discover a leak, they may vent the leak to the atmosphere instead of repairing it if the leak is not a safety hazard. An LDC may also vent a hazardous leak to reduce the safety threat of the leak, thus reducing its explosive potential and downgrading its hazard rating. If a state does not adopt initiatives to enforce the repair of persistent, non-hazardous leaks, the LDC can potentially allow a non-hazardous leak to vent to the atmosphere in perpetuity.
The EPA has not partnered with PHMSA to address leaks from a combined safety and environmental standpoint. EPA staff told us that they do not have a formal partnership with PHMSA, and PHMSA last participated in an EPA Natural Gas STAR workshop in 2009. The lack of coordinated action between the EPA and PHMSA hinders an effective partnership where PHMSA’s technology and regulations could be used to produce additional environmental benefits. The EPA has the opportunity to partner with PHMSA in implementing the 2014 interagency methane strategy.
Gulf Stream: Williams Suspends Bluegrass Gas Export Pipeline, Announces New Export Line | NationofChange
May 3, 2014 Leave a comment
In short, New York—a state geographically distant from Louisiana, Gulf Trace and Sabine Pass LNG—is directly connected to Williams’ latest export pipeline announcement both via its lobbyists and Williams’ gas pipeline empire.
Ohio Updates Best Management Practices for Pipeline Installation and Soil Health – News from the Ohio Department of Natural Resources
December 23, 2013 Leave a comment
Link to standards in text
December 18, 2013 Leave a comment
Plan to connect Millennium pipeline to Dominion pipeline in Cortlandville.
Statement of Joseph Heath, Esq. on Millennium’s tactics: Message from Joe Heath 12-20-13
MILLENNIUM PIPELINE COMPANY PROVES WE CAN’T TRUST
ANYTHING THEY SAY:
On Monday, December 16th, a senior Millennium vice president
e-mailed me and said “Unfortunately, the markets (sic) participation
did not materialize in a sufficient quantity to justify pursuit of the
project at this time.”
However, by Wednesday, December 18th, the Millennium media
spokesman changed that position and told the newspapers “Based
on that initial response there was not sufficient demand to move
forward with the development all the way to Syracuse, so we are still
evaluating the southern part of that line.”
Their plan now appears to be consideration of constructing of a
large, high pressure pipeline from the Millennium east/west pipeline
in Broome County to connect with the Dominion pipeline in the middle
of Cortland County.
So, if we can’t trust their senior vp in charge of the project, how
can we trust their landmen when they come to our doors?
Rest assured that the Stop the I-81 Pipeline resistance group
will continue our work of educating landowners and our communities,
and that we will double down our efforts until everyone is protected.
Our research shows that building a 30 mile pipeline to connect
the Millennium to the Dominion makes no sense, because these
pipelines already cross near Horseheads, in Chemung County. On
September 9, 2013, the pro-fracking Marcellus Drilling News, ran an
article which stated:
The story of the northeast: Too much Marcellus
Shale natural gas, not enough pipelines to move it all
to market. More pipelines are on the way like the
Constitution, but in the meantime, how to move the
enormous amount of gas already flowing? 1
On Friday, the Millennium Pipeline, a major
transmission pipeline that transverses New York
State . . . announced a binding open season through
September 13 on a proposal to ship more Marcellus
gas by creating an interconnect between Dominion
Transmission’s pipeline and the Millennium at or near
We will need to continue to research how a corporation can
attempt to justify to FERC, or its shareholders, the much more costly
and disruptive 30 mile pipeline, rather than the interconnect in
Horseheads where the two lines already cross.
Unfortunately, the residents and landowners of our
communities cannot get reliable information from this corporation,
and so, we will continue our work, and our research which we will
share with our neighbors.
Landowners will never stop defending their property against
eminent domain by private corporations that seek to build
dangerous, redundant and unnecessary fracked gas infrastructure
across the landscape, bringing ruin to farms, destroying property
values, menacing air quality and drinking water. Millennium should
expect and will receive stiff, well-organized and well-researched
citizen resistance at every step.
December 20, 2013
1 Here, the industry is openly admitting what we have known and said repeatedly: these
pipelines are only about moving fracked gas to increase corporate profits.
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December 8, 2013 Leave a comment