Climate Change

EPA Proposes Eliminating Methane Capture Regulations

This week the EPA proposed new rules that would reverse regulations adopted by the Obama administration requiring the natural gas industry to prevent fugitive methane gas releases. The existing rules were adopted during the previous administration as a measure to slow the emission of greenhouse gases causing climate change.

Under the proposal released this week the EPA would no longer specifically regulate the transmission and storage of the potent greenhouse gas… but treat it like a routine volatile organic compound. 

The rules proposed this week would eliminate the current requirements that require the industry to prevent methane releases at transmission and storage of methane at compressor stations, pneumatic controllers, and underground storage vessels (basically- the transmission and storage segment of the industry).  The proposed regulations would also eliminate methane emission limits from the transmission and storage segment of the industry. 

Methane (CH4) is a very powerful greenhouse gas. It absorbs much more energy than carbon dioxide (CO2) and is 30 times more potent as a greenhouse gas.  Methane has a half-life in the atmosphere of about 10 years (much less than CO2) but has a powerful impact during that time.

The U.S. oil and gas industry emits 13 million metric tons of methane from its operations each year (emissions of methane are about 2.3% of the production).  Most of these “fugitive” emissions came from leaks and equipment malfunctions in the transmission and storage of the gas- the very sector that the proposed rules deregulate. 

The climate impact of these leaks is roughly the same as the climate impact of carbon dioxide emissions from all U.S. coal-fired power plants.  [R.A. Alvarez el al., "Assessment of methane from US oil and gas supply chain”, Science (2018).]

In their comments this week - EPA officials stated that the industry has a powerful incentive to stop fugitive emissions of methane without regulation because they lose product via leaks. That argument only holds when the cost of fixing the leak is less expensive than the short-term cost of lost product.

Here’s a link to EPA’s proposed rules.  Public comment isn’t open because it’s not published in the Federal Register yet.  Once it’s published, there will be a 60-day comment period.  I’ll keep following this and put the link to the comment site in a future public health policy update.  The comments page - when available - will be at

Editorial Note: In addition to the public health impacts from climate change caused by the obvious things like worse storms, water shortages, decreased agricultural output, impacts to assets from sea level rise (oceans are already 20cm higher then they were in WWII), and the geopolitical implications that these disruptions will cause from increased  conflicts, refugee crises and widespread social dislocation would almost certainly increase - climate change also causes a diversion of resources toward adaptation, diverting public and private resources from more efficient uses of capital.

This results in long-term decreased GDP growth and investment and capital losses. For example, the expected value of a future with 6°C of warming represents present value losses worth US$43trn—30% of the entire stock of manageable assets (the current market capitalization of all the world’s stock markets is around US$70trn).

The reason I mention this - is that as public health officials - we often focus on those direct public health impacts that are resulting and will continue to result from climate change. Convincing decision makers that aren't partucularly interested in public health that the the climate crisis is serious and requires immediate aggressive interventions requires a variety of arguments. Here is an interesting, if dense, analyis recently published by The Economist.

Here's Why We Endorse the Clean Energy for a Healthy Arizona Initiative

The AzPHA Board of Directors has endorsed Proposition 127- the Clean Energy for a Healthy Arizona ballot initiative. Proposition 127 would increase the state's renewable portfolio standard (RPS) which is a mandate that electric utilities acquire a minimum amount of electricity from renewable energy sources. Here's the actual  Proposition 127 Ballot Language

As of 2018, Arizona's renewable portfolio standard (RPS) is 15% renewable by 2025. Proposition 127 would increase our RPS each year until reaching 50% in 2030.

The Initiative defines renewable energy as electricity generated by  solar, wind, certain hydropower, geothermal, and landfill gas energy.  The definition of renewable energy under the initiative doesn’t include nuclear power. For our state, most of the new renewable energy that would be created would probably mostly be solar.

APS reports it currently generates about 12% of its energy from renewable sources which includes utility-owned plants and power being generated by customers through rooftop solar.  Tucson Electric Power reports 13%. Right now, Arizona gets 6% of its electricity from solar power.

It’s no secret that Arizona Public Service (APS) doesn’t want Proposition 127 to pass.  Their current strategic plan  is to mostly meet future electricity needs by building new gas-fired power plants.  You can see the resource plan APS filed at the Arizona Corporation Commission in 2017 and APS’ recent RFP for new power plants to get an idea about their current strategic plan.

This is an over-simplification- but the public policy question posed by Prop 127 is whether it’s in the public’s best interest to meet future generation demand with mostly natural gas plants or solar.

There are compelling health reasons why Proposition 127 makes sense from a public health perspective. Burning fossil fuel, including natural gas, creates air emissions (oxides of Nitrogen and volatile organic compounds) that form ozone. Ozone adversely affects human health by increasing cardiovascular and respiratory disease.  It can decrease lung function and causes more people to visit emergency rooms or even be admitted to the hospital because of asthma or allergy related illnesses. Some studies have even linked preterm birth to air pollution.

But, if it turns out that the health benefits from cleaner air come at the cost of higher electricity prices- then the health gains from the improvement in air quality would need to be weighed against the public health costs to low income folks who already struggle to pay their electric bills- worsening the social determinants of health for low income people.

Before we took a position on Proposition 127, I and our Board carefully examined what impact the initiative might have on future electricity prices.  After all, income is a primary driver of health status, and if the Initiative were to increase electricity prices more rapidly than under the current RPS standard, then it could end up having a net negative impact on public health among low income Arizonans.  That’s why we carefully examined the cost issue before taking a position.

One of the best and most objective sources of information about the relative costs of generating electricity I found is the US Energy Information Administration’s 2018 report entitled  ”Levelized Cost and Levelized Avoided Cost of New Generation Resources in the Annual Energy Outlook 2018”.   The report examines capital, operational and transmission costs as well as off sets from the tax credits.  It takes a little time to read but worth the effort.

The bottom line is that solar energy generated using photovoltaic cells is on par or slightly cheaper than energy generated with natural gas.  Solar plants have a higher capital cost but lower variable (operational cost) because they don’t need fuel (free photons are the fuel).  Solar also benefits from tax credits- which is part of the cost equation.

One of the reasons why solar power is now slightly cheaper than natural gas energy is that the cost of solar panels has decreased rapidly in recent years (in part because of increased global solar panel manufacturing capacity in China).  The cost of utility-scale solar has fallen 77% since 2009.  The cost of battery storage fell 79% between 2010 and 2017.  Another reason why solar costs less in the long run is because of the federal tax credits that are available to utilities that use solar to generate electricity.

Prop 127 also requires 20% of renewable energy eventually be “decentralized” - basically roof-top solar.  That means incentives will be created to encourage solar installation. Done thoughtfully, that could provide an opportunity to prioritize installation of panels on homes in lower income areas, relieving pressure on monthly budgets of families who most need that relief while increasing the value of their property.

The bottom line is that after reviewing as many objective facts as we could find, we concluded that Proposition 127 provides net health and environmental benefits.  That's why we’re supporting Proposition 127.

EPA Proposing Fuel Efficiency Standard Rollback

The EPA & National Highway Traffic Safety Administration are proposing a roll back of the existing vehicle fleet fuel efficiency standards, which require automakers to gradually increase the average fuel efficiency of their new fleets.  

Under the existing regulations, new cars, trucks, and SUVs fleets will need to average about 50 miles per gallon by 2025. The new EPA & NTHSA proposed rule will stop the progression of standards in 2021.  Rather that requiring a fleet average of 50 mpg by 2025, the new standard will stop at 38 mpg.  Last year, the average fleet fuel efficiency was about 25 mpg.  The current average fuel efficiency of all vehicles on the road is about 21 mpg.

Fuel efficiency standards are an important driver that pushes vehicle manufacturers to discover new ways of improving fuel efficiency and are an important strategy toward reducing greenhouse gas emissions.  The transportation sector is the largest contributor to atmospheric CO2 emissions.

You can submit comments directly to the EPA and NTHSA at this web portal (it’s Docket EPA-HQ-OAR-2018-0283).  The deadline to comment is October 23, 2018. There are only 138 comments in the system so far.  I have this on my to-do list.  Hopefully some of our members will weigh in as well

EPA Proposing Looser Methane Leak Regulations

The USEPA has proposed a new rule that will relax the regulation of methane emissions at oil and gas facilities.  Methane is a very powerful greenhouse gas.  A mole of CH4 emitted today lasts about 10 years  in the atmosphere on average, which is much less time than CO2.  But, because CH4 absorbs much more energy than CO2 (CH4 is 30 times more potent as a greenhouse gas than CO2) it has an outsize impact on climate change (but for a shorter time period).  

The plan announced today by EPA will roll back key provisions of the current methane regulations.  The new proposal reduces the frequency of emissions monitoring at oil and natural gas wells from twice a year to once a year or even every other year.  Facilities that compress gas for transport through pipelines will have their monitoring frequencies cut in half from 4 times a year to just twice.  It will also extend the time that companies will have to repair leaks of this potent greenhouse gas from 30 days to 60 days.  Here's the proposal summary:

At least it won’t let companies completely off the hook, but then that’s looking through rose-colored glasses I guess.

This new rollback hasn’t been published in the UA Administrative Register yet, and comments are not yet open.  The 60-day comment period will begin once it’s published in the Register.  The Docket ID number will be EPA-HQ-OAR-2017-0483 with comments at