It’s big news when one of the world’s largest oil and gas companies announces it supports hard and fast regulations to reduce its industry’s methane emissions. And it deserves to be, since methane pollution is supercharging the climate crisis and enforceable, comprehensive regulations are the only proven way to make a significant dent in this problem.
However, go a level deeper on the Model Regulatory Framework Exxon unveiled this week and it quickly becomes clear that the specific strategies it proposes lack the ambition needed to dramatically reduce oil and gas methane emissions industrywide. Far from a nationally leading set of proposals, if implemented, they would actually be weaker than the methane standards currently in place in several leading states as well as the Environmental Protection Agency’s current requirements.
Leading on leak detection and repair
For example, Exxon proposes that regulators implement leak detection and repair programs that would include periodic inspections “at least once per year”. Meanwhile, leading states like Colorado, California and Wyoming have put rules in place that require quarterly inspections on many sources, and the current EPA rules require twice yearly inspections on all new and modified wells.
Annual LDAR is not a serious proposal and should not be emulated by regulators looking to craft rules to reduce emissions. Frequent LDAR inspections are critically important given that the latest science shows they are one of the best ways to dramatically reduce methane emissions while being extremely cost effective.
Ensuring haste doesn’t make waste
Annual LDAR is just one example of the shortcomings in the Exxon framework. Flaring is another, which is an especially glaring problem in the Permian Basin of West Texas and southeast New Mexico, now the world’s largest oil field.
While some producers there have made moves to limit flaring by sensibly timing drilling to ensure natural gas infrastructure is in place, Exxon has not, and their framework doesn’t include the necessary tools to tackle this growing problem.
Regulators should take a holistic approach to reducing methane emissions as well as natural gas waste through flaring by including strong anti-flaring measures as part and parcel of their methane regulations.
Raising ambition to achieve what’s possible and necessary
Overall, Exxon estimates that implementing its suggestions have allowed the company to reduce its methane emissions by 20%. That’s good, but it falls far short of the greenhouse gas reductions that scientists say we need to maintain a stable climate or that leading states have committed to as a part of the Paris Agreement.
To give one example, New Mexico under Gov. Michelle Lujan Grisham has quickly begun a race to the top on tackling climate change and methane emissions. The state set an aggressive goal of a 45% reduction in overall greenhouse gas emissions by 2030, charting a course toward creating comprehensive, statewide methane rules this year. A recent analysis has shown that by implementing a suite of nationally leading requirements, New Mexico can reduce its methane emissions by 60%. In this context, Exxon’s 20% cut just doesn’t cut it.
A growing group of companies have committed, in theory, to achieving a methane intensity of 0.20%, but more importantly none is demonstrating compliance with that target through high quality empirical data and robust disclosure. This is critical for companies like Exxon trying to inspire confidence in their methane management and defend their position in a rapidly decarbonizing world.
Overall, in an era of federal methane rollbacks, Exxon deserves credit for advocating for enforceable rules to reduce methane emissions. Exxon and other leading producers should be recognized for doing work to advance innovative solutions for methane monitoring and mitigation, particularly when they demonstrate innovations at scale. Regulations should take advantage of these current and future innovations.
However, state leaders and policymakers will need to dig deeper than Exxon’s current framework in order to craft the sorts of rules necessary to garner the best, most cost-effective methane emissions reductions possible.