Downstream Natural Gas Initiative: EPA s Methane Challenge Program

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Downstream Natural Gas Initiative: EPA s Methane Challenge Program CH 4 C O N N E C T I O N S O C T O B E R 6, 2 0 1 5 Brian Jones 978-405-1269 bjones@mjbradley.com

Downstream Natural Gas Initiative A coalition of natural gas utility companies dedicated to promote outstanding operations to manage and substantially reduce methane emissions within natural gas distribution systems. Our members deliver natural gas to more than 17.5 million customers accounting for 15 percent of the total natural gas deliveries in the U.S. Natural Gas Service Nearly 184,000 miles of natural gas distribution mains throughout the U.S. 2

DSI Focus Areas Regulatory: promote effective repair and replacement programs, mechanisms for cost recovery and mitigating rate impacts, and means for measuring progress State of the Art Technology: assess opportunities and barriers for adopting state-of the art leak detection technologies and innovative repair and replacement technologies Emissions Quantification: leverage new data available from cutting edge research efforts and evaluate opportunities for improving quantification of emissions and emissions reduction activities 3

LDCs Role in Reducing Methane Emissions Local Distribution Companies are Emission Reductions Infrastructure Modernization Operational Emissions Research and Development reducing methane emissions from their own operations, enabling reductions from other sectors (i.e., renewable natural gas) and aiding customers to reduce emissions (fuel switching and energy efficiency) working with state PUCs to accelerate infrastructure modernization and replacement programs to improve safety and also reduce methane emissions investigating operational methane emissions associated with maintenance, main replacement, hydro testing, etc. conducting research on methane leak detection and quantification to improve understanding of methane emissions from infrastructure, prioritize repair, and improve GHG inventories 4

Benefits of the Methane Challenge Program to LDCs Encourage LDCs to manage and reduce methane emissions from infrastructure and operations Transparent annual public reporting and recognition of emission reduction achievements Increase visibility of operational excellence and methane emission reductions with PUCs, regulators, consumer advocates, customers, and environmental organizations Encourage regulatory structures that facilitate increased action to reduce methane emissions from LDC operations Improve methane emissions accounting and inform GHGRP and GHG Inventory 5

Transparency and Reporting In addition to GHGRP Subpart W Reporting, EPA is also proposing that Methane Challenge Partners will be required to report Supplemental Data for some sources Methane Challenge Partner reported emissions and reductions: + = GHGRP Subpart W Reporting Supplemental Data Reporting Methane Emission Reductions Above and below ground M&R stations Mains and services Lining and inserts for mains and services High pressure blowdowns (number of events, amount of gas released (pipe diameter x pressure x length), strategies to reduce methane emissions) Excavation Damages (number of locate calls, number of damages, time to shut in, amount of gas released, strategies to improve damage rate and shut in time Subpart W and Supplemental Data reporting will need to be merged to provide complete methane emissions and emissions reduction picture for Partners 6

National GHG Inventory Considerations Potential National GHG Inventory Updates for LDCs include: 1 2 3 Meter and Regulating Stations Mains and Services Liners and Inserts Activity Data and Emission Factors Use GHGRP data for M&R station activity counts rather than throughput based formula Update emission factors for M&R stations using data from WSU and GHGRP Emission Factors and Quantification Methodology Update emissions factors for pipelines using data from the WSU and GRI studies Change activity data for pipelines from leaks/mile to total leaks for each pipe material to more accurately account for pipeline replacement programs Develop Emission Factors Develop separate emissions factors for pipelines with liners and inserts 7

Concord, MA Washington, DC Headquarters 47 Junction Square Drive Concord, Massachusetts United States Tel: 978 369 5533 1225 Eye Street, NW, Suite 200 Washington, DC United States Tel: 202 525 5770 Fax: 978 369 7712 www.mjbradley.com 8

2013 Natural Gas Distribution Local Distribution Companies Methane Emissions by Source GHGRP Emission Source CH 4 Emissions (MT CO 2 e) % change from 2012 Mains 9,087,586 +12.0% Mains 61% Services 30% Other 7% Below Ground Metering <0.5% Above Ground Transfer Station 2% Services 4,397,392 +8.9% Below Ground Metering Above Ground Transfer Station Below Ground Transfer Station 30,650-71.8% 221,835 +9.3% 4,432-50.3% Below Ground Transfer Station <0.05% Other 1,044,304-63.9% Total 14,786,198-3.8% Analysis Notes: 1. LDC Other is defined as the remaining percentage from the difference between total LDC emissions reported, and the sum of each reported emissions source (Mains, Services, Metering, Transfer Station). 2. Combustion and Other Equipment Leaks combined account for <0.07% of Natural Gas Distribution. 9