NOTE: these comments were submitted before the EPA public hearing on hydraulic fracturing air pollution regulation in Denver on September 28th
My name is Bruce Baizel. I am Staff Attorney for Earthworks, a nonprofit organization that works with communities to reduce the impacts from mining and energy extraction. Our organization has worked on oil and gas issues for more than two decades and specifically on the issue of hydraulic fracturing for more than a decade.
I appreciate the opportunity to provide oral comment to you this morning. We have thousands of members throughout the Rocky Mountain states, in Texas and in the Marcellus shale region.
Many of our members are impacted by the currently unregulated emissions from oil and gas operations throughout those states.
So this proposed regulation providing a new source performance standard for Volatile Organic Compounds; a new source performance standard for sulfur dioxide; an air toxics standard for oil and natural gas production; and an air toxics standard for natural gas transmission and storage is of great importance to our members.
Overall, we strongly support the draft rule as a significant first step in addressing emissions from upstream oil and gas operations.
Now, as the issues of shale gas and hydraulic fracturing have focused attention on this sector, significant questions have emerged about the practicality and desirability of using natural gas as a bridge fuel.
One of the most interesting of the recent analyses of these questions is a report by David Hughes. He suggests that a convergence of interests between the natural gas industry looking to hype a new production prospect with investors, the energy policy establishment looking for a new energy source to support future economic growth and large environmental interests looking for a simple way to lower carbon emissions gave rise to the natural gas as bridge fuel mantra.
The most interesting part of his report is a close look at the production numbers for natural gas and an assessment of whether it is even possible for natural gas to serve as a bridge fuel. His bottom line: that the bridge fuel concept for natural gas represents wishful thinking and is not possible to achieve.