Department of Commerce, Community, and Economic Development
Alaska Oil and Gas Conservation Commission
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HomeMy WebLinkAboutO 1471. November 5, 2018
2. November 9, 2018
3. December 17, 2018
4. December 18, 2018
5. January 18, 2019
Other Order 147
Kate Troll petition for hearing regarding the prevention of
all non -emergency venting and flaring.
Notice of public hearing, email and mailing list
Written comments and testimony
Hearing transcript and sign -in sheet
Statement of Commissioner Hollis French
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West 71h Avenue
Anchorage, Alaska 99501
Re: THE PETITION OF KATE TROLL ) Other Order 147
regarding the prevention of all non- ) Docket Number: OTH-18-057
emergency venting and flaring. )
January 18, 2019
IT APPEARING THAT:
1. Kate Troll submitted a petition to the Alaska Oil and Gas Conservation Commission (AOGCC)
that was received on October 2, 2018. The petition, signed by 46 people, asked the AOGCC
to "prevent all non -emergency venting and flaring from Alaska oil and gas wells."
2. On November 8, 2018, Ms. Troll requested a hearing on her petition, citing AS 31.05.060. The
AOGCC scheduled a hearing for December 18, 2018.
3. At the hearing, Ms. Troll submitted another petition, dated December 18, 2018, with the names
of nearly 300 individuals attached to it, urging the AOGCC to "fully enforce and strengthen
existing statutes requiring Alaska's oil and gas industry to stop all non -emergency venting and
flaring from Alaska oil and gas wells."
4. Ms. Troll and other witnesses asked a series of questions regarding the AOGCC's practices
relating to enforcing its statutes and regulations pertaining to venting and flaring. All witnesses
were open about their root concern, the reason the hearing was requested, which is climate
change. They acknowledged, and the AOGCC reiterated at the hearing, that while the AOGCC
regulates to prevent waste, it has no authority to act regarding that subject matter.
FINDINGS:
1. No specific example or claim of waste was raised during the hearing.
2. Both the testimony and the questions raised during the hearing appeared to stem from a general
lack of familiarity with how the AOGCC addresses issues related to venting and flaring.
3. The appropriate way to obtain from AOGCC information regarding venting and flaring is
through meeting with AOGCC's technical staff. Should any of the participants in the hearing
so desire, AOGCC staff is willing to meet to answer their questions.
CONCLUSION
No action is required of the AOGCC as a re ult of the he ing.
Cathy/P. Foerster/ Daniel T. Seamount, Jr.
Commissioner Commissioner
Other Order 147
January 17, 2019
Page 2 of 2
RECONSIDERATION AND APPEAL NOTICE
As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the
AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter
determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the
respect in which the order or decision is believed to be erroneous.
The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act
on it within 10 -days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the
denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date
on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS
the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for
reconsideration was filed.
If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on
reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be
filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision
on reconsideration.
In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in
the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period mns until 5:00
p.m. on the next day that does not fall on a weekend or state holiday.
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
333 West 7t1 Avenue
Anchorage, Alaska 99501
Re: THE PETITION OF KATE TROLL ) Other Order 147
regarding the prevention of all non- ) Docket Number: OTH-18-057
emergency venting and flaring. )
) January 18, 2019
IT APPEARING THAT:
1. Kate Troll submitted a petition to the Alaska Oil and Gas Conservation Commission (AOGCC)
that was received on October 2, 2018. The petition, signed by 46 people, asked the AOGCC
to "prevent all non -emergency venting and flaring from Alaska oil and gas wells."
2. On November 8, 2018, Ms. Troll requested a hearing on her petition, citing AS 31.05.060. The
AOGCC scheduled a hearing for December 18, 2018.
3. At the hearing, Ms. Troll submitted another petition, dated December 18, 2018, with the names
of nearly 300 individuals attached to it, urging the AOGCC to "fully enforce and strengthen
existing statutes requiring Alaska's oil and gas industry to stop all non -emergency venting and
flaring from Alaska oil and gas wells."
4. Ms. Troll and other witnesses asked a series of questions regarding the AOGCC's practices
relating to enforcing its statutes and regulations pertaining to venting and flaring. All witnesses
were open about their root concern, the reason the hearing was requested, which is climate
change. They acknowledged, and the AOGCC reiterated at the hearing, that while the AOGCC
regulates to prevent waste, it has no authority to act regarding that subject matter.
FINDINGS:
1. No specific example or claim of waste was raised during the hearing.
2. Both the testimony and the questions raised during the hearing appeared to stem from a general
lack of familiarity with how the AOGCC addresses issues related to venting and flaring.
3. The appropriate way to obtain from AOGCC information regarding venting and flaring is
through meeting with AOGCC's technical staff. Should any of the participants in the hearing
so desire, AOGCC staff is willing to meet to answer their questions.
CONCLUSION
No action is required of the AOGCC as a result of the hearing.
//signature on file// //signature on file//
Cathy P. Foerster Daniel T. Seamount, Jr.
Commissioner Commissioner
Other Order 147
January 17, 2019
Page 2 of 2
AND APPEAL NOTICE
As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the
AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter
determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the
respect in which the order or decision is believed to be erroneous.
The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is tiled. Failure to act
on it within 10 -days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the
denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date
on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS
the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for
reconsideration was filed.
If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on
reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be
filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision
on reconsideration.
In computing a period of time above, the date of the event or default after which the designated period begins to ran is not included in
the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00
Carlisle, Samantha J (DOA)
From: Carlisle, Samantha J (DOA)
Sent: Friday, January 18, 2019 8:48 AM
To: 'AOGCC_Public_Notices@list.state.ak.us'
Subject: Other Order 147
Attachments: otherl47.pdf
THE PETITION OF KATE TROLL regarding the prevention of all non -emergency venting and flaring.
Samantha Carlisle
Executive Secretary III
Alaska Oil and Gas Conservation Commission
333 West 7t1, Avenue
Anchorage, AK 99501
(907) 793-1223
CONFIDENTIALITY NOTICE., This e. -snail message, inchiding any attachments, contains information from the Alaska Oil and Gas
Conservation Commission (AOGCC). State of Alaska and is for the sole use of the intended recipicnt(s). It may contain confidential and/or
privileged information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an
unintended recipient of this a -mail, please delete it, without first saving or forwarding it, and, so that. the AOGCC is aware of the mistake
in sending itto you, contact Samantha Carlisle at (907) 793-1223 m Samarnha.Carlisle7Palaska.eov.
Bernie Karl
K&K Recycling Inc. Gordon Severson Penny Vadla
P.O. Box 58055 3201 Westmar Cir. 399 W. Riverview Ave.
Fairbanks, AK 99711 Anchorage, AK 99508-4336 Soldotna, AK 99669-7714
George Vaught, Jr. Darwin Waldsmith Richard Wagner
P.O. Box 13557 P.O. Box 39309 P.O. Box 60868
Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706
5
Statement of Commissioner Hollis French
The following statement is not a quorum order of the Alaska Oil and Gas Conservation
Commission (AOGCC). The statement consists of my answers to questions submitted to the
AOGCC during the December 18, 2018 hearing requested by Ms. Kate Troll on venting and
flaring.
1. What is the track record for full compliance?
Alaska has a track record of holding its vented and flared gas to approximately 0.2 % (two-
tenths of one percent) of the total amount of natural gas produced in the state. A 2004 GAO
report on venting and flaring stated that in the year 2002 Alaska flared .21% of the natural gas
produced in the state.' The flared percentage for FY 18 was .23%. The percentage for FY 17
was .20%.
Compare these values to Texas, which, according to the state's oil and gas commission, flared
about 1% of its gas in 20162, or about five times as much as Alaska did, proportionally. More
notably, North Dakota flared 20% of its gas production in October 2018, or nearly 100 times
more than Alaska did, proportionally.3
Flaring rates in the US are low compared to some international oil and gas producers.4
2. As temperatures rise on the North Slope creating more need to flare off methane are we
just allowing this to become the new normal?
Increasing temperatures on the North Slope do not by themselves create more need to flare off
gas. It is true that the North Slope's oil production is by and large limited by the amount of
natural gas that the oil production facilities (variously called flow stations, central production
facilities, or gathering centers) can safely process, and it is also true that the gas compressors
that do this work are more productive at colder temperatures. Daily temperature swings can
create flaring events when the facilities' compressors `bog down' in the higher temperatures
and internal pressures rise. The vast majority of these temperature swings do not produce any
flaring events, however, due to the alertness of the operators who can reduce the flow into the
plant from high gas content wells.
3. Has AOGCC met with industry to discuss how to reduce emissions in these changing
times?
Yes. AOGCC has met with individual operators when their flaring practices warrant extra
attention. The agency has not conducted a workshop with industry on this topic, although the
hearing held on this petition was an opportunity for industry to hear from concerned citizens.
' Washington D.C.: U.S. GAO 04-089, Natural Gas Venting and Flaring 2004 at 17.
2 www.rrc.state.tx.us/media/46191/annual-gas-summary-2016.pdf.
3 Bismarktribune.com/bakken/north-dakota-oil-production-natural-gas-flaring-reach-new-highs/article_9795ab87
° "While Iran has stopped releasing any official report on gas flaring levels since early 2015, new statistics published
by the country's Planning and Budget Organization indicate that the volume has increased significantly — to almost
625 billion cubic feet in 2017. Iran bums two-thirds of the associated gas produced from its oil fields due to lack of
technology and investment to collect the gas." Radio Farda, Iran, Jan. 7, 2019, found in Larry Persily's Oil and Gas
News Briefs January 14, 2019.
I
Statement of Commissioner Holus French
January 17, 2019
Page 2 of 5
4. Has AOGCC devoted resources to enforcement of its waste gas regulation and will it do
so in the future?
Yes and yes. The agency's efforts to reduce unnecessary flaring go back to the 1970s, when
AOGCC took action to end wasteful flaring practices in Cook Inlets Voluminous records
pertaining to other venting and flaring enforcements are in the agency's files. Recently,
citizen complaints about flaring on the Kenai Peninsula resulted in a day long visit from one
the agency's field inspectors to a land-based production facility. Going forward, the agency
is well-equipped to continue to enforce its laws and regulations.
5. Is there a sense of mission urgency within the AOGCC or is it a status quo operation
focused on just the reporting of releases of methane?
This is a question perhaps better answered by Ms. Troll and the petitioners. It is my strong
impression, however, that the agency in general takes its responsibilities very seriously.
6. Where are vented sources of gas reported? We'd like to know how the AOGCC tracks
methane releases.
Subsections (a) and (b) of 20 AAC 25.235, set out at the end of this document, require that
flared or vented gas be reported to AOGCC on Form 10-422. The only exception to reporting
flared or vented gas is found in subsection (d)(4): "de minimis venting of gas incidental to
normal oil field operations is authorized."
Completed Form 10-422s are not currently available on the AOGCC website. The public can
examine the data submitted to AOGCC on Form 10-422 by visiting the AOGCC website
(doa.alaska.gov/ogc/) and then selecting the `Data' tab which leads to a drop-down menu.
Select `Data List' from the drop-down menu. On that page select `Data Extract.' Doing so
will allow the reader to open a data file which will consist of two documents: a very small file
in Word, which contains a descriptive key to the other file, which is 25 megabytes and is
presented in Microsoft Access. Opening the larger Access file yields a spreadsheet with a list
of Tables on the left side. Selecting the table named `tblFacDisp_Alt' will lead the viewer to
monthly data extracted from Form 10-422 going back to 1995.
Suggested reform — make completed Form 10-422s available directly on the website.
7. How does AOGCC feed data into the state calculation of total greenhouse gas emission
as required by the federal greenhouse gas reporting rule?
It does not appear that AOGCC has a responsibility to report emissions to the EPA under the
greenhouse gas reporting rule. An EPA -sponsored FAQ page on the topic answers the question
of `who will have to report under the final rule?' this way: "In general, the rule calls for fossil
fuel suppliers and industrial gas suppliers, manufacturers of vehicles and engines outside of
the light-duty sector, and certain downstream facilities that emit greenhouse gases (primarily
large facilities emitting 25,000 metric tons of carbon dioxide equivalent (mtCO2e) or more of
GHG emissions per year) to submit annual reports to EPA."'
'See Our Resources Our Past Our Future AOGCC Fifty Years of Service to Alaska (2008) p.32 (copies available at
AOGCC offices 333 W. 71, Avenue, Anchorage.)
6 cedsupport.com/confluence/pages/viewpage.action?pageld=91553924 (accessed January 9, 2019).
r
Statement of Commissioner Hollis French
January 17, 2019
Page 3 of 5
8. Do these substantial emissions fall under authorized emergency and normal operations
or is something else going on? (Referring to a list of 35 flaring events) What is AOGCC
doing to analyze Form 10-422 (flaring and venting reports) to determine if there should
be enforcement actions against certain operators for wasted gas resources?
Each Form 10-422 and any supporting documentation submitted along with it is reviewed by
members of the agency's professional engineering staff and a commissioner to determine how
to classify the flared or vented gas under 20 AAC 25.235(d).
Suggested reform — modem Form 10-422 to accommodate two commissioner signatures to
ensure each determination of how to classify flaring events exceeding one hour is a quorum
decision by the AOGCC.
9. Has AOGCC spot checked any operator's reports to see if their claims of an exemption
are legitimate?
As pointed out above, the submissions on Form 10-422 are reviewed by staff and
commissioners. Staff gathers data, including the volumes of gas involved and an explanation
from the facility regarding the cause of the flaring event. See also the details regarding
BlueCrest, set out in response to Question 10.
10. Have there been any enforcement actions for waste gas in the Arctic or Cook Inlet over
the past 10 years? If yes, what are the details?
There appear to have been two formal enforcement actions for waste in the past ten years. One
involved Cook Inlet Energy, LLC. That case was summarized in a January 2015 Petroleum
News article? as follows:
Alaska drilling regulators hit Cook Inlet Energy LLC with a nearly
$295,000 fine - then dropped it.
But the company still must take certain steps as part of an enforcement
action brought by the Alaska Oil and Gas Conservation Commission.
Cook Inlet Energy is an Anchorage -based firm that operates, among other
properties, the Osprey oil and gas platform in the offshore Redoubt unit and
the related, shore -based Kustatan production facility.
On Oct. 23, 2014, the AOGCC issued a notice of proposed enforcement
action against the company regarding failure to minimize or prevent gas
flaring. The notice advised that Cook Inlet Energy had failed to shut-in a
well, known as RU -3, when the Kustatan facility was undergoing a major
overhaul, and flared nearly 24.7 million cubic feet of gas from Nov. 26,
2013, through Feb. 28, 2014.
The notice proposed corrective actions and a $294,834 civil penalty.
7 The full article is available at http://www.petroleumnews.com/pnads/767425895.shtml.
Statement of Commissioner Hohis French
January 17, 2019
Page 4 of 5
State regulations generally discourage the waste of gas through burning or
free releases into the air.
The other enforcement action involved BlueCrest Alaska Operating LLC, which was and is
developing the Cosmopolitan project on the lower Kenai Peninsula. Citizen complaints of
excessive flaring led to a full-day visit to the facility from one of the agency's field inspectors
and a letter from the AOGCC sent in June 2016. The company reported that the flaring was
the result of their starting up production processing equipment. Among other tasks, the field
inspector conducted tests on the facility's measurement devices, to make sure that the amount
of gas flowing to the flare was being accurately accounted for. AOGCC sent a letter to
BlueCrest on June 10, 2016, informing them that "AOGCC will not initiate enforcement
proceedings for amounts flared in April and May 2016. However, two months is more than
sufficient to conclude commissioning efforts. Flaring produced gas for the purpose of allowing
well production, or for any reason beyond what is necessary for facility operations,
emergencies that threaten life or property, or for preventing loss of ultimate recovery, is waste."
It does not appear that any fine or other corrective action was ordered.
These two formal actions do not tell the whole story, however, as each of the flaring events
referred to in Question #8 were analyzed for potential waste.
Beyond the ten-year period referred to in this question, enforcement actions were pursued for
flared gas in 2004 and 2006. Both resulted in the imposition of fines. See Other Order No. 26
(2004) and Other Order No. 38 (2006).
Conclusion
There are three takeaway points from this review of the agency's regulatory oversight of gas
venting and flaring. First, the 0.2% overall flared percentage figure means that, looking at the state
from the 30,000' level, the Alaska oil and gas industry is, with the watchful eyes of AOGCC upon
it, performing as well or better than any other jurisdiction in the United States when it comes to
conserving the state's valuable resources. Second, is there any room for improvement in how the
agency handles information relating to flaring and venting events? Of course, and this review has
prompted the suggestion of two reforms. The third point is that it is perfectly appropriate for
citizens to ask questions of their public servants, and it is not unreasonable for them to expect
answers.
Rcsulation
20 AAC 25.235. Gas disposition
(a) For each production facility the operator shall compile and report monthly gas disposition and
acquisition on the Facility Report of Produced Gas Disposition (Form 10-422). If a facility's
production comes from multiple pools, the operator shall allocate production between each
producing pool as a percentage of the total volume of gas that the facility handled for the month.
The operator shall report gas acquisition or disposition by category, as follows:
(1) gas sold;
(2) gas reinjected;
I
Statement of Commissioner Hohis French
January 17, 2019
Page 5 of 5
(3) gas flared or vented;
(4) gas used for lease operations other than flaring or venting;
(5) natural gas liquids (NGLs) produced;
(6) gas purchased;
(7) gas transferred;
(8) other.
(b) Any release, burning, or escape into the air of gas other than incidental de minimis venting as
authorized under (d)(4) of this section must be reported as flared or vented on the Facility Report
of Produced Gas Disposition (Form 10-422). The operator shall submit a written supplement for
any flaring or venting incident exceeding one hour. The supplement must describe why the gas
was flared or vented, list the beginning and ending time of the flaring or venting, report the volume
of gas flared or vented, and describe actions taken to comply with (c) of this section.
(c) The operator shall take action in accordance with good oil field engineering practices and
conservation purposes to minimize the volume of gas released, burned, or permitted to escape into
the air.
(d) Gas released, burned, or permitted to escape into the air constitutes waste, except that
(1) flaring or venting gas for a period not exceeding one hour as the result of an emergency or
operational upset is authorized for safety;
(2) flaring or venting gas for a period not exceeding one hour as the result of a planned lease
operation is authorized for safety;
(3) flaring pilot or purge gas to test or fuel the safety flare system is authorized for safety;
(4) de minimis venting of gas incidental to normal oil field operations is authorized;
(5) within 90 days after receipt of the report required under (b) of this section, the commission
will, in its discretion, authorize the flaring or venting of gas for a period exceeding one hour
(A) if the flaring or venting is necessary for facility operations, repairs, upgrades, or testing
procedures;
(B) if an emergency that threatens life or property requires the flaring or venting, unless failure to
operate in a safe and skillful manner causes the emergency; or
(C) if the flaring or venting is necessary to prevent loss of ultimate recovery;
(6) upon application, the commission will, in its discretion, authorize the flaring or venting of gas
for purposes of testing a well before regular production.
(e) Notwithstanding an authorization under (d) of this section, the commission will, in its
discretion, review flaring or venting of gas and classify as waste any volume of gas flared or vented
in violation of (c) of this section.
(f) Notwithstanding conservation orders that the commission issued before 1/1/95, this section
applies to flaring or venting of gas that occurs on or after 1/1/95.
Bernie Karl
K&K Recycling Inc.
P.O. Box 58055
Fairbanks, AK 99711
George Vaught, Jr.
P.O. Box 13557
Denver, CO 80201-3557
Gordon Severson
3201 Westmar Cir.
Anchorage, AK 99508-4336
Darwin Waldsmith
P.O. Box 39309
Ninilchik, AK 99639
Penny Vadia
399 W. Riverview Ave.
Soldotna, AK 99669-7714
Richard Wagner
P.O. Box 60868
Fairbanks, AK 99706
�l
ALASKA OIL AND GAS CONSERVATION COMMISSION
In the Matter of a Petition to Hold )
a Public Hearing to Prevent all Non- )
Emergency Venting and Flaring. )
Docket No.: OTH 18-057
ALASKA OIL and GAS CONSERVATION COMMISSION
Anchorage, Alaska
PUBLIC HEARING
December 18, 2018
10:00 o'clock a.m.
BEFORE: Hollis French
Daniel T. Seamount
Cathy Foerster
nom.
i
u`a`
Page 2
1
TABLE OF CONTENTS
2
Opening
remarks
by Chairman French
03
3
Remarks
by
Ms.
Troll
06
4
Remarks
by
Ms.
Smith
15
5
Remarks
by
Ms.
Long
32
6
Remarks
by
Ms.
Epstein
36
7
Remarks
by
Ms.
Moriarty
44
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
u`a`
Page 3
1 P R O C E E D I N G S
2 (On record)
3 CHAIRMAN FRENCH: I'll call the meeting to
4 order. Good morning. It's 10:00 o'clock on the
5 morning of December 18, 2018. We're here at 333 West
6 Seventh Avenue in Anchorage, Alaska, this is the
7 headquarters of the Alaska Oil and Gas Conservation
8 Commission. To my right is Commissioner Cathy
9 Foerster, to my left is Commissioner Dan Seamount, I'm
10 Hollis French, the Chair of the Commission.
11 We're here today on docket number OTH 18-057, a
12 petition to hold a public hearing to prevent all non -
13 emergency venting and flaring. By a letter dated
14 November 5th, 2018, Kate Troll requested the hearing --
15 requested a hearing to be held by the Alaska Oil and
16 Gas Conservation Commission and that's what we're
17 doing.
18
Computer
Matrix will be recording
the
19
proceedings, you
can get a copy of the transcript from
20
Computer Matrix
Reporting.
21
We have
two people signed up here
in the room
22
to testify and I
believe there are people
online to
23
testify. Let's
go ahead and take care of
that matter
24
of housekeeping
first.
25
If you are
online and if you wish
to testify
.mcg iv�nou n+.o..E Ie..o.o�o+r��woro..ErEkr.�..wN.. ara w. oxx�wn
9 O -L -L.
10 CHAIRMAN FRENCH: Thank you. And who else is
11 online who wishes to testify?
12 MS. LONG: Becky Long, L -O -N -G.
13 CHAIRMAN FRENCH: Ms. Long. And who else?
14 (No comments)
15 CHAIRMAN FRENCH: Going once, going twice. If
16 other people change -- if you change your mind -- if
17 you're online and you change your mind later on just
18 speak out and we'll make room for your testimony.
19 The Commissioners today will ask questions
20 during the testimony, we may take a recess to consult
21 with staff to determine whether additional information
22 or clarifying questions are necessary. If a member of
23 the audience has a question that he or she feels should
24 be asked, please submit that question in writing to
25 Jody Colombie. She will provide the question to the
Page 4
1 please state your name, spelling your last name.
And I
2 know it's tough because you don't know how many of
you
3 there are, but maybe, Kate Troll, you can start.
4 MS. TROLL: Thank you. I am Kate Troll and I
5 am ready to testify when so directed.
6 CHAIRMAN FRENCH: Okay. And if you could
just
7 spell your last name for us, Kate.
8 MS. TROLL: Troll, like under the bridge,
T -R-
9 O -L -L.
10 CHAIRMAN FRENCH: Thank you. And who else is
11 online who wishes to testify?
12 MS. LONG: Becky Long, L -O -N -G.
13 CHAIRMAN FRENCH: Ms. Long. And who else?
14 (No comments)
15 CHAIRMAN FRENCH: Going once, going twice. If
16 other people change -- if you change your mind -- if
17 you're online and you change your mind later on just
18 speak out and we'll make room for your testimony.
19 The Commissioners today will ask questions
20 during the testimony, we may take a recess to consult
21 with staff to determine whether additional information
22 or clarifying questions are necessary. If a member of
23 the audience has a question that he or she feels should
24 be asked, please submit that question in writing to
25 Jody Colombie. She will provide the question to the
Page 5
1 Commissioners
and
if we
feel
that asking the
question
2 will assist us
in
making
our
determinations
we will ask
3 it.
4 For those testifying please keep in mind that
5 you must speak into the microphone so that those in the
6 audience and the court reporter can hear your
7 testimony. Also please remember to reference your
8 slides so that someone reading the public record can
9 follow along. For example refer to slides by their
10 numbers if numbered or by their titles if they are not
11 numbered.
12 We have a few ground rules on what is allowed
13 relative to testimony. First, all testimony must be
14 relevant to the purposes of the hearing that I outlined
15 a few minutes ago and to the statutory authority of the
16 AOGCC. Anyone desiring to testify may do so, but if
17 the testimony drifts off subject we will limit the
18 testimony. Additionally testimony may not take the
19 form of cross examination, as I said before the
20 Commissioners will be asking questions. Finally
21 testimony that's disrespectful or inappropriate will
22 not be allowed.
23 Commissioner Foerster, anything to add?
24 COMMISSIONER FOERSTER: Not at this time.
25 CHAIRMAN FRENCH: Commissioner Seamount,
Page 6
1 anything to add?
2 COMMISSIONER SEAMOUNT: I have nothing.
3 CHAIRMAN FRENCH: I'll go ahead and swear in
4 the witnesses. So why don't we start with you, Kate
5 Troll, since you asked for this hearing. If you'd
6 raise your right hand.
7 (Oath administered)
8 MS. TROLL: I do.
9 CHAIRMAN FRENCH: All right. Go ahead. Kate,
10 I'll let you know that we have received your testimony
11 in written form. I know I've read it, I believe the
12 other Commissioners have. We -- if you wish you can
13 read the entire statement into the record or if you
14 want to select highlights from it, that's up to you,
15 but please go ahead, the floor is yours.
16 KATE TROLL
17 called as a witness on her own behalf, testified as
18 follows on:
19 DIRECT EXAMINATION
20 MS. TROLL: Thank you, Commissioner French,
21 Foerster and Seamount for designing this hearing in
22 response to a petition signed by 48 Alaskans. And
23 since that petition there's hundreds more that have
24 signed a similar petition. And that'll be addressed by
25 Ceal Smith who I think is now online.
Page 7
1 To start I would just like to introduce myself.
2 I have a background in natural resource management and
3 over 22 years experience in climate and energy policy,
4 fisheries and coastal management in Alaska. I've also
5 been elected to local office twice.
6 And I want to emphasize that while the topic of
7 climate change is going to enter this hearing, we are
8 not asking you to enlarge your mission. We do not seek
9 mission creep, we merely ask that you urgently and
10 competently enforce statute 31.05.095 which prohibits
11 the waste of oil and gas and your regulations which
12 define waste as gas released, burned or permitted to
13 escape into the air. Because that gas which escapes is
14 mostly methane, a greenhouse gas about 30 times more
15 potent than carbon dioxide over the long term and
16 almost 90 times more potent over the short term, the
17 matter of climate change enlarges the public interest
18 behind your existing mission. In other words it's not
19 mission creep we seek, but mission urgency.
20 As I note in my written remarks the United
21 Nations International Panel on Climate Change has
22 estimated that we now have about a dozen years to keep
23 the maximum amount of heating in the world below 1.5
24 degrees celsius beyond which even a half a degree will
25 significantly worsen the risk of droughts, floods,
�v�w�v new. Ix...0 voxv�naucwnwxoromcvevru,�.on.Er.¢w o -un x�.an�i>�.+
Page 8
1 extreme heat and poverty for hundreds of millions of
2 people. We are already at one degree celsius and 12
3 years is not long at all. And when you listen to the
4 words of renown naturalist David Attenborough, it tells
5 me that it's time for all hands on deck. And he says
6 right now we're facing a manmade disaster of global
7 scale, our greatest threat in thousands of years,
8 climate change. If we don't take action the collapse
9 of our civilization and extinction of much of the
10 natural world is on the horizon.
11 Those are very scary terms and sometimes
12 hearing those types of descriptions turns people off,
13 but bringing it back down to Alaska, we also note that
14 these types of concerns are backed up in the latest
15 national climate assessment in which an entire chapter
16 was devoted to Alaska and it continues to describe
17 Alaska as one of the fastest warming places on earth.
18 Fairbanks climatologist, Rick Thoman, he helped write
19 the chapter and he says one of our big take aways for
20 Alaska is that it's going to be very expensive to adapt
21 to climate change and that it would be felt in every
22 household across the state. In fact a similar report
23 by the University of Alaska Anchorage estimates that
24 climate change is going to cost the state between 340
25 and 700 million per year over the next decade. And
Page 9
1 those are just to deal with known consequences in
2 Alaska such as permafrost thawing, coastal erosion,
3 village relocation and infrastructure damage.
4 So it's one of the most highly impacted states
5 for climate change, we need to get our own issues in
6 order if we want any type of federal aid to address our
7 adaption needs. And whether you look at climate change
8 globally or just within Alaska there's an undeniable
9 pressing need to reduce greenhouse gas emissions as
10 soon as possible. And since the oil and gas sector is
11 a large contributor of our greenhouse gas emissions, it
12 makes sense to focus on the reduction of waste in this
13 section. And that is your statutory charge.
14 The defenders of status quo in Alaska like to
15 point out that the emissions from Alaska comprise less
16 than 1 percent of U.S. emission and less than .1
17 percent of global emissions. Status quo defenders like
18 to use these figures in presenting the de minimis
19 argument that there is no action necessary. Not only
20 does this approach overlook our moral responsibility to
21 future generations, but skips right over the fact that
22 on a per capita basis Alaska is fourth in the nation
23 for greenhouse gas emission. And the reason for this
24 high per capita amount circles us right back to the oil
25 and gas operations which generate more than 50 percent
Page 10
1 -- which generated more than 50 percent of our
2 emissions in 2015.
3 And 10 years ago when I was serving as a deputy
4 director of the Alaska Conservation of Voters and
5 Alaska Conservation Alliance I was appointed to
6 Governor Palin's Mitigation Advisory Group. And while
7 there I participated in discussions with the oil and
8 gas sector about agreeing to reduce future methane
9 emissions including the non -emergency venting and
10 flaring of methane. And this was a recommendation that
11 was unanimously supported by all the oil and gas
12 representatives. And since then no governor or state
13 agency has made any effort to implement this industry
14 supported action. In other words we've had status quo
15 for more than 10 years and with all the reports of
16 existing and threatening climate change only growing in
17 scale and intensity the time for implementing these
18 industry supported recommendations is now. And one
19 would think that judging by the (indiscernible)
20 statements of industry that the oil and gas sector of
21 Alaska would agree to this immediate needs assessment.
22 And I would kind of like to take a moment to
23 highlight some of the sections that were signed on to
24 by British Petroleum and Exxon in a document called the
25 Guiding Principles of Climate Change. And they note
Page 11
1 that providing access to energy while addressing global
2 climate change is one of our greatest challenges.
3 Since natural gas consists mainly of methane, a potent
4 greenhouse gas, this part is -- in the transition to a
5 low carbon future will be influenced by the extent to
6 which the oil and gas industry reduces its methane
7 emissions. And they go on further to quote, we will
8 reduce venting of (indiscernible) methane emissions and
9 improve combustion efficiency. They further state we
10 will work constructively with international
11 institutions, industry and NGOs in the development and
12 implementation of effective methane abatement policies
13 and regulations.
14 So from these statements we can take that BP
15 and Exxon are fully on -board with your mission to
16 reduce methane emissions. ConocoPhilips, while not a
17 signatory to these guiding principles, has its own
18 climate change strategy posted online and they note
19 that they need to prioritize emission reduction. And
20 they also want to improve the recording of emission
21 reduction projects. So these statements in conjunction
22 with industry agreement on Governor Palin's Mitigation
23 Advisory Group strongly suggest that the Alaska Oil and
24 Gas Commission has a willing industry partner to reduce
25 waste, to reduce emissions including the non -emergency
Page 12
1 venting and flaring. In essence it should be
2 relatively straightforward to hold the oil and gas
3 sector not only accountable to their pledges, but to
4 their obligations under your waste regulations.
5 Which brings me to the issue at hand which is
6 what is the track record for full compliance. As noted
7 by those following me in this hearing there is reason
8 to doubt that rigorous compliance is occurring. As the
9 temperatures rise on the North Slope create more need
10 to flare off methane are we just allowing this to
11 become the new normal in North Slope operations. Has
12 the Oil and Gas Commission met with the industry to
13 discuss how to reduce emissions in these changing
14 times. Has the Oil and Gas Conservation Commission
15 devoted resources to enforcement of its waste gas
16 regulations and will it do so in the future. These are
17 questions that we would really appreciate the
18 Commission addressing. And is there a sense of mission
19 urgency within your operations or are we into a status
20 quo mode on just reporting more releases of methane.
21 Bringing a little more focus into these
22 (indiscernible) questions is Ceal Smith who is now on
23 the line. And following her is Lois Epstein.
24 Thank you for allowing me to provide these
25 introductory comments.
Page 13
1 CHAIRMAN FRENCH: Thank you, Ms. Troll. And
2 let's see if we have any questions for you from members
3 of the Commission.
4 Commissioner Foerster, Commissioner Seamount,
5 any questions?
6 COMMISSIONER FOERSTER: Not at this time.
7 COMMISSIONER SEAMOUNT: Not at this time.
8 CHAIRMAN FRENCH: I just have one or two, Kate.
9 And I'm looking on page 2 of your printed statement.
10 In the one, two, third bulleted paragraph the last
11 sentence says the reason for this high per capita
12 amount of emissions circles us right back to oil and
13 gas operations which generate more than 56 percent of
14 Alaska total greenhouse emissions. I circled that when
15 I read it because I thought to myself where does that
16 come from. And then I saw in one of the other
17 submissions a DEC -- looks like a printed page from a
18 DEC publication. And so I'm just going to -- do you
19 know if that's where your 56 percent came from?
20 MS. TROLL: Yes, that is my same source of
21 document and.....
22 CHAIRMAN FRENCH: Sure.
23 MS. TROLL: .....what I did to get to 50
24 percent mark was that I just went down to the bottom
25 and looked at the total net emissions and divided that
I
Page 14
1 by what the oil and gas sector provided. So, yes, the
2 DEC report is the source of that figure.
3 CHAIRMAN FRENCH: Sure. That -- and that looks
4 -- it looks like your arithmetic is right from looking
5 at that report.
6 And just a couple of other questions about
7 sources and so forth. Did the -- did governor -- did
8 the Governor Palin Mitigation Advisory Group issue a
9 report or a document or any kind of final wrap-up
10 document?
11 MS. TROLL: Yes, they did. And it is the
12 Mitigation Advisory Group's report. You'll find it
13 online, it's kind of harder to find now because it's
14 such an old document, but I was able to locate it
15 through the DEC's website.
16 CHAIRMAN FRENCH: Okay. If you -- okay. That
17 -- that's fine. And finally in the -- in the final
18 bullet on that page you make reference to the guiding
19 principles signed by BP and Exxon. Was that in
20 conjunction with Governor Palin's Mitigation Advisory
21 Group or is that a separate effort?
22 MS. TROLL: That was a separate effort and that
23 followed later on. And this is a -- was a report that
24 came out in November, 2017.
25 CHAIRMAN FRENCH: November, 2017. Okay. I
Page 15
1 think those are all my questions. Any follow-up based
2 on those questions from the Commissioners?
3 (No comments)
4 CHAIRMAN FRENCH: I don't see any. You
5 mentioned that you thought that Ceal Smith had joined
6 the folks online. Ceal Smith, are you online?
7 MS. SMITH: Yes, I am.
8 CHAIRMAN FRENCH: And you wish to testify?
9 MS. SMITH: I do.
10 CHAIRMAN FRENCH: Excellent. If you would
11 raise your right hand.
12 (Oath administered)
13 MS. SMITH: I do.
14 CHAIRMAN FRENCH: And do you smell -- do you
15 spell your last name in the common fashion, S -M -I -T -H?
16 MS. SMITH: Yes, I do.
17 CHAIRMAN FRENCH: Okay. Go ahead, the floor is
18 yours. Please proceed.
19 MS. SMITH: Okay. Thank you.
20 CEAL SMITH
21 called as a witness on behalf of the Alaska Climate
22 Action Network, testified as follows on:
23 DIRECT EXAMINATION
24 MS. SMITH: Yes, my name is Ceal Smith and I'm
25 speaking today on behalf of the Alaska Climate Action
Page 16
1 Network. We're a statewide grassroots network of
2 plaintiffs, policy and renewable energy experts,
3 partner groups and Alaskans from all walks of life who
4 are worried about (indiscernible) dangerous and
5 possible impacts of climate change especially for rural
6 Alaska.
7 I'd like to thank the Commissioners French and
8 Foerster and Seamount for granting this hearing in
9 response to Kate's request and the 48 Alaskans who
10 signed the petition at our (indiscernible) in Anchorage
11 on September B. And since then more than 300 more
12 Alaskans have joined in our appeal to the AOGCC to do
13 everything in their power to fully enforce and
14 strengthen the rules to reduce Alaska's greenhouse gas
15 emissions.
16 We submitted our petition in full with all the
17 signatures and I was having a little trouble with my
18 email, but I'm hoping you received those today?
19 CHAIRMAN FRENCH: I have a copy and I think the
20 other Commissioners do too, they're nodding their
21 heads. It's entitled Petition to Fully Enforce and
22 Strengthen Waste Rules to Reduce Alaska's Greenhouse
23 Gas Emissions. And it looks like it's 10 pages long
24 with almost 300 signatures or at least names on the
25 petition.
Page 17
1 MS. SMITH: Yes. Okay. Good. Okay.
2 CHAIRMAN FRENCH: Excellent.
3 MS. SMITH: I was worried that that hadn't gone
4 through.
5 Yes. So I -- I'm not going to repeat what Kate
6 said and -- but I would like to address the commercial
7 lease question of what is the track record for full
8 compliance.
9 On November 18th, Kristen Nelson reported in
10 Petroleum News in response to the announcement
11 (indiscernible - background noise).....
12 CHAIRMAN FRENCH: And for whoever.....
13 MS. SMITH: Oh. I don't know why I'm getting a
14 lot of feedback.
15 CHAIRMAN FRENCH: .....for whoever's online, if
16 you could -- for those not testifying, everybody
17 besides Ms. Smith, if you could just mute your phone,
18 that will allow you to listen and that will keep us
19 from hearing papers moving or, you know, any other kind
20 of disruption.
21 It's much quieter now. Thank you.
22 MS. SMITH: Okay. So the Petroleum News
23 reported that the Commission revised its flaring
24 regulations effective January 1st, 1995. The goal of
25 the flaring oversight program is the elimination of
Page 18
1 unnecessary flaring whenever possible. And secondly,
2 the Commission's current regulations allow no gas
3 release except for up to an hour for emergencies or
4 operational upsets or for planned release operations
5 authorized for safety, to (indiscernible) or test a
6 safety flare system and de minimis venting incidental
7 to normal operations.
8 The regulations also say the Commission can
9 authorize flaring for more than one hour under specific
10 circumstances.
11 So we took a look at the data and here is what
12 we found. First, according to the same DEC report that
13 Kate referenced, the 2018 Alaska Greenhouse Gas
14 Emissions Inventory Report describes and quantifies
15 human caused sources of greenhouse gas emissions that
16 occurred between 1990 and 2015 from Alaska operations
17 and facilities. The oil and gas industry contributed
18 an average of 52 percent of Alaska's total greenhouse,
19 and that's gross emissions. So I did a little bit
20 different calculation than Kate did, but it's in the
21 ball park. So that equals about 44.5 million metric
22 tons of carbon dioxide equivalents per year for a
23 cumulative total of 552 million metric tons of carbon
24 dioxide equivalents.
25 So based on these figures between 1990 and 2015
Page 19
1 average annual emissions from the oil and gas sector
2 was 23.22 million metric tons of carbon dioxide
3 equivalents. And that's equivalent to about 5 million
4 passenger cars per (indiscernible - background noise)
5 or 53.5 million barrels of oil per year. And that --
6 just to give some context, that's about 17 percent of
7 California's total annual consumption per year which I
8 guess you probably know that California is the fourth
9 or fifth biggest economy in the world. And it also is
10 equivalent to about 3 million average U.S. households'
11 electricity use. So that's a substantial number.
12 We looked at the data direct from the OGCC that
13 I obtained from the -- from Lois Epstein from
14 Wilderness Society. And between January, 2012 and
15 February, 2017 industry reported flaring 17,374,472
16 cubic feet of gas or just short of 3 million cubic feet
17 per year. And that included 1,468 releases that were
18 greater than one hour. And the cumulative total of
19 those releases was -- well, we're getting some big
20 numbers here, 12,742,668 million cubic feet or that's
21 about 12.7 billion cubic feet of gas. And the range
22 was from 747,534 million cubic feet in Point Thomson on
23 April 16th, 2016 all the way down to just a single
24 million cubic feet at Ninilchik Falls on July, 2017.
25 So 34 of those releases exceeded 100,000 million cubic
Page 20
1 feet and of those 34 releases three were from Point
2 Thomson, including the release just mentioned, nine
3 were from Prudhoe Bay gathering center one, three were
4 from Prudhoe Bay gathering center two, eight were from
5 Prudhoe Bay CGFB and nine from North Star and then a
6 single one from Prudhoe Bay unit GC3.
7 And then I've included a table in my written
8 comments that lists those top 35 or, yeah, 34 releases
9 that were reported in the -- in the data released to
10 Lois Epstein.
11 So as quoted in the Petroleum News above and
12 according to rule 25.235, section (d) gas released,
13 burned or permitted to escape into the air constitutes
14 waste except that a flaring or venting gas for a period
15 not exceeding one hour as a result of an emergency or
16 operational upset as authorized by safety.
17 So that kind of contradicts the rule so we have
18 a lot of questions here. we haven't yet received all
19 the documents we requested in our public information
20 request so we're unable to compare the gas deposition
21 report, form 10422 against the Excel spreadsheet data
22 to determine if these were authorized releases. Even
23 if we had -- as a small nonprofit dependent on
24 volunteers we don't really have the expertise or the
25 capacity to do this analysis. And we might be off on
Page 21
1 some of our calculations that's I'm quoting here so,
2 you know, we're doing our best here to understand the
3 data, but it's, you know, kind of -- a little bit
4 beyond our capacity.
5 So in the end we're left with more questions
6 than answers including do these substantial emissions
7 that I just reported fall under authorized emergency
8 and normal operations of maintenance or is something
9 else going on.
10 In addition to the 1,400 plus releases greater
11 than one hour we did not see where industry reports
12 vents of gas, the form only has spaces for flared gas.
13 So one question is, you know, where is -- where are
14 these vented sources being reported. And on page 21 of
15 the greenhouse report and it notes that in 2015 the
16 industry sector produced over half of Alaska's
17 greenhouse gas emission. Fugitive methane contributed
18 over 19 percent of the CO2E emitted by the sector in
19 2015. Quote, much of the fugitive methane comes from
20 oil production, a small portion comes from natural gas
21 production.
22 So we're -- we'd like to know how the AOGCC
23 tracks the methane releases. You know, obviously we
24 were concerned of their more powerful greenhouse gas
25 affect. we also like to know the AOGCC feeds data,
Page 22
1 feeds into the state calculation of total greenhouse
2 gas emission as required under the federal greenhouse
3 gas reporting rule. So, you know, we're basically
4 trying to relate the greenhouse gas data report to the
5 industry deposition data. So any help we could get
6 from you guys on that count just to understand, you
7 know, exactly what's going on with industry emissions.
8 So we would really appreciate answers to these
9 questions.
10 And then I'd like to note too that these
11 greenhouse gas emissions carry with them a whole fleet
12 of hazardous pollutants including volatile organic
13 compounds that have serious direct and indirect
14 community and environmental health impacts including
15 cancer, neurological developmental and reproductive
16 affects and the capacity to disrupt critical endocrine
17 hormones.
18 In closing as Bjorn Olson with Alaskans Know
19 Climate Change and I wrote in a recent op ed and it
20 deserves repeating, our civilization has little more
21 than a decade to rein in greenhouse gas emission or
22 face a series of cascading ecosystem and economic
23 collapses. We urge you as our duly appointed and
24 trusted AOGCC Commissioners to do absolutely everything
25 in your power to reduce waste in the form of dangerous
Page 23
1 greenhouse gas emissions. We're on the front lines of
2 climate change and we'd like to get on the front lines
3 of being a solution to climate change.
4 I want to thank you again for listening to my
5 comments today. That's all I have to say.
6 CHAIRMAN FRENCH: Thank you for your testimony,
7 Ms. Smith. Questions for Ms. Smith from members of the
8 Commission?
9 Commissioner Foerster.
10 COMMISSIONER FOERSTER: I do. I just have one.
11 On page 2 you have a lot of mcfs and million cubic
12 feets written down and you stated those in your
13 testimony. In oil field vernacular an mcf is 1,000
14 cubic feet and I just would request that you check your
15 document and correct it for us as to whether you're
16 talking about mcf or million cubic feet in each
17 instance just for your own -- just for the accuracy of
18 your statements.
19 MS. SMITH: Yes, and we've been struggling with
20 those numbers. So.....
21 COMMISSIONER FOERSTER: Okay.
22 MS. SMITH: .....you know, I realize that we
23 may need to make some adjustments there.
24 COMMISSIONER FOERSTER: Okay. Thank you.
25 MS. SMITH: Yeah, thank you.
r
Page 24
1 COMMISSIONER FOERSTER: That's it.
2 COMMISSIONER SEAMOUNT: Ms. Smith, this is Dan
3 Seamount. Is there a difference in the affect of
4 climate -- I'm not a climate expert so I may be asking
5 an ignorant question, but if you burn the methane is --
6 does that have a different affect on the climate than
7 if you just vent it?
8 MS. SMITH: Oh, yes, of course. Yes,
9 combusting the -- the natural -- the methane converts
10 it into straight CO2 while releasing all those VOCs
11 that I mentioned at the end. But, yes, it -- it
12 actually reduces the climate enforcing impact. And in
13 general it's about a 98 percent efficiency so there
14 still are some methane emissions even from the flaring
15 depending on how efficient that flaring is.
16 COMMISSIONER SEAMOUNT: Okay. So the methane
17 has a greater affect -- just venting it has a greater
18 affect on climate than if you actually burn it, is that
19 what I'm hearing?
20 MS. SMITH: Yes, uh-huh. That's correct, yes.
21 We don't have numbers anywhere that we've been able to
22 locate on how much gas is being vented other than that
23 DEC number of 19 percent.
24 COMMISSIONER SEAMOUNT: Okay. How long does
25 the effective of venting or burning methane stay in the
Page 25
1 atmosphere compared to CO2, I mean, compared to -- is
2 there a difference between that and how much CO2 is
3 actually released? I think I read somewhere that CO2
4 will stay in the atmosphere and have a much longer
5 effect that methane; is that correct?
6 MS. SMITH: Yeah, the CO2 is -- is much more
7 persistent. Yeah, CO2 is much more persistent and has
8 a much more long range affect whereas methane is short
9 term, but it's much more powerful. And at this point I
10 think the -- the methane -- well, both of them are very
11 important for different reasons, but for the immediate
12 future the methane is becoming a very critical piece
13 that we want to reduce as much as possible to minimize
14 short term warming.
15 COMMISSIONER SEAMOUNT: So how long will
16 methane stick around and affect the climate, are we
17 talking years, decades?
18 MS. SMITH: Well, I don't have those numbers at
19 my fingertips, certainly decades. But it -- it reduces
20 over time, it has the most powerful affect as Kate said
21 up to 90 times the affect of carbon in the short run.
22 And I'm not quite sure what that time scale is, but I
23 would say two or three decades.
24 COMMISSIONER SEAMOUNT: Okay. So you mentioned
25 -- well, I'm looking at -- well, it's page 2 on my
Page 26
1 email, I don't know what page it would be on others'
2 emails, but you've.....
3 MS. SMITH: Uh-huh.
4 COMMISSIONER SEAMOUNT: .....got flared gas at
5 17 bcf over looks like five years which comes to 2.9
6 bcf per year. Am I reading that correctly?
7 MS. SMITH: I'm not sure what you're looking
8 at.
9 COMMISSIONER SEAMOUNT: It says then we looked
10 at data obtained directly from AOGCC. Between January,
11 2012 and.....
12 MS. SMITH: Oh, okay. Uh-huh.
13 COMMISSIONER SEAMOUNT: .....February, 2017,
14 you've got a bullet that says flared off 17 bcf. And
15 under that the third bullet -- well, first of all the
16 second bullet says 1,468 releases greater than one hour
17 and then the third bullet.....
18 MS. SMITH: Uh-huh.
19 COMMISSIONER SEAMOUNT: .....is cumulative
20 total of 12.7 bcf. Okay. So.....
21 MS. SMITH: Uh-huh.
22 COMMISSIONER SEAMOUNT: .....would I be correct
23 in adding the 17.3 plus the 12.8 to get a total?
24 MS. SMITH: That was the -- the first bullet
25 point is 17 million mfc or mcf is the -- okay, that's
Page 27
1 the total and then divided by the nine years just short
2 of 3 million per year. And.....
3 COMMISSIONER SEAMOUNT: Okay. And.....
4 MS. SMITH: .....now I'm just -- the -- the
5 cumulative total in this third bullet point only refers
6 to the -- to the 1,468 releases greater than one hour.
7 COMMISSIONER SEAMOUNT: Okay. So.....
8 MS. SMITH: So those are two different num.....
9 COMMISSIONER SEAMOUNT: Sure.
10 MS. SMITH: .....those are looking at two
11 different variables.
12 COMMISSIONER SEAMOUNT: Okay. So if you did
13 some weird math you'd add those two together to get a
14 total. So as you sit.....
15 MS. SMITH: No, not really because I only
16 pulled out for the -- for the second and third bullet
17 points, I just pulled out those bigger releases, the
18 ones over 100,000.....
19 COMMISSIONER SEAMOUNT: Okay.
20 MS. SMITH: .....mfc -- mcf. Yeah.
21 COMMISSIONER SEAMOUNT: Okay.
22 MS. SMITH: So maybe I should have separated
23 that out so it wasn't -- you know, so they weren't
24 being -- it's kind of comparing two different data
25 sets, a subset of the larger data. Does that make
Page 28
1 sense now?
2 COMMISSIONER SEAMOUNT: Yeah, I think I
3 understand. And did.....
4 MS. SMITH: Yeah, because the third -- the
5 second, third and fourth and fifth, all the -- except
6 for the first bullet point all the other bullet points
7 only refer to those 34 larger releases.....
8 COMMISSIONER SEAMOUNT: Okay. I understand.
9 MS. SMITH: .....that were over one hour.....
10 COMMISSIONER SEAMOUNT: Okay.
11 MS. SMITH: .....over 100,000 mcf.
12 COMMISSIONER SEAMOUNT: Okay. Then you have a
13 series of questions which I think are valid questions
14 and I would think.....
15 MS. SMITH: Uh-huh.
16 COMMISSIONER SEAMOUNT: .....we would like to
17 do our best to answer those questions in the.....
18 MS. SMITH: Thank you. Yes, I would -- we
19 would greatly appreciate -- you know, we're -- this is
20 our first sort of dive into this whole subject so we're
21 getting -- you know, getting up to speed on it as well
22 and -- and how things are reported and regulated. And
23 I'm just -- I'd like to ask who's speaking who asked me
24 those questions?
25 COMMISSIONER SEAMOUNT: This is Dan Seamount,
Page 29
1 Commissioner Seamount
2 MS. SMITH: Excuse me?
3 COMMISSIONER SEAMOUNT: This is Commissioner
4 Seamount.
5 MS. SMITH: Oh, okay.
6 COMMISSIONER SEAMOUNT: And I'm not sure.....
7 MS. SMITH: Thank you.
8 COMMISSIONER SEAMOUNT: .....what process we'd
9 go through to answer these questions. Do any of the
10 other Commissioners?
11 COMMISSIONER FOERSTER: Yeah. This is
12 Commissioner Foerster. And as I read through you all's
13 testimony this morning I heard a lot of -- I got a lot
14 of the impression that you really just have some
15 questions about understanding our process. And I'm not
16 sure a hearing is really what you wanted. Typically in
17 a hearing we act as adjudicators and an applicant comes
18 to us and makes a specific request and we make a
19 decision on that request. And it sounds to me
20 that.....
21 MS. SMITH: Okay.
22 COMMISSIONER FOERSTER: .....you're asking for
23 us to.....
24 MS. SMITH: Okay.
25 COMMISSIONER FOERSTER: .....answer questions
Page 30
1 and we don't do that, we do not testify from the bench.
2 However having said that it's very important to the
3 AOGCC that the public understands what we do and that
4 we
act as a transparent agency. So
what the -- perhaps
5 the
best approach to address your concerns would be if
6 you
schedule a meeting with some of
our technical staff
7 and
anyone who wants to attend that
meeting is welcome
8
to attend,
and
they can
explain to you
the processes
9
that we use to
evaluate
the flaring and venting that
10
occurs in
the
state and
regulate those
events. So I
11 think the...
12 MS. SMITH: Okay.
13 COMMISSIONER FOERSTER: .....approach for you
14 guys to take to get your questions answered would be to
15 make a call to our special assistant, Jody Colombie, or
16 our secretary, Samantha Carlisle, both of their phone
17 numbers are available on the website or I can give them
18 to you right now, 793-1223 or 793-1221. And make a
19 call and ask them to work with you to schedule a
20 meeting. I think that will go a long way to help you
21 understand what we do.
22
MS.
SMITH: Okay. Yeah.
Thank you for that.
23
I do want
to be clear though that
we are specifically
24
asking the
Commissioners to enforce existing waste
25 rules and strengthen those rules. You know, our
I
Page 31
1 petition and the 300 folks that signed in addition to
2 the ones that signed Kate's request, we are -- we have,
3 you know, quest -- we have reason to question whether
4 those regula -- you know, the -- the waste rules are
5 being enforced to the fullest extent based on the data
6 that I presented. So, you know, I do want to make it
7 clear that in addition to the questions we have a very
8 specific request to the Commissioners to enforce and
9 improve their waste management methods. So, you know,
10 our questions are there, but they're only a subset of
11 our request to the Commissioners to enforce existing
12 regulations.
13 CHAIRMAN FRENCH: Ms. Smith, thank you. The
14 colloquy between you and Commissioner Seamount and
15 Commissioner Foerster are both very useful for us.
16 I guess for my -- well, I'll hold my remarks.
17 But do you have anything else you want to add based on
18 the conversations you had with members of the
19 Commission?
20 MS. SMITH: No, not at this time.
21 CHAIRMAN FRENCH: Thank you very much then.
22 Let's turn to Becky.....
23 MS. SMITH: Thank you.
24 CHAIRMAN FRENCH: .....let's turn to Becky Long
25 who's also on the line.
tea,
Page 32
1 Becky, are you there?
2 MS. LONG: Yes, I am here.
3 CHAIRMAN FRENCH: Will you raise your right
4 hand.
5 (Oath administered)
6 MS. LONG: I do.
7 CHAIRMAN FRENCH: Please testify.
8 MS. LONG: Yes.
9 BECKY LONG
10 called as a witness on her own behalf, testified as
11 follows on:
12 DIRECT EXAMINATION
13 MS. LONG: The current administration in our
14 borough government is moving to increase both onshore
15 and offshore oil and gas leasing in Alaska, in the
16 Arctic Refuge, Coastal Plane, the Beaufort and Chukchi
17 Sea leasing in the five year schedule. They are
18 talking about opening up special areas in the NPR -A and
19 also there is increased production in the NPR -A. And
20 this has really heightened public concern over the
21 flaring and venting of methane in the North Slope and
22 in Cook Inlet by the oil industry as we've been hearing
23 methane is a potent greenhouse gas emission. Overall
24 oil and gas production produces 31 percent of the U.S.
25 methane emission and is the largest source. Now the
Page 33
1 AOGCC is directed by regulations to reduce and
2 eliminate waste. And more than ever the AOGCC
3 enforcement is very, very important. In September the
4 current federal government repealed the 2015 ELM rule
5 on waste gas regarding flaring and leaks on federal
6 land. The 2015 Environmental Protection Agency rule on
7 methane and reducing emissions, those requirements
8 which I commented on a few years ago, that is poised to
9 be repealed. So what this means is the industry will
10 only have to meet the state standards, it's more
11 important than ever.
12 And in Alaska on federal land, this is on
13 federal land, from 2008 to 2017 over 640,000 mcf of
14 waste gas was submitted and that's worth $2.8 million.
15 So this seems like a pretty outrageous number to
16 consider.
17 I'll just be brief. Alaska as it has been said
18 is on the front line of climate change. I won't go
19 into all the specifics that prove that. I just want to
20 make sure that the AOGCC is enforcing and doing enough
21 to stop the non -emergency methane waste into the air
22 and also I think the public needs to know this.
23 So thank you very much for your time and for
24 holding this hearing.
25 CHAIRMAN FRENCH: Thank you, Ms. Long.
i
Page 34
1 Questions for Ms. Long?
2 COMMISSIONER FOERSTER: I have none.
3 COMMISSIONER SEAMOUNT: I have none. Thank
4 you, Ms. Long.
5 CHAIRMAN FRENCH: I will make an observation
6 and thank you for testifying, Ms. Long. And again this
7 is just one -- this is just one perspective from one
8 Commissioner. But one of the -- at least one of the
9 rubs I'm hearing here is between venting and flaring.
10 From the folks who've asked for this hearing, from
11 their perspective venting is let's just say 10 times
12 worse than flaring because of the release of methane.
13 And yet from our perspective and I'm going to say
14 excessive flaring because if you work in industry and
15 you're around industry, you know, you have to have a
16 flare, it's an absolutely vital aspect of safely
17 managing the high pressures that gas and gas handling
18 entails. So when you compare excessive flaring versus
19 venting from your perspective venting is 10 times
20 worse, from our perspective they're exactly identical,
21 they're both waste of a resources and that's just going
22 to be one of the -- one of areas in where, you know,
23 our mission which is to prevent waste and to protect
24 correlative rights and I think Kate Troll was blunt
25 about this in the beginning, doesn't really match up
Page 35
1 with
your
mission which
is
to stop climate
change.
2 They
both
work together
in
a certain sense,
but in a
3 certain sense they don't. And that's just something I
4 think was worth pointing out and maybe not.
5 COMMISSIONER FOERSTER: Well, let me just
6 add.....
7 CHAIRMAN FRENCH: Commissioner Foerster.
8 COMMISSIONER FOERSTER: .....this is
9 Commissioner Foerster. Although we don't make a
10 differentiation between venting and flaring, DEC does
11 so it is being regulated.
12 CHAIRMAN FRENCH: Next up is Lois Epstein.
13 Please come forward.
14 Thank you. We'll mark one of these for the
15 record. I'll try not to write on it.
16 Welcome to the Commission. You're -- we
17 obviously know who you are, but please raise your right
18 hand.
19 (Oath administered)
20 MS. EPSTEIN: Yes.
21 CHAIRMAN FRENCH: Please state your name,
22 spelling your last name if you would.
23 MS. EPSTEIN: Lois Epstein, L -O -I -S E -P -S -T -E-
24 I -N.
25 CHAIRMAN FRENCH: Thanks so much and the floor
1 is yours.
2 MS. EPSTEIN: Thank you.
3 LOIS EPSTEIN
4 called as a witness on behalf of the Wilderness
5 Society, testified as follows on:
C
DIRECT EXAMINATION
Page 36
7 MS. EPSTEIN: And thank you to the Commission
8 for holding this hearing on an important issue that
9 many believe has not received the attention it deserves
10 from AOGCC and the state of Alaska.
11 Again my name is Lois Epstein and I am an
12 Alaska licensed engineer with the Wilderness Society, a
13 national, nonprofit conservation organization.
14 The Wilderness Society scientists have worked
15 on conservation in the Alaskan Arctic since our
16 inception in the 1930s and the report I just handed you
17 entitled the State of Methane was put out by our
18 organization and it looks at a comparison of state
19 rules regarding waste gas and methane throughout the
20 country. It came out last month.
21 The first goal listed on the AOGCC website is
22 to quote, prevent waste of Alaska's oil and gas
23 resources, unquote. I and others are here today and
24 online to discuss the unnecessary waste of natural gas
25 from non -emergency flaring and venting.
I
Page 37
1 And just to
follow-up on Commissioner
2 Seamount's question
on venting
versus flaring I would
3 also like to add while flaring
would have less of an
4 impact from a climate change perspective it does
5 produce black carbon which is well known and well
6 recognized as a localized warming impact when it is
7 deposited on ice and snow. So it does have impacts in
8 Alaska localized.
9 So as you know AOGCC has statutory and
10 regulatory requirements to prevent release or burning
11 of gas other than incidental de minimis venting and gas
12 released or burned under 20 AAC 25.235(d)'s listed
13 exceptions.
14 Our primary questions today and then following
15 those questions I'll talk about what our ask is, is the
16 public would like to know what AOGCC is doing to
17 analyze form 10-422, flaring and venting reports to
18 determine if there should be enforcement actions
19 against certain operators for wasted gas resources.
20 Number 2, has AOGCC spot checked any operator's reports
21 to see if their claims of an exception are legitimate.
22 And three, a question about whether there have been any
23 enforcement actions for waste gas in the Arctic or Cook
24 Inlet over the past 10 years. If yes, what are the
25 details of those enforcement actions.
Page 38
1 As
the
Commissioners
know the
federal
2 government
has
reissued the
Bureau of
Land Management's
3 waste gas
rule
and it plans
to reissue
EPA's role to
4 reduce methane releases from new, modified and
5 reconstructed wells. The Trump Administration's
6 approach with these new rules is to limit the federal
7 role on the waste gas issue and defer to states. Of
8 course that means that AOGCC's actions on this issue
9 have become even more important than -- than
10 previously.
11 Based on the information in the report I
12 distributed it's clear that Alaska's behind other oil
13 and gas producing states in many regulatory areas
14 associated with waste gas including for example there's
15 a lack of a venting prohibition. If you want to refer
16 to the chart on page 4 you'll see that that's one of
17 the areas where we are behind.
18 The lack of several state regulatory standards
19 in Alaska addressing waste gas combined with the
20 seeming lack of enforcement resources and I'd be happy
21 to learn that our observations don't have a basis, but
22 I closely follow this industry and how it's covered by
23 the media so I think there is a seeming lack of
24 enforcement spent on this issue and want to emphasize
25 that that appears to be troubling.
Page 39
1 So as a request we ask that AOGCC consider
2 pursuing one or more high profile enforcement actions
3 against operators who are not meeting the state's
4 existing regulatory requirements. Additionally we urge
5 you to upgrade the state's regulatory standards
6 addressing waste gas so Alaska is no longer a laggard
7 and meets the level of a leader state such as Colorado.
8 We often hear from Alaska's elected officials
9 that the state has the quote, unquote best or the
10 quote, unquote highest environmental standards.
11 Because AOGCC has allowed the state to fall behind on
12 waste gas enforcement and regulations that appears not
13 to be the case at this time.
14 So thank you very much for taking these
15 comments into consideration and I welcome further
16 discussions with the Commissioners and with staff on
17 this issue.
18 COMMISSIONER FOERSTER: I have a comment.
19 CHAIRMAN FRENCH: Commissioner Foerster.
20 COMMISSIONER FOERSTER: Lois, I heard you ask
21 some -- make some what sounded like public records
22 request in your testimony. And I don't want your
23 request to go unanswered, but this isn't the forum to
24 make a public records request so if you really want
25 that data, make a public records request for it, okay?
I
Page 40
1 MS. EPSTEIN: Yeah, that's an excellent
2 suggestion. You know, when we were putting together
3 testimony it became clear that there were a number of
4 questions that needed to be followed up on so I will do
5 that.
6 Thank you.
7 COMMISSIONER FOERSTER: Yeah. And I'm not
8 trying to be snarky.
9 MS. EPSTEIN: Sure.
10 COMMISSIONER FOERSTER: I -- everyone has
11 probably seen me be snarky before, but I'm really
12 trying just to help you and the rest of the people that
13 are concerned get their questions answered. And
14 there's a way to do it and that's probably the best
15 way.
16 CHAIRMAN FRENCH: Commissioner Seamount.
17 COMMISSIONER SEAMOUNT: Ms. Epstein, on page 4
18 you have a table that shows how the states stack up.
19 And I noticed North Dakota is pretty high ranked
20 although at one point in the last few years they were
21 flaring over 40 percent of the gas that was produced.
22 Have they changed their regulations recently to give
23 them these higher marks?
24 MS. EPSTEIN: They have. Actually there's.....
25 COMMISSIONER SEAMOUNT: Okay.
Page 41
1 MS. EPSTEIN: .....quite a bit of pressure for
2 what -- the releases come out of North Dakota. And I
3 suspect New Mexico now is beginning to address their
4 releases as well. That's what I've been hearing from
5 colleagues.
6 COMMISSIONER SEAMOUNT: I'll have to take a
7 look at North Dakota's regulations. I didn't know they
8 were doing so well although I don't know if they've
9 improved their percentage of waste gas any, but at
10 least they're trying to do something about it.
11 MS. EPSTEIN: Yes, I agree.
12 CHAIRMAN FRENCH: Maybe just one legal
13 quibbling question or something along those lines. On
14 page 6 you've got a page for Alaska. Under current
15 state requirements on page 6 it says there's no
16 prohibition on venting gas. But isn't that the same
17 thing as releasing gas into the air, isn't that -- I
18 mean, is that what we -- isn't that what our statute
19 says or reg says?
20 MS. EPSTEIN: So the basis.....
21 CHAIRMAN FRENCH: I mean, do you guys see it
22 differently or am I.....
23 MS. EPSTEIN: Well, I can tell you where that
24 came from. So a colleague looked at the regulations, I
25 reviewed their responses.....
Page 42
1 CHAIRMAN FRENCH: Uh-huh.
2 MS. EPSTEIN: .....and because it is allowable
3 to.report flaring and venting on form 10-442.....
4 CHAIRMAN FRENCH: Uh-huh.
5 MS. EPSTEIN: .....there is not a prohibition
6 on flaring and venting. It is allowable to -- other
7 states actually prohibit it and require everything to
8 be flared.....
9 CHAIRMAN FRENCH: Uh-huh.
10 MS. EPSTEIN: .....and don't -- don't allow any
11 venting. We allow it at least for an hour.
12 COMMISSIONER SEAMOUNT: Well, I had another
13 question then. On this table on page 4 are we talking
14 about equivalent agencies to the AOGCC or are we
15 talking about all agencies that have anything to do
16 with flaring?
17 MS. EPSTEIN: Right. It's a good question and
18 it gets to Commissioner Foerster's point that DEC has
19 some role.
20 COMMISSIONER SEAMOUNT: Yeah.
21 MS. EPSTEIN: So the best way to look at the
22 flaring issue is holistically. So it certainly
23 includes the equivalent of oil and gas conservation
24 commissions in other states, but it does -- sometimes
25 states are organized differently and it would include
Page 4 3 1
1 some other agencies.
2 COMMISSIONER FOERSTER: So it does include
3 other agencies?
4 MS. EPSTEIN: I believe so.
5 CHAIRMAN FRENCH: So in this case it might be
6 AOGCC plus DEC?
7 MS. EPSTEIN: Right.
8 CHAIRMAN FRENCH: Okay. Other questions for
9 Ms. Epstein?
10 (No comments)
11 CHAIRMAN FRENCH: Thanks so much for being here
12 today.
13 MS. EPSTEIN: Thank you all.
14 CHAIRMAN FRENCH: Last person signed up to
15 testify is Kara Moriarty. Please come forward.
16 Another person well known to the Commission.
17 If you would raise your right hand.
18 (Oath administered)
19 MS. MORIARTY: I do.
20 CHAIRMAN FRENCH: Please state your name,
21 spelling your last name.
22 MS. MORIARTY. Thank you. For the record my
23 name is Kara Moriarty. You spell my last name M -O -R -I-
24 A -R -T -Y.
25 CHAIRMAN FRENCH: Thank you.
2 AK M-1473
11
KARA MORIARTY
Page 44
2 called as a witness on behalf of AOGA, testified as
3 follows on:
4 DIRECT EXAMINATION
5 MS. MORIARTY: As Commissioner French said I am
6 well known here, I don't know if that means I'm getting
7 old, Commissioner, or if it just means I've been at
8 AOGA for a while. But I am the president and CEO of
9 the Alaska Oil and Gas Association commonly referred to
10 as AOGA. And I appreciate the opportunity to provide
11 some brief comments regarding the petition in front of
12 us today.
13 As you know the Alaska Oil and Gas Association
14 is the professional trade association for the oil and
15 gas industry, representing the majority of oil and gas
16 exploration, production, refining and transportation
17 companies in Alaska. We do oppose the petition before
18 you and we do support your current -- AOGCC's current
19 regulations regarding venting and flaring. And I'm
20 going to take a few minutes to explain our position.
21 Ms. Troll's petition seeks to prevent all non -
22 emergency venting and flaring, a suggestion which we
23 believe is not only impractical, but more importantly
24 it's unsafe. As Ms. Troll mentioned, the -- she
25 mentioned that and in the petition it mentions that
Page 45
1 this recommendation to prevent all non -emergency
2 venting and flaring was unanimously supported by
3 Governor Palin's Mitigation Advisory Group. I was not
4 an industry representative of that group 10 years ago
5 so I went back to the technical group recommendation.
6 Several of the industry representatives that were part
7 of the advisory group back then as well as the
8 technical group have retired. There are still a few in
9 industry and some working outside of Alaska and some
10 here in the state. But I went through the report and
11 the recommendations.
12 There is a full report as well as a technical
13 group report and nowhere in the technical group report
14 or the full report does it say that we -- that the
15 industry supported all non -emergency venting and
16 flaring should be prevented. You can find the oil and
17 gas recommendations on pages 19 through 22 of the
18 advisory report which I found online. And if you will
19 allow me to read, Mr. Chairman. On page 20 it says the
20 technical work group which is TWG examined
21 conservation, reduction of fugitive methane emissions,
22 centralized electrification of North Slope operations,
23 upgrades in efficiency of fossil fuel consuming
24 equipment, renewable energy substitutes for fossil fuel
25 energy and carbon capture. It went on to say in
i
Page 46
1 quantifying the options it became clear that besides
2 conservation most of the recommendations would be very
3 expensive to implement and have other attendant issues
4 that need to be resolved prior to implementation. What
5 these recommendations represent is a suite of the best
6 opportunity to reduce greenhouse gas emissions from oil
7 and gas sector operations, but that does not mean they
8 are cheap, easy or ready to implement, rather the
9 investigation within this report recommends the areas
10 for further study.
11 So further I just think it's also important to
12 note that reduction of fugitive and wet seal emissions
13 which is what Governor Palin's Mitigation Advisory
14 Group actually recommended, is not the same as the
15 elimination of all non -emergency venting and flaring.
16 Just briefly and we can get further experts to
17 testify to this, but fugitive and wet fuel emissions
18 are disbursed around the field where flaring emissions
19 come only from a flare stack with always burning pilot
20 gas. I think it's also important to note there is a
21 suggestion that the industry is fully on -board with
22 reducing methane emissions and we are, we are very
23 concerned about the environment and our climate and
24 we're actually the leaders in technology and
25 development of ways to reduce emissions. And in fact
5 Back to the proposal to prevent all non -
6 emergency venting and flaring, as a best management
7 practice oil and gas operators use all reasonable
8 precautions to prevent the waste of oil and gas
9 resources. However the venting or flaring of some
10 natural gas is practically an unavoidable consequence
11 of oil and gas development. And I think I heard one of
12 you say it's necessary for safe operations. So let me
13 give you a couple examples. During routine operations
14 including, but not limited to, well drilling,
15 production testing and/or well purging, some gas that
16 reaches the surface cannot be feasibly captured, used
17 or sold. When this occurs the gas must either be
18 combusted or released to the atmosphere. During normal
19 production operations as well volumes fluctuate or if
20 there is an equipment failure, the production facility
21 needs to have a safe place for all the excess volume of
22 gas to be immediately relieved. Routine and continuous
23 flaring of pilot and purged gas during non -emergency
24 situations is a key component to the safe development
25 of oil and gas reserves. Pilot and purged gas is
Page 47
1 since 2005 there has been a
17 percent
reduction in
2 greenhouse gas emissions by
industry in
Alaska. And
3 that's from the most recent
DEC report
that has already
4 been referenced.
5 Back to the proposal to prevent all non -
6 emergency venting and flaring, as a best management
7 practice oil and gas operators use all reasonable
8 precautions to prevent the waste of oil and gas
9 resources. However the venting or flaring of some
10 natural gas is practically an unavoidable consequence
11 of oil and gas development. And I think I heard one of
12 you say it's necessary for safe operations. So let me
13 give you a couple examples. During routine operations
14 including, but not limited to, well drilling,
15 production testing and/or well purging, some gas that
16 reaches the surface cannot be feasibly captured, used
17 or sold. When this occurs the gas must either be
18 combusted or released to the atmosphere. During normal
19 production operations as well volumes fluctuate or if
20 there is an equipment failure, the production facility
21 needs to have a safe place for all the excess volume of
22 gas to be immediately relieved. Routine and continuous
23 flaring of pilot and purged gas during non -emergency
24 situations is a key component to the safe development
25 of oil and gas reserves. Pilot and purged gas is
I
Page 48
1 continuously flared as part of the facility's safety
2 design to safely ignite excess gas brought to surface
3 of course during emergency situations such as processes
4 that -- equipment failures and emergency shutdown.
5 Flare systems are designed to API standards to maximize
6 facility safety and minimize flare gas volume.
7 As has already been mentioned AOGCC is not the
8 only agency in Alaska that regulates this. Flaring,
9 venting and fugitive emissions by our industry are
10 currently regulated not only by this agency, but also
11 the Alaska Department of Environmental Conservation,
12 the Environmental Protection Agency and the Bureau of
13 Land Management on federal land. The combination of
14 these regulations ensure that all flaring or venting
15 operations are done safely with minimal waste of
16 resources.
17 So as I mentioned we do currently support your
18 regulation in its current form and we do strive to
19 reduce our emissions, but any proposal needs to take
20 into consideration several factors and for us safety is
21 always paramount. And unfortunately this proposal
22 would make oil and gas operations in Alaska unsafe.
23 Thank you. And I'm happy to answer any
24 questions that you might have.
25 CHAIRMAN FRENCH: Questions for Ms. Moriarty?
Page 4 9 1
1 COMMISSIONER FOERSTER: I have none.
2 COMMISSIONER SEAMOUNT: I have none. Thank
3 you, Mr. Moriarty.
4 CHAIRMAN FRENCH: Likewise. Thanks so much for
5 appearing here today.
6 Is there anyone else in the room here today who
7 wishes to testify?
8 (No comments)
9 CHAIRMAN FRENCH: Is there anyone else online
10 who wishes to testify?
11 (No comments)
12 CHAIRMAN FRENCH: With that we'll get ready to
13 close the hearing. We'll keep the record open until
14 5:00 o'clock this afternoon if anyone else wants to
15 submit something. There were several mentions made of
16 the report done by the Governor Palin group. If
17 someone wants to forward that to us that -- we'll make
18 that part of the record. I don't have a copy and many
19 people referred to it and I'd be happy to review it
20 and, you know, we'll make it part of the record.
21 Commissioner Foerster.
22 COMMISSIONER FOERSTER: Typically at the end of
23 a hearing we know what we're supposed to make a
24 decision on and I'm unclear as to if there is a
25 decision that needs to be made. So I'm uncomfortable
6 anything about
this
Page 50
1 closing a hearing when I
don't know how -- what
action
2 I'm going to take on the
information that I received.
quorum
3 CHAIRMAN FRENCH:
Well, I guess I would
say
4 that we'll take the matter
under advisement and
the
5 three of us will confer
and we'll see if there's
6 anything about
this
hearing that
causes
two of us to
7 agree and if we
do
that'll make a
quorum
and we can go
8 forward. I understand -- I agree with your -- some
9 degree of your perplexity if that's a word, you know,
10 at some level I think we're being asked to just check
11 ourselves and make sure we're doing as good a job as
12 possible and generally when you ask that question
13 people say, yeah, we're doing a great job. On the
14 other hand as the -- looking at some of the records and
15 reviewed some of the requests it appears that there are
16 at least some questions we can answer or, you know,
17 maybe try to make our website more accessible, make the
18 conversation factors easier to understand.....
19 COMMISSIONER FOERSTER: That's not reaching a
20 decision.
21 CHAIRMAN FRENCH: .....things like that. See
22 so far we don't have any agreement. So it may be that
23 we don't get very far.
24 But is there anything else to come before the
25 Commission?
f
Page 51 1
1 COMMISSIONER SEAMOUNT: I have a request.
2 CHAIRMAN FRENCH: Commissioner Seamount.
3 COMMISSIONER SEAMOUNT: Ms. Epstein, you stated
4 or you listed a series of questions and I would like to
5 ask you if -- to compare them with the questions that
6 Ms. Smith had and if there's extra questions in there
7 let us know or if it's total overlap it's fine.
8 CHAIRMAN FRENCH: We'll keep the record open
9 until 5:00 o'clock.
10 With that at 11:05 we're adjourned.
11 (Off record)
12 (END OF REQUESTED PORTION)
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f
Page 52
TRANSCRIBER'S CERTIFICATE
I, Salena A. Hile, hereby certify that the
foregoing pages numbered 02 through 52 are a true,
accurate, and complete transcript of proceedings in
Docket No.: OTH 18-057, transcribed under my direction
from a copy of an electronic sound recording to the
best of our knowledge and ability.
DATE
SALENA A. HILE, (Transcriber)
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
Docket OTH-18-057
December 18, 2018 at 10:00 a.m.
NAME AFFILIATION Testifv (yes or no)
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NAME AFFILIATION Testify (ves or no)
3
ECEVED
Alaska Oil & Gas Conservation Commission
December 18, 2018 Hearing DEC 17 2018
Written comments submitted to: Samantha.Carlisle@alaska.gov
Call in: 1-800-315-6338 access code 14331 AOGCC
Comments submitted by Ceal Smith
Alaska Climate Action Network
Eagle River, AK
ceal@akclimateaction.org
I'm speaking today on behalf of the Alaska Climate Action Network, a statewide
grassroots network of scientists, policy and renewable energy experts, partner groups
and Alaskans from all walks of life who are worried about the increasingly dangerous
and costly impacts of climate change, especially in rural Alaska.
• 1 would also like to thank the Commissioners French, Foerster and Seamount for
granting this hearing in response to Kate Troll's request and the 48 Alaskan's who
signed the petition at our Climate, Jobs & Justice rally in Anchorage on Sept 81h
a Since then, nearly 300 more Alaskan's have joined in our appeal to the AOGCC
Commission to do everything in your power to reduce Alaska's GHG emissions (petition
attached).
1 won't repeat what others have already spoken to, but I would like to address Kate
Troll's question: "What is the track record for full compliance?"
On November 18th Kristen Nelson reported in the Petroleum News' that:
1. The commission revised its flaring regulations effective Jan. 1, 1995. "The goal of
the flaring oversight program is the elimination of unnecessary flaring
whenever possible, and
2. The commission's current regulations allow no gas release except for up_to
an hour for emergencies or operational upsets or for planned lease
operations authorized for safety; to purge or test a safety flare system; and de
minimus venting incidental to normal operations. The regulations also say the
commission can authorize flaring for more than an hour under specific
circumstances."
We looked at the data, and here is what we found (disclaimer: we are not OG experts):
o First, according to the 2018 Alaska Greenhouse Gas Emissions Inventory
Reportz that "describes and quantifies human -caused sources of greenhouse gas
(GHG) emissions occurring between 1990 and 2015 from Alaska operations and
facilities" the oil and gas industry contributed an average of 52% of Alaska's total
GHG emissions equal to 44.5 million metric tons of carbon dioxide equivalents
' Petroleum News, AOGCC receives petition on gas flaring,
http://www,petroleumnews.com/pdfarch/319393447.pdf#page=9
' https://dec.alaska.gov/commish/press-releases/20187 dec-releases-updated-alaska-greenhouse-gas-em!ssions-
inventory-report/
(MMT CO2e)/per year or a cumulative total of 552 million metric tons of carbon
dioxide equivalents.
Based on these figures, between 1990 and 2015, average annual emissions from
the oil and gas sector was 23.22 million metric tons of carbon dioxide equivalents
(MMT CO2e) (range: 20.26/2010 — 27.02/2005). That's equivalent t03:
0 5 million passenger cars/year
0 53.5 million barrels of oil/year, or 17% of California's total annual (320
MBO/year)
0 3 million average U.S. household electricity use
Industrial
x0.67
26.33
27.02
20.26
22.67
2137
77.13
10.99
22.35
Coal/Coal mining
0.026
0,026
0.024
0.038
0.045
0.038
0.029
0.028
0.022
Natural Gas/ Natural Gas
Induslty
13.95
18.70
19.13
14.12
14,00
14.44
14.24
14.30
14.94
petroleum/Oil Industry
1090
760
786
6.10
8.63
7119
7.86
6.66
7.39
Then we looked at data obtained directly from AOGCC. Between January 2012 and
Feb, 2017 industry:
Flared = 17,374,472 million cublic feet (McF) of gas or just short of 3 million
cubic feet (2,895,745 McF)/year, including:
1,468 releases greater than > 1 hour
• Cumulative total of 12,742,668 McF (or 12.7 Billion cubic feet) of gas'
Range:
• 747,534 McF in Pt. Thomson Exp on Apr 16, 2016 to
• 1 Mcf at Ninilchik Falls Creek on July 1 sl, 2017.
34 releases exceeded 100,000 McF including:
• 3 from Pt. Thompson including the release just mentioned,
• 9 from Prudhoe Bay Gathering Center 1
• 3 from PBU GC2
• 8 from PBU CGF B, and
• 9 from Northstar. and
• 1 from PBU GC3 (see Table 1 below).
`NOTE: 1 million metric tons of carbon dioxide equivalent = 216,000 passenger carstyear
3 https://www.arb.ca.gov/cc/factsheets/lmmtconversion.pdf
2
• As quoted in Petroleum News above and according to rule 20 AAC 25.235:
• Section(d): Gas released, burned, or permitted to escape into the air constitutes
waste, except that (1) flaring or venting gas for a period not exceeding one hour
as the result of an emergency or operational upset is authorized for safety;
We haven't yet received all the documents requested in our Public Information Request,
so we were unable to compare the gas disposition report form's 10-422 (FACILITY
REPORT OF PRODUCED GAS DISPOSITION) against the Xcel spread sheet data to
determine if these were authorized releases. Even if we had as a small nonprofit,
dependent on volunteers, we don't have the expertise or capacity to do the analysis (and
we might well be off in the above calculation!). So in the end, we are left with more
questions than answers, including:
• Do these SUBSTANTIAL emissions fall under authorized emergency and normal
operations and maintenance, or is something else going on?
• In addition to the 1400+ releases greater than hour, we did not see where
industry reports vented gas (presumably pure methane). The state GHG report
(page 21) notes that:
• In 2015, the industrial sector produced over half of Alaska's GHG
emissions. Fugitive methane contributed over 19% of the CO2e emitted
by this sector in 2015. Most of the fugitive methane comes from oil
production; a small portion comes from natural gas production.
• Thus, how does the AOGCC track the more powerful methane GHG?
• Additionally, we'd like to know how AOGCC data feeds into the state calculations
of total GHG emissions, as required by the Federal Greenhouse Gas Reporting
Rule? (we're essentially trying to relate the GHG report to industry disposition
data),
A
H
C
L,
L
I
G
li
1
J
1
Y --I
BptDat•l
i11t9N4 j
Fsclllty1-A14-I
1S 11–a
1d–
FlareG
1 j -1i
2
2016
01 -Apr -16
890000001
Pt Thom— Explotatlon
O
IIHSJS
O
101081
747534
O
3
2014
01 -Feb -14
290000032
PBU GC
0
112300
0
O
436111
9722
4
2012
014ul-12
290000031
PBU GCI
O
112300
O
O
395787
250
5
2012
014..-12
290000031
PBU GC I
0
112300
0
0
362033
2020
6
2013
01 -Apr -13
290000031
PBU GC 1
0
112300
0
0
360310
1862
7
2016
01 -Apr -16
290000008
PBUCGFB
O
112300
1000976
4EM6
313559
163592
8
2016
014un-16
890000001
Pt Th.M.. Eapl.,.I..
0
118575
O
44561
263807
17836
9
2016
01-0 t-16
890000001
Pt Thoma n Exploratlon
0
118575
0
722459
247420
3519
10
2012
01-5ep-12
290000031
PBU GC 1
0
112300
0
0
219885
9820
11
2013
01-M r-13
290000031
PBU GCI
0
112300
0
0
194364
0
12
2012
Olfeb-12
290000025
NorthRar
0
112300
O
IEM7
152691
0
13
2014
01-Au8-14
290000008
PBUCGFB
0
112300
523153
2EM6
143496
12008
14
2016
01 -Mar -16
290000008
PBUCGFB
0
112300
1501945
SEM6
135998
10430
15
2014
01-0t-14
290000008
PBUCGFB
0
112300
1491944
7EW6
134503
3638
16
2016
01 -Dec -16
290000008
PBUCGFB
0
112300
1645424
7EM6
126101
21864
SJ
2013
014eb-13
290000008
PBUCGFB
0
112300
1723259
6EM6
124369
1703
18
2016
01-N.46
290000033
PBU GC
O
112300
0
O
118507
0
19
2013
01 -Feb -13
290000031
PBU GCI
O
112300
0
0
116131
5481
20
2012
014eb-12
290000032
PBU GC
O
112300
0
0
116111
8785
21
2017
01-Ju1-17
290000008
PBUCGFB
0
112300
950008
4EM6
115459
15406
22
2013
01 -Jan -13
290000031
PBU GC 1
O
112300
O
O
112292
4967
23
2013
01-N -13
290000031
PBU GC
O
112300
0
O
111914
800
24
2013
01Oct-13
290000031
PBU GC 1
O
112300
0
O
111355
880
25
2012
014Nay-12
290000025
Nortlrtar
O
112300
0
1EM7
107247
0
26
2012
01-0 -12
290000025
Nortbrtar
O
112300
0
1EM7
105582
0
271
2012
OS -Mar -12
290000025
Nortbrtar
O
112300
0
1EM7
104734
O
28
2013
01 -Jan -13
290000025
Nortbrtar
O
112300
O
XEM7
104310
0
29
2017
01 -Mar -17
290000008
PBUCGFB
0
112300
1683032
7EM6
103982
387
30
2012
01- .o -12
290000025
Nortbrtar
0
112300
0
1EM7
102553
O
31
2012
01 -Dec -12
290000025
Nortbrtar
0
112300
0
1EM7
102246
0
32
2016
01 -Nov -16
290000031
PBUGCI
0
112300
0
0
101473
.984
33
2012
01 -Jul -12
290000025
Northrtar
0
112300
0
IEM7
101271
0
34
2012
01 -Apr -12
290000025
Nortbrtar
0
112300
0
IEM7
101004
0
35
2016
01 -Apr -16
290000032
PBUGC2
O
112300
0
0
98203
41667
Table 1: Releases exceeding 100,000 Mcf of flared
gas, from AOGCC data
• As quoted in Petroleum News above and according to rule 20 AAC 25.235:
• Section(d): Gas released, burned, or permitted to escape into the air constitutes
waste, except that (1) flaring or venting gas for a period not exceeding one hour
as the result of an emergency or operational upset is authorized for safety;
We haven't yet received all the documents requested in our Public Information Request,
so we were unable to compare the gas disposition report form's 10-422 (FACILITY
REPORT OF PRODUCED GAS DISPOSITION) against the Xcel spread sheet data to
determine if these were authorized releases. Even if we had as a small nonprofit,
dependent on volunteers, we don't have the expertise or capacity to do the analysis (and
we might well be off in the above calculation!). So in the end, we are left with more
questions than answers, including:
• Do these SUBSTANTIAL emissions fall under authorized emergency and normal
operations and maintenance, or is something else going on?
• In addition to the 1400+ releases greater than hour, we did not see where
industry reports vented gas (presumably pure methane). The state GHG report
(page 21) notes that:
• In 2015, the industrial sector produced over half of Alaska's GHG
emissions. Fugitive methane contributed over 19% of the CO2e emitted
by this sector in 2015. Most of the fugitive methane comes from oil
production; a small portion comes from natural gas production.
• Thus, how does the AOGCC track the more powerful methane GHG?
• Additionally, we'd like to know how AOGCC data feeds into the state calculations
of total GHG emissions, as required by the Federal Greenhouse Gas Reporting
Rule? (we're essentially trying to relate the GHG report to industry disposition
data),
We would very much appreciate answers to these questions!
It's important to note that these GHG emissions carry with them a whole suite of hazardous
pollutants, including volatile organic compounds that have serious direct and indirect community
and environmental health impacts4, including cancer, neurological, developmental and
reproductive effects and the capacity to disrupt critical endocrine hormones.
In closing, as Bjorn Olsen with Alaskans Know Climate Change and I wrote in a recent OoEd5
(and it deserves repeating): "our civilization has little more than a decade to rein in greenhouse
gas emissions or face a series of cascading ecosystem and economic collapses". We urge you,
as our duly appointed and trusted AOGCC commissioners, to do absolutely everything in your
power to reduce waste, in the form of dangerous greenhouse gas emissions.
We are the front lines of climate change; let's get on the front lines of being the solution to
climate change.
Thank you,
Ceal Smith
..................................................................................
References
STATE OF ALASKA
http7//doa.alaska.gov/``o-gc/forms/10-422.pdf
° https://www.ncbi.nim.nih.gov/pmc/articles/PMC6069077/
5 https://www.adn.com/opinions/2018/12/16/alaska-has-climate-
solutions/?fbclid=lWAROXrfWAkAeo2v36Tlgenl baQU11BFxxH1PlFCMWTEAOdB1aGE1DgQUn1U#8046
The biggest emitters are the Prudhoe Bay Unit Gathering and Flow Stations, but Cook Inlet is
also a significant contributor.
In 2012: Prudhoe Bay Unit/Gathering Center 1*, 2, Flow Station6 (FS) 1, 3 and Beluga River
,,WO.MO
'memo
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em em em am FT a ` a" v ex T`' P' ca �y e ° aa'
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In 2013: Prudhoe Bay Unit GC 1, Northstar, Beluga River, Prudhoe Bay GC3
, q.O
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..aoo III
O.• -------------------------------------
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4T P°
- M_ I _ --
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•Pore' ln,
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In 2014 (1 million/million
,mom°
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< a a^' �°° � t� `o � F,dp{+eoe�4 �sym''m„� vi o-°�F " °` .r'�se` �5®tea 3" "'a; s'a°•a `a,F'.ri �,` .s �+'`'>
2015
----1------------ L
I
'm'Y°„- oa`„r• .t`� z a= .F` ^�aa` °°s�•yN,,fi` c an y €` °'" 'ell
6 Fact Sheet Gathering Centers, Flow Stations, https://www.bp.com/content/dam/bp-
country/en_us/PDF/alaska_separation_facilities_fact_sheet. pdf
2016
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¢:'` ¢ Vic` °¢ bb �¢P�e gra•' +E�.°" a�c,� p.Y� cT P ^¢2•x¢° +°$ bPA d ��¢ �> X58 pd¢;.�� °` P� 3°j
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Precedence/Case history (from the 50 -report):
•FlareaAr
•Flarec lhr
•F014:: r
•Flam<N�
"In 1970 alone, nine billion cubic feet of gas were flared from just one Cook Inlet oilfield, Granite
Point," "It was a huge amount of energy just going up in smoke," recalls Norman, who is
currently a Commissioner of the AOGCC.
The public [then, as now] was solidly on the side of the Commission. The gas flares could be
seen from Anchorage on a clear night, and they became symbols of what the public considered
to be wasteful practices.
In 1971, following extensive hearings, the Commission ordered an end to the wasteful flaring of
gas produced along with oil from Cook Inlet platforms, except for what was needed for safety
flares on the platforms. The Alaska Superior Court upheld the authority of the AOGCC in its
action to prevent waste? and (according to the 50 -year "Our resources Our past Our future"
report8). The Commission's ban on gas flaring was extended to Prudhoe Bay when this
giant North Slope field began production in 1977.
Any gas flared after the order, except for the safety flare, was determined to constitute "waste"
of the natural gas resource and was prohibited.
http://doa.alaska.gov/ogc/AboutUs/5Oth/aogcc5OthBooklet.pdf
ahttp://doa.alaska.gov/ogc/AboutUs/50th/aogcc5OthBooklet.pdf
'The companies didn't want to stop flaring. They claimed there was no market for the gas and
that it had no value." But when forced to do so, the producers did find ways to use the gas
beneficially
Applicable Statutes and Rules
§AS 31.05.027 gives AOGCC authority over all land in the state of Alaska lawfully subject to its
police powers, including Federal lands,
§AS 31.05.095 clearly states, "the waste of oil and gas in the state is prohibited",
§AS 31.05.170(15) defines "waste" in addition to its ordinary meaning, "physical waste" and
includes the inefficient, excessive, or improper use of, or unnecessary dissipation of, reservoir
energy; and the locating, spacing, drilling, equipping, operating or producing of any oil or gas
well in a manner which results or tends to result in reducing the quantity of oil or gas to be
recovered from a pool in this state under operations conducted in accordance with good oil field
engineering practices; the inefficient above-ground storage of oil; and the locating, spacing,
drilling, equipping, operating or producing of an oil or gas well in a manner causing, or tending
to cause, unnecessary or excessive surface loss or destruction of oil or gas; and other
producing oil or gas in a manner causing unnecessary water channeling or coning; the
operation of an oil well with an inefficient gas-oil ratio; the drowning with water of a pool or part
of a pool capable of producing oil or gas; underground waste; the creation of unnecessary fire
hazards; the release, burning, or escape into the open air of gas, from a well producing oil or
gas; the use of gas for the manufacture of carbon black; and the drilling of wells unnecessary to
carry out the purpose or intent of this chapter; and
20 ACC 25.235. Gas disposition. (a) For each production facility the operator shall compile
and report monthly gas disposition and acquisition on the Facility Report of Produced
Gas Disposition (Form 10-422). If a facility's production comes from multiple pools, the
operator shall allocate production between each producing pool as a percentage of the total
volume of gas that the facility handled for the month. The operator shall report gas acquisition or
disposition by category, as follows:
(1) gas sold;
(2) gas reinjected;
(3) gas flared or vented` (form only includes flared);
(4) gas used for lease operations other than flaring or venting;
(5) natural gas liquids (NGLs) produced;
(6) gas purchased;
(7) gas transferred;
(8) other.
(b) Any release, burning, or escape into the air of gas other than incidental de minimis venting
as authorized under (d)(4) of this section must be reported as flared or vented on the Facility
Report of Produced Gas Disposition (Form 10-422). The operator shall submit a written
suooiement for any flaring or venting incident exceeding one hour. The supplement must
describe why the gas was flared or vented, list the beginning and ending time of the flaring or
venting, report the volume of gas flared or vented, and describe actions taken to comply with (c)
of this section.
7
(c) The operator shall take action in accordance with good oil field engineering practices and
conservation purposes to minimize the volume of gas released, burned, or permitted to escape
into the air.
(d) Gas released, burned, or permitted to escape into the air constitutes waste, except that
(1) flaring or venting gas for a period not exceeding one hour as the result of an
emergency or operational upset is authorized for safety;
(2) flaring or venting gas for a period not exceeding one hour as the result of a planned
lease operation is authorized for safety;
(3) flaring pilot or purge gas to test or fuel the safety flare system is authorized for
safety;
(4) de minimis* venting of gas incidental to normal oil field operations is authorized;
(5) within 90 days after receipt of the report required under (b) of this section, the
commission will, in its discretion, authorize the flaring or venting of gas for a period
exceeding one hour
(A) if the flaring or venting is necessary for facility operations, repairs, upgrades,
or testing procedures;
(B) if an emergency that threatens life or property requires the flaring or venting,
unless failure to operate in a safe and skillful manner causes the emergency; or
(C) if the flaring or venting is necessary to prevent loss of ultimate recovery;
(6) upon application, the commission will, in its discretion, authorize the flaring or venting
of gas for purposes of testing a well before regular production.
(e) Notwithstanding an authorization under
(d) of this section, the commission will, in its discretion, review flaring or venting
of gas and classify as waste any volume of gas flared or vented in violation of
(c) of this section.
(f) Notwithstanding conservation orders that the commission issued before
1/1 /95, this section applies to flaring or venting of gas that occurs on or after
1/1/95.
AlIK Alaska GNG Emissions Inventory
Exhibit 5 -Alaska Emissions by Sector with Total U.S. Emissions for Comparisons%
Industrial Processes 2000
Industrial Processes 1990
Waste Electrical Generation Waste
ElectricalGeneration h
i,Residential WResidential and CommCommercialCommandmercial
Ma,ine aaa_MarineOn-Road —On -Road '_ —,
Aviation
Industrial Processes 2005
Electrical Generattoi
Resldentlal and
Commercial
Marine
On -Road
Petroleum/
Oil Industry
Waste
Aviation Petrdeum/
011lndustry
Industrial 2015 Wage
Processes
Electrical Agriculture
Generation Coalxwl Mining
Residential
Commerci
Marine
O. -Road
Aviation
M clustrlal Processes 2010
Waste
Electr cal Generv�^^
Residential and
Commercial
Marine
On -Road
Mite
[e.mmo
a.w«ai
ufs
"kite...
ax
Petroleum/
011 Industry
Petroleum/
011 Industry
Aviation
Petroleum/ IqQIW
Oil Industry
I. xhura 5: Alaska diso'ibuuon of warrants is by swat with total (IS Greenhouse Gas Ernimiorn by Ecim a rue S'ertor Jar'
comparison. In the Alaska Enaction chores, the industrial senor has heeu divided Into nalum l0m/nutural gns Imhauy
and pet?olrann/oil industry, The trmnportunun sector has Inert divided into aviation, on -road, and maruie Total Its..
Greenlmose Gas E ... ho oto by Economic Sector in 2015 shows that the top GHG contributor tot avemge is the eketriciry
sector followed by Onnsporlarion and industry.
rr EPA: sources of Greenhouse Gas Emissions
1/30/2018
page 14
W
AVEC Alaska GHG Emissions Inventory
Exhibit 4 - Alaska's Greenhouse Gas Emissions by Sector and Fuel Type (MMT CO2e)
Solid Waste Management
1990
2000
2005
2010
2011
2012
2013
2014
2015
Electrical Generation
3A5
3.62
3.69
3.S1
3.64
3.61
3.11
3.35
3.38
Coal
OAS
0.78
0.57
0.56
0.56
059
0.55
0.93
1.03
Natural Gas
1.87
1.89
2.10
2.12
2.25
2.14
1.81
1.70
1.61
Petroleum
0.73
0.95
1.02
0.83
0.83
0.88
0.76
0.73
0.75
Residential and Commercial
436
5.27
4.90
5.02
4.60
451
4.07
3.90
4.25
Coal
0.77
0.90
0.77
0.94
0.92
0.90
0.87
0.81
0.83
Natural Gas
1.80
2.32
1.86
1.85
2.13
2.22
202
1.90
1.97
Petroleum
1.78
2.14
2.24
2.30
1.52
1.38
1.15
1.16
1.43
Wood (CH. and N20)
0.012
0.013
0.019
0.022
0.018
0.017
0.023
0.023
0.018
Industrial
24.87
2633
27A2
20.26
22.67
2237
22.13
2099
2235
Coal/Coal Mining
0.026
0.026
0.024
0.038
0.045
0.038
0.029
0.028
0.022
Natural Gas/ Natural Gas
Industry
13.95
18.70
19.13
14.12
14.00
14.44
14.24
14.30
14.94
Petroleum/Oil Indust
10.90
7.60
7.86
6.10
8.63
7.89
7.86
6.66
7.39
Transportatkin
11.18
1431
1737
13.36
11.41
11.10
10.70
9.90
30A2
Aviation
7.21
10.78
13.18
9.37
8.59
8.23
7.80
6.98
7.45
Marine
1.59
0.87
1.36
1.13
0.08
0.07
0.07
0.08
0.08
On -Road
2.33
2.62
2.75
2.81
2.67
2.72
2.76
2.79
2.83
Rail and Other
0.059
0.043
0.082
0.060
0.070
0.070
0.060
0.057
0.054
Industrial Processes
1.10
1.17
1.14
0.29
0.35
038
0.39
OAO
0.40
Ammonia Production
1.050
0.966
0.885
0.000
0.000
O.ODO
0.000
0.000
0.000
Urea Production
0.001
0.000
0.000
0.000
D.ODD
0.001
0.001
0.001
O.OD3
Limestone and Dolomite Use
OA00
0.010
0.007
0.000
0.000
O.ODD
0.000
0.000
0.000
Cement Manufacture
0.000
0.000
0.000
0.000
DOW
0.000
0.000
0.000
0.000
ODSSubaftutes (HFC, PFC)
0.001
0.169
0.224
0.264
0.337
0.350
0.360
0.373
0.373
Soda Ash(CDt)
0.006
0.006
0.006
0.005
0.005
0.005
0.005
0.005
0.005
Solid Waste Management
0,27
0.34
0.39
0.46
0.54
0.53
0.36
0.32
0.37
Wastewater Management
0.052
0.060
0.065
0.069
0.059
0.059
0.060
0.060
0.060
A rkuthre
OAS
0.05
0.07
0.08
0.07
OA7
0.07
0A8
0.08
Agricultural Soils
0.030
0.026
0.031
0.033
0.030
0.031
0.029
0.034
0.028
Enteric Fermentation
0.015
0.019
0.026
0.025
0.028
0.028
0.026
0.023
0.025
Manure Management
0.001
0.007
0.009
0.021
0.015
(K015
0.014
0.023
0.023
Gross Emistbm
44.93
51.16
54.64
_ 45.04
_ 43;34
42.63
_40,88
39.01
4L30 _
Net Em ssions 38A3 25.96 5994 20.67 13.69 13.14 17.51 s.1v aa.ao
Gross Increase Since 1990 (MMT) 0.00 6.23 9.71 -199 -1.59 -2.30 -4.05 -5.92 -3.63
Gross Increase since 19901%) 0% 14% 22% -4% .4% 3% .9% -13% 4%
Exhihit 4: The low level of eruission sink benefits m 2005 and 2015 is in part due to active wildfire seasons. Cont usage for
electrkalgeoeration increased from 1990 to 2015. geductiort in the percentage of marine transport emissions since 2010 is
related to exclusion of bulk fuel from calculations as the fuel is not burned in Alaska Production at Agrium USAbegan ro fall
beginning in 1001 Leading to a sharp dechne in emissions from industrial pmress in 2005 and 2006. Agrium US4 offkiagy
announced closure in late 2007
1/30/2018
page 13
10
DEr 17 2013
AOGCC
Petition to fully enforce & strengthen waste rules
to reduce Alaska's Greenhouse Gas Emissions
December 18, 2018
To: Hollis French, Chair and members of the Alaska Oil & Gas Conservation Commission
Dear Commissioners:
As you well know, Alaska is on the front lines of climate change that imminently threatens 87% of
Alaska Native communities.
The Alaska Oil and Gas Conservation Commission has the power to significantly slash the state's carbon
emissions simply by enforcing existing statutes (outlined below) that require industry to minimize waste,
i.e. largely methane, a greenhouse gas 30 times more powerful than CO2.
The Alaska Department of Environmental Conservation 1990-2015 Greenhouse Gas Inventory Report
concludes that more than half of Alaska's GHG emissions comes from the oil and gas sector. Of that,
fugitive methane from oil and gas production contributed over 19% of GHG emissions in 2015.
We urge you to direct staff of the Alaska Oil and Gas Conservation Commission to fully enforce and
strengthen existing statutes (§AS 31.05.027, AS 31.05.095, AS 31.05.170 and 20 ACC 25.235) requiring
Alaska's oil and gas industry to stop all non -emergency venting and flaring from Alaska oil and gas
wells. This single, but powerful step would reduce our total greenhouse gas emissions significantly and
send a clear message to industry, the nation and world that Alaska takes climate change seriously.
Methane (CH4) is a potent greenhouse gas (GHG) capable of trapping more than 25 times more solar
radiation than CO2 over a 100 -year period. According to your own data, the oil and gas industry flared
over 17 million cubic feet (McF) of GHG emissions between 2012 and 2017; an average of nearly 3
McF per year, roughly equivalent to 30% of the average annual demand of the Railbelt utility system.
Stopping flaring and venting of methane on the North Slope and Cook Inlet was unanimously supported
by the oil and gas industry representatives on Governor Palin's Mitigation Advisory Group in 2008 yet
no Alaska official has ever acted on this recommendation. With climate change now front and center in
all regions of Alaska, enforcing existing statutes is the low -hanging fruit for Alaska to take a giant step
in reducing harmful greenhouse gas emissions.
The latest International Panel on Climate Change (IPCC) report leaves no doubt; the window of
opportunity for averting climate catastrophe is shrinking. At best, we have twelve years to substantially
cut GHG emissions. Taking this definitive step today will not only vastly improve air quality in
impacted communities but it could reduce costs for industry and increase state revenue.
We urge you to use your authority as Chair and members of AOGCC to direct AOGCC staff to fully
address the egregious violations of Alaska State statutes regarding emissions of methane waste.
Sincerely,
1. Bob Shavelson, Homer, AK
2. Elisa Russ, Homer, AK. Please Governor Walker - this is something that you can leave as part
of your legacy before the new governor comes in and allows more pollution and corruption.
Thank you for doing the right thing. We have a moral obligation to take action and mitigate the
effects of climate change by reducing carbon emissions in order to ensure a healthy environment
for future generations.
3. Ceal Smith, Alaska Climate Action Network, Eagle River, AK
4. Scott Gruhn, Alaska Climate Action Network, Anchorage, AK. This is urgent. Every nation in
the world signed the Paris Agreement for a reason.
5. Rosemary Ahtuangaruak, Nuiqsut, AK. Cut emissions as much as you can I will take 50% but
push for more as this needs to be better. Protections for human health in California prevent more
than 10 flares a year. We have seen 30 or more in a night at Nuiqsut. Same issue human health
California and Alaska. Please protect us too.
6. Rick Steiner, Anchorage, AK. AOGCC has the authority and responsibility to act on this
request, and anything less than immediate and effective action would constitute litigable
negligence.
7. Bjorn Olson, Alaska Climate Action Network, Homer, AK. Please do not miss this opportunity
to curb Alaska's greenhouse gas emissions. Alaska, as you well know, is on the front lines of
climate change; requiring the oil and gas industry to minimize waste is low hanging fruit in our
global effort to avert climate chaos.
8. McKibben Jackinsky, Alaska Climate Action Network, Anchorage, AK
9. Bretwood Higman, Soldovia, AK. There's a lot of low -hanging fruit out there to mitigate
climate change - things that might give us a little more time to make deeper systemic changes
before cataclysmic effects set in. Reducing methane flaring and leakage is high on this list!
10. Elizabeth Roderick, Anchorage, AK
11. Martha Itta, Nuiqsut, AK. Please Help to stop them from contaminating our water, our food,
and most of all quit killing us!
12. Eunice Brower, Nuiqsut, AK. Please start enforcing existing waste statues in and around
Nuiqsut, Alaska. Protect the people, wildlife, and vegetation from so many toxins that are
polluting the air we breathe, and the plants we eat.
13. Kendra Zamzow, Sutton, AK. Please consider this request to reduce methane emissions from
venting and flaring. Please consider also funding work to map natural gas leaks in towns and
cities that also contribute methane to the atmosphere, as has been done at cities around the US
(https://www.edforg/climate/methanemaps).
14. Cook Inletkeeper, Anchorage, AK
15. Kerry Williams, Eagle River, AK
16. Kimberly Slone, Wasilla, AK Please cut greenhouse gas emissions. In Alaska we could curb
emissions by holding oil and gas corporations to a zero -methane leak standard and reduce bum
off to a higher industry standard than was set in 2016. Methane, as I'm sure you are aware, is the
second biggest driver of climate change after carbon dioxide. Oil and gas corporations are
responsible for leaking methane and burning it off. This toxic, smog -causing pollution is harmful
to wildlife and people. The toxic pollutants released alongside methane can trigger asthma
attacks and increase the risk of cancer. Oil and gas industry safety standards can and must be
increased. Facilities must limit their methane releases and prevent leaks in infrastructure. Human
beings cannot survive a hot planet, we cannot eat sickened animals, but we can change.
17. Karin Dahl, Anchorage, AK
18. Kimberlee McNett, Anchorage, AK
19. David Matheny, Healy Lake, AK. We Alaskans did not choose to be in the center of our climate
crisis, but we can choose to be a pivotal example for change in solving this shared emergency.
Please carefully consider taking this bold and definitive step to reduce our climate impact and
allow us to be a leading light for other communities in the United States and beyond. I thank you
so much for your leadership and careful stewardship of this great state of ours. Sincerely, David
Matheny Life-long Fairbanksan.
20. Carole Comeau, Eagle River, AK. Alaska stands in a unique place with regard to being able to
make a very real contribution right now toward reducing damage due to carbon emissions
produced within our state. I would urge you to use your current power as the Oil and Gas
Conservation Commission to enforce the already existing statutes to require the oil and gas
industry to reduce the current levels of greenhouse gasses that they produce. Thank you.
21. Karen Beaudin, Anchorage, AK
22. Aaron Surma, Juneau, AK
23. Abby Smola, Soldotna, AK
24. Allen Dahl, Anchorage, AK. Please help protect the numerous Alaskan communities currently
being affected and endangered by human driven climate change. Please pledge to enforce the
upkeep of the regulations for the oil and gas industry to minimize their waste, and take steps to
reduce emissions. Thank you.
25. Adele Josepho, Anchorage, AK
26. Linda Gorman, Anchorage, AK
27. D Gasaway, Fairbanks, AK
28. Deirdre Coval, Soldoma, AK. Take a bold act on Climate Change protect Alaska's future.
29. Lauri Pepi, Kasilof, AK
30. Susan Gibbs, Wasilla, AK
31. Karla Hart, Juneau, AK
32. Philip Gordon, Anchorage, AK. Eminently sensible behavior. Thank you.
33. Susan Kaplan, Anchorage, AK
34. Karen Rode, Anchorage, AK
35. Alfredo Bolivar, Anchorage, AK
36. Michael LeMay, Anchorage, AK. Thank you for always being the adult in the
37. Stuart Schmutzler, Anchorage, AK. Please make a statement to Alaska that we absolutely need
to curtail greenhouse gases. Thank you
38. Alyson Pytte, Anchorage, AK
39. Lacey Harris, Wasilla, AK. Let's harness our natural resources. Not strip our earth.
40. Paul Arneson, Anchorage, AK
41. Arthur Peterson, Juneau, AK
42. Allison Jay, Juneau, AK. We must cut carbon emissions if we are to survive.
43. Meghan O'Shea Spring, Kasilof, AK
44. Amy Paige, Juneau, AK
45. Nancy Hillstrand, Homer, AK
46. John Bearden, Wasilla, AK
47. Bill Byl, Anchorage, AK
48. Gretchen Bishop (99821) Please reduce methane releases!
49. Bonnie Wanat, Eagle River, AK)
50. Bruce Booth (99522)
51. Brian Taylor (99587)
52. Kathy Ingallinera, Sitka, AK
53. Izzy Farris, Anchorage, AK
54. Chilton Bowman, Juneau, AK
55. Peter Otsea, Juneau, AK
56. Carolyn Nichols, Sitka, AK
57. Cathryn Coats, Ketchikan, AK
58. Catherine Hatch, Juneau, AK
59. Catherine Herron, Wasilla, AK
60. Miranda Monet, Anchorage, AK. Slash Alaska's Emissions by enforcing existing waste rules.
WE Only Have 1 earth &1 Alaska we ALL need to take care of it & do our part for our children,
for our neighborhood Mast but not least OUR SELVES!
61. Connie Harris, Palmer, AK What a waste of natural resources, capture and direct to other uses.
62. Chelsea Vukovich (99516)
63. Cheri Dean, Palmer, AK
64. Cheryl Silcox, Anchorage, AK Please consider the next seven generations.
65. Cris Hill, Fairbanks, AK) Please sign this we must protect our state and residents
66. Cindy Johnson, Eagle River, AK
67. Catherine Kemp, Anchorage, AK
68. Cliff Ward (99574)
69. Christine Wilcox, Anchorage, AK. It is a crisis.
70. Jenny Rasch, Anchorage, AK
71. Colleen Fisk, Anchorage, AK
72. Jason Collins, Palmer, AK Thank you for your efforts and your consideration.
73. Matthew Drumm (99714)
74. Lisbeth Jackson, Palmer, AK
75. Sharon Finn (99664) Please take this opportunity to have another significant positive impact.
76. Jesn Ward, Anchorage, AK Please cut the greenhouse gasses as much as possible. Thank you
for you service to the state.
77. Dael Devenport, Anchorage, AK
78. Daniella May, Eagle River, AK
79. Louise Seguela, Anchorage, AK. Of course this needs to be done.
80. Deborah Corral, Eagle River, AK
81. Deirdre Booth (99522)
82. Deborah Voves (99516)
83. Danielle Redmond
84. Diane Fink, Palmer, AK We must work to preserve earth! For ourselves and future generations
as well as animal life!
85. Douglas Woodby, Juneau, AK
86. Andrew McDonnell, Fairbanks, AK
87. Richard Ourada, Fairbanks, AK. Over 80 years I have watched pollution come and go, but this
is different. This for all the marbles in the survival game and we must do all we can before it's
too late.
88. Rodney Bliss (99506)
89. Douglas Westphal, Anchorage, AK
90. Elayne Hunter, Anchorage, AK
91. Liz Hawkins, Juneau, AK
92. Eileen Wagner, Juneau, AK
93. Shonti Elder (99654)
4
94. Elizabeth Jurgeliet (99827)
95. Donald Hennessey, Anchorage, AK
96. Emily Davies, Chugach, AK
97. Megan Long, Anchorage, AK. Please do your part and help reduce our carbon emissions! You
have the opportunity to change the world for the better!
98. Emily Becker, Anchorage, AK
99. Emily Stark (99502)
100. Robin Smith (99515)
101. Erin Willahan, Anchorage, AK
102. Erik Gunderson, Eagle River, AK
103. Christopher Northcutt, Anchorage, AK
104. Fay Herold (99664)
105. Angela Ferrari, Anchorage, AK
106. Adam Weber, Anchorage, AK
107. John Nagel, Juneau, AK
108. Andrea Messenger, Wasilla, AK PLEASE!!!!
109. Jaime Gable, Anchorage, AK
110. Garryson Collette, Fairbanks, AK. Let's make sure Alaska's sky isn't a warehouse for
undesirable products. Methane is useful. Alaska's oil and gas industry needs to put flare gases to
work or find someone who can.
111. Gretchen Keiser, Juneau, AK
112. Glenn Richardson (78753)
113. Heather Forbes, Anchorage, AK
114. Heather Mcintyre (99725)
115. Kevin Walker, Anchorage, AK
116. Alex Hughes, Kodiak, AK
117. Janice Bobek, Soldotna, AK. Stop hurting our environment!
118. Janice Caulfield, Juneau, AK
119. Jan Welt, Anchorage, AK
120. Jeanne Parker, Anchorage, AK
121. Jennifer Smith, Juneau, AK
122. Joseph Sadley, Palmer, AK
123. James Lyons (99664)
124. James Mahan (97221) There must be a better way!
125. Joanie Kirk, Sutton, AK. Make a splash for the long term good of all
126. Jeff Sloss, Juneau, AK
127. Julie Bailey, Sitka, AK
128. Kathleen Kreiss, Sitka, AK
129. Katherine Walters (99686) Global warming is REAL. We must do everything in our
power to stop it.
130. Kimberly Porter, Anchorage, AK
131. KAREN MCCRAE, Juneau, AK
132. Kat Haber, Homer, AK. Methane is 84 times more lethal than CO2. Alaska is suffering
the most dire climate consequences of any American state. NCA4 affirms the times we are in.
Alaska faces a much steeper mitigation and adaptation to climate change. We would be wise to
immediately change course. Climate consequences are adding black carbon into our atmosphere
like a sewer. Please create a better future for us all by enforcing existing regulations. How might
we shift the cultures of oil/gas companies to be ever more diligent about their polluting Alaska?
133. Katie Gavenus, Anchorage, AK
134. John Kaufman, Anchorage, AKI look forward to a future in which we can be partners in
the fight against global warming!!
135. Deborah Vandruff, Anchorage, AK
136. Karyn Murphy, Anchorage, AK. Please do what you can to help Alaska be a leader in
what can be done to protect our future. We can make changes that will slow the effects of
climate change.
137. Kyra Harty, Anchorage, AK
138. Leanora Skaggs, Juneau, AK
139. Abigail Leatherman, Juneau, AK
140. Linda Kruger, Juneau, AK
141. Lindsie Fratus-Thomas (98225)
142. Lauren McPhun (99827)
143. Lorraine Krueger, Eagle River, AK
144. Larri Spengler, Juneau, AK
145. Leila Pyle, Anchorage, AK
146. Lucille Zercher, Chugach, AK. Let's make Alaska a leader and a model to decrease
greenhouse gases.
147. Luke Seaman, Palmer, AK
148. Tania Lewis (99826)
149. Kathryn Jordan, Palmer, AK
150. Mary Griffith (99664)
151. Malena Marvin (99833)
152. Margo Waring, Juneau, AK
153. Marjorie Hamburger, Juneau, AK
154. Mark Sirek (04005)
155. Mark Vail (99588) Do it! For the children.
156. Matthew Hennigan, Anchorage, AK
157. Robert McGimsey, Eagle River, AK. I realize this may not be popular among
Republicans, but sometimes doing the right thing is more important than being popular.
158. Laurenc DeVita, Homer, AK
159. Meredith LaValley, Anchorage, AK
160. Michael Yourkowski, Anchorage, AK
161. Denis Corral, Eagle River, AK. Climate change is real. Methane emissions contribute to
climate change. Enforce the statutes that limit methane emissions.
162. Lin Davis, Juneau, AK
163. Mollie Boyer, Palmer, AK
164. Craig Mishler (99516)
165. Alan Smith, Anchorage, AK
166. Kimberly Meck, Anchorage, AK Thanks for moving quickly on this!
167. Ben Muse, Juneau, AK
168. Heather Faber, Palmer, AK
169. Laurie Millane (99664)
170. Nancy Thibodeau (99612)
171. Nathaniel Perry, Shaktoolik, AK Why do companies shield flares from view in the
lower'48', but not in AK?
172. Jessica Tenhoff (99704)
173. Pete Lyford, Wasilla, AK
D
174. Nancy Simpson, Juneau, AK
175. Mike Burnham, Soldotna, AK
176. Pam Hennigan (32563) Please do all you can to protect the natural beauty of Alaska by
limiting all commercial activities that threaten that natural resource for all Americans.
177. Patricia Wood, Ketchikan, AK
178. Paul Brown, Anchorage, AK An opportunity to take climate change seriously.
179. Patricia Cue, Anchorage, AK
180. Daniel Perry, Anchorage, AK. It is our current responsibility to do whatever we can to
mitigate human caused climate change. Please enforce statutes curbing methane emissions.
Thank you!
181. Rosemarie Buchman (98844)
182. Patrick Pragman, Anchorage, AK. Thanks!
183. Rebecca Lambourn (99611)
184. Ray Bulson, Eagle River, AK)
185. Rich Stromberg, Sutton, AK. What a wonderful legacy gift to leave for your
grandchildren and all Alaskans.
186. Nick Riordan, Anchorage, AK
187. Ron Newcome (99664-3731) Please do the right thing. Thank you.
188. Roberta Highland, Anchorage, AK
189. Rodney Guritz, Fairbanks, AK
190. Andy Romanoff, Juneau, AK. Time to pull out heads out of the sand. Please...
191. Cynthia Hendel, Eagle River, AK
192. Russell Haver, Anchorage, AK
193. Sage Cohen, Anchorage, AK
194. Sally Paul, Juneau, AK
195. Steven Bergt , Anchorage, AK
196. Scott Bartlett, Anchorage, AK
197. Harvey Herrick (92037)
198. Susan Loshbaugh, Fairbanks, AK
199. Shoshanah Stone, Anchorage, AK
200. Shannon Ozee Anchorage, AK
201. Tracy Smith, Palmer, AK
202. Shelley Hansen (99703)
203. Sheri Thomson, Palmer, AK
204, Meghan Kerlin, Anchorage, AK
205. Mim McConnell, Sitka, AK
206. Jeffers Alaska, Chugach, AK
207. Sharon Keller, Anchorage, AK. Please take this step to protect our environment
208. Patricia Crane, Fairbanks, AK. Use it to heat the homes In Fairbanks that currently heat
with wood!!
209. Betty Springen, Anchorage, AK. I'm assuming this petition will not be necessary as I
believe you will do the right thing & sign!
210. Sonia Nagorski, Juneau, AK
211. Steve Behnke, Juneau, AK
212. Susan Spyker, Eagle River, AK
213. Stephen Harvey, Fairbanks, AK
214. Susan Blanton (99516). Recent fires and mega storms mean we need to address our
warming crisis.
215. Sue Gill, Juneau, AK
216. Abraham Horschel (99686) This could easily be used to produce energy. Such a waste
and proof of how little these companies care about Alaska
217. Laura Thate, Juneau, AKWe have a sacred duty to care for our environment this great
state of ours is Ground Zero of global warming. Last year we lost 1/3 of our ice sheet and we
were 48° above normal. I am sick and tired of all the denial when we can see it with our own
Alaskan eyes. The devastation that climate change due to human activities and political decision-
making has created. It is our responsibility ensuring that these greenhouse emissions through
methane. Alaskans have a deep responsibility to care for the land! It is your responsibility it is
your duty!
218. Susann Amos, Fairbanks, AK
219. Katharine Swift, Anchorage, AK
220. Tanya Holley, Juneau, AK
221. Tiffany Creed (99752)
222. Tifflany Hopson, Nuiqsut, AK. Life-long resident of Nuiqsut, Alaska. Mother of 4
beautiful children, who also live in Nuiqsut. Our lives and health matter too.
223. Christina Peterson, Fairbanks, AK
224. Tristan Glowa, Fairbanks, AK
225. Teresa Sundmark, Anchorage, AK
226. Tyre Fairbanks, Homer, AK. Thank you for leaving a legacy that will impact ALL
ALASKANS and our home, Earth.
227. Christopher Booth (99522)
228. Elvira Paschke, Anchorage, AK
229. Ginger Drais, Anchorage, AK. This is your chance to truly make a substantial difference
in Alaska!
230. Vivian Finlay, Anchorage, AK
231. Shelley Gill, Anchorage, AK please stop this war on the planet.
232. Suki Wilder (99664)
233. Charley & Sherry Wilmoth, Kodiak, AK. Care for our earth! She nurtures us!
234. Sharon Winner, Anchorage, AK
235. Emily Wentzel Walle, Anchorage, AK
236. Brooke Heppinstall Kroenung, Palmer, AK Please help us save the planet by putting
Alaska in the forefront of change!
237. Edward Sheridan, Soldotna, AK
238. Zoe Fuller (99762) Please!
239. T. Frank Box (99502) Thanks Hollis
240. Kathleen Roush, Fairbanks, AK
241. Neil Waggoner, Anchorage, AK
242. Debra Wessler (99676) We are pass due for this. Thank you!
243. Alfredo Bolivar (99515)
244. Amanda Campbell, Anchorage, AK
245. Andrew White, Soldotna, AK
246. R. Ann Oberlitner, Homer, AK
247. Barbara Poss, Anchorage, AK
248. Chelsea Vukovich, Anchorage, AK
249. Christine Wilcox, Anchorage, AK
250. Constance Fredenberg, Palmer, AK What are we thinking to carry on business as usual
while Earth burns, floods, quakes, and a mass extinction event is set in motion - primarily caused
Ij
by the foolishness of human genius? Think about our grandchildren's children. The new green
deal is a great idea long overdue. Alaska could be a leader in this new energy economy if we
wanted - small renewable powered micro -grids and large scale geothermal. For the love of a
decent future for today's babies, let's all want to.
251. Donald Hennessey, Anchorage, AK
252. Michael Fenster, Anchorage, AK
253. Dale Banks, Homer, AK
254. David Carrothers, Juneau, AK
255. Deborah Retherford, Palmer, AK
256. Denise Anderson, Anchorage, AK
257. Ann Dixon, Anchorage, AK
258. Richard Ourada, Fairbanks, AK. Stop this waste and environmental damage.
259. Mary Jo Towne, Wasilla, AK
260. Dustin Gridley, Fairbanks, AK
261. Ed Berg, Homer, AK
262. Angela Ferrari, Anchorage, AK
263. Jasmine Maurer, Anchorage, AKI expect violations to be addressed and regulations to
be followed now and in the future.
264. Jeanne Parker, Homer, AK
265. Judith Lindenfelser, Chugach, AK
266. Jordan Ebert, Anchorage, AK
267. Kathleen Kreiss, Sitka, AK
268. Kaitlin Vadla, Soldotna, AK. Time to harvest methane for salable use, for financial
stability and so we can have a habitable place to live!
269. Kathleen Eagle, Anchorage, AK. Please enforce existing rules to minimize waste and
take additional actions to reduce greenhouse gas emissions. Do this for both Alaska and the
world's climate. Alaska is already affected, and changes are costing us a great deal. Climate is a
world-wide system and we all need to do our part!
270. Kathleen Sarns-Irwin, Anchorage, AK
271. Kendra Blochwitz, Anchorage, AK
272. Karen Sasnett, Anchorage, AK Thank you!
273. Kerry Wright, Ward Cove, AK
274. Dr. Casey J Rudkin, Soldotna, AK. It's December 12th in South Central Alaska, and we
have no measurable snow on the ground. This is a huge problem, and the fossil fuel industries
need to be held accountable.
275. Abigail Leatherman, Juneau, AK
276. Lyn Franks, Anchorage, AK
277. Margo Waring, Juneau, AK
278. Marian Allen, Sitka, AK
279. Marianne Aplin, Anchorage, AK
280. Mike O'Meara, Anchorage, AK. People serving on the AOGCC need to do the ethically
right thing. Make the multinational corporations that reap excessive profit from our resources at
least abide by existing law.
281. Mickie Montoya, Anchorage, AK. We have to be responsibl for what we add to this
situation. Please remember it's about more than money. It's about human life and the future
quality of what we create in this moment of time. Please do everything you can to limit the toxic
emissions. Please enforce existing rules to reduce methane emissions.
282. Shirley Moto, Wasilla, AK. Renewable resources go not hurt the environment!!!
283. Mariah Thomas -Wolf (99639) Please take into consideration the traumatic impact of
greenhouse gases on Alaska's pristine environment. Thank you.
284. Nathaniel Perry, Shaktoolik, AK
285. Eric Lee, Petersberg, AK. We must force the oil industry to follow the law!
286. Deborah Poore, Anchorage, AK. One of the most significant things we NEED to do as
soon as humanly possible!
287. Robert Archibald, Anchorage, AK. Please consider this a very proactive approach.
288. Roderick Smith, Anchorage, AK
289. Kelsey Ebert, Anchorage, AK
290. Sue Christiansen, Anchorage, AK
291. Jone Suleski, Kodiak, AK We clearly see adverse situations along the coast and with our
marine life due to climate change, here on Kodiak Island, Alaska
292. Teresa Jump, Homer, AK
293. Joann Torgeson, Sitka, AK
294. Elvira Paschke, Anchorage, AK
295. Vijay Patil, Chugach, AK
296. Sherry Wilmoth, Kodiak, AK
10
Testimony of Kate Troll
Regarding Petition to Prevent Non -Emergency Venting and Flaring of Methane
Public Hearing December 18, 2018
• Thanks to Commissioner French, Foerster and Seamount for granting this hearing in
response to a petition signed by 46 Alaskans. Since submitting this petition there have
been more Alaskans signing on to this request and that will be addressed by Ceal Smith
who will follow in public testimony.
• To start I want you to know that while the topic of climate change will enter this
hearing, we are not asking you to enlarge your mission. We do not seek mission creep,
we merely ask that you urgently and competently enforce AS. 31.05.095 which prohibits
the waste of oil and gas and regulation 20 ACC 25.235 (b) which defines waste as gas
released, burned or permitted to escape into the air. Because that gas which escapes is
mostly methane, a greenhouse gas about 30 times more potent than carbon dioxide
over the long-term and almost 90 times more potent over the short-term, the matter of
climate change enlarges the public interest behind your existing mission. In other words
it's not mission creep we seek but mission urgency.
• The United Nations International Panel on Climate Change is the leading world body for
assessing the science related to climate change, its impacts and potential future risks,
and possible response options. These leading climate scientists have warned there is
only a dozen years for global warming to be kept to a maximum of 1.5 degree Celsius,
beyond which even half a degree will significantly worsen the risks of drought, floods,
extreme heat and poverty for hundreds of millions of people. We are already at 1
degree Celsius. Twelve years is not long at all. Listen to these recent words of renowned
naturalist David Attenborough and tell me it's not a time for all hands on deck.
"Right now we are facing a man-made disaster of global scale, our greatest threat in
thousands of years: Climate change. If we don't take action, the collapse of our
civilizations and the extinction of much of the natural world is on the horizon."
• The seriousness of this IPCC assessment was recently backed up the latest National
Climate Assessment. The report devotes an entire chapter to Alaska and it describes the
state as one of the fastest warming places on earth. Fairbanks -based climatologist Rick
Thoman helped write it. He says one of the big takeaways for Alaska is that it's going to
be expensive to adapt to climate change and that will be felt in every household across
the state. In fact, the a report out of the University of Alaska Anchorage estimates some
of the most certain consequences of climate change in Alaska will cost the state
between $340 and $700 million per year over the next three to five decades. And there
are current consequences in Alaska especially related to coastal erosion, infrastructure
impacts from permafrost thawing, and changes in temperature and precipitation
impacting the lives of Alaskans.
• As one of the most highly impacted states from climate change, we need to get our own
emissions in order if we want any type of federal or other help to address our
adaptation needs, especially the scores of coastal communities currently impacted by
winter storms and shore erosion.
• Whether you look at climate change globally or just within Alaska, there is an
undeniable, pressing need to reduce greenhouse gases as soon as possible. Since the oil
and gas sector is the largest contributor of greenhouse gas emissions in Alaska, it makes
sense to focus on the reduction of waste in this sector.
• The defenders of status quo in Alaska like to point out that the emissions from Alaska
comprise less than 1 percent of all U.S. emissions and less than .1 percent of global
emissions. Status quo defenders like to use these figures in presenting the de minimis
argument for no action necessary. Not only does this approach overlook our moral
responsibility to future generations but skips right over the fact that on a per capita
basis Alaska is fourth in the nation for greenhouse gas emissions. The reason for this
high per capita amount of emissions circles us right back to oil and gas operations which
generate more than 56 percent of Alaska total greenhouse gas emissions in 2015.
Ten years ago the oil and gas representatives on Governor Palin's Mitigation Advisory
Group, (a group I served on) unanimously agreed that Alaska should reduce fugitive
methane emissions which includes the non -emergency venting and flaring of methane.
Since then no Governor or State agency has made any effort to implement this industry
supported action. In other words, we've had status quo for more than ten years and
with all the reports of existing and threatening climate impacts only growing in scale and
intensity the time for implementing this industry supported recommendation is now.
Judging by the posted statements of industry, one would conclude that the oil and gas
sector of Alaska would agree with this immediate need assessment. I would like to
highlight these sections from the Guiding Principles signed onto by BP and Exxon: The
Preamble notes, "Providing access to energy while addressing global climate change, is
one of the greatest challenges of the 21s` century. Since natural gas consists mainly of
methane, a potent greenhouse gas, its part in the transition to a low -carbon future will
be influenced by the extent to which the oil and gas industry reduces its methane
emissions." Under the topic Continually reduce methane emissions —"we will reduce
venting, and fugitive methane emissions, and improve combustion efficiency. Under the
topic of Advocate sound policy and regulations on methane emissions - "we work
constructively with international institutions, governments, industry and NGOs in the
development and implementation of effective methane abatement policies or
regulations."
• ConocoPhillips while not a signatory to the Guiding Principles mentioned above, has its
own climate change strategy designed to "prepare the company to succeed in a world
challenged to reduce greenhouse gas emissions. Under the topic of Managing
Operations and Projects is "prioritize emissions reductions" Under the topic of
Understanding Footprint is "improve recording of emission reductions projects."
These statements in conjunction with industry agreement on Governor Palin's Climate
Change Mitigation Group strongly suggest that the AOGCC has a willing industry partner
to reduce waste, to reduce emissions including non -emergency venting and flaring. In
essence, it should be relatively straightforward to hold the oil and gas sector not only
accountable to their pledges but to their obligations under your waste regulations.
• This brings me the issue at hand. What is the track record for full compliance? As noted
by those following me in this hearing there is reason to doubt that rigorous compliance
is occurring. As the temperatures rises on the North Slope, creating more need to flare
off methane are we just allowing this to become the new normal in North Slope
operations? Has AOGCC met with industry to discuss how to reduce emissions in these
changing times? Has AOGCC devoted resources to enforcement of its waste gas
regulations, and will it do so in the future? Is there a sense of mission urgency within the
AOGCC or is a status quo operation focused on just the reporting of releases of
methane? Bringing a little more focus into these lingering questions is Ceal Smith and
following her, Lois Epstein.
�_t LL %w 1�_' n Ad LZ Lld
OEC 18 2013
Thank you, Commissioners, for holding this hearing on an important issue that,,�Z'�'
many believe, has not received the attention it deserves from AOGCC and the
state of Alaska. My name is Lois Epstein and I am an Alaska -licensed engineer
with The Wilderness Society, a national non-profit conservation organization. The
Wilderness Society's scientists have worked on conservation in the Alaskan
Arctic since our inception in the 1930s.
The first goal listed on your website is to "[p]revent waste of Alaska's oil and gas
resources." I, and others, are here today to discuss the unnecessary waste of
natural gas from non -emergency flaring and venting. And in response to
Commission Seamount's question on venting vs. flaring, I'll note that flaring
produces black carbon which has a localized warming impact when deposited on
snow or ice and this is a problem in Alaska.
As you know, AOGCC has statutory and regulatory requirements to prevent
release or burning of gas other than incidental de minimis venting and gas
released or burned under 20 AAC 25.235(d)'s listed exceptions. Our primary
questions today are:
1. What is AOGCC doing to analyze Form 10-422 flaring and venting reports
to determine if there should be enforcement actions against certain
operators for wasted gas resources?
2. Has AOGCC spot-checked any operators' reports to see if their claims of
20 AAC 25.235(d) exceptions are legitimate?
3. Have there been any enforcement actions for waste gas in the Arctic or
Cook Inlet over the past ten years? If yes, what are the details of those
enforcement actions?
As the commissioners know, the federal government has re -issued the Bureau of
Land Management's waste gas rule and has plans to re -issue EPA's rule to
reduce methane releases for new, modified, and reconstructed wells. The Trump
administration's approach is to limit the federal role on the waste gas issue and
defer to states. That approach makes AOGCC's actions on this issue even more
important.
I brought copies for you of a November 2018 repo issued by The Wilderness
Society last month entitled The State of Methane which shows how Alaska
compares to other states in its regulatory efforts to reduce waste gas. It's clear
that Alaska is behind other oil and gas producing states in many regulatory
areas, including the lack of a venting prohibition (see the chart on page 4). The
lack of several state regulatory standards addressing waste gas combined with a
seeming lack of enforcement resources spent on this issue, is troubling.
Please consider pursuing one or more high-profile enforcement actions against
operators who are not meeting state regulatory requirements. Additionally, we
urge you to upgrade the state's regulatory standards addressing waste gas so
Alaska is no longer a laggard and meets the level of a leader state, such as
Colorado.
We often hear Alaska's elected officials saying that the state has the "best" or the
"highest" environmental standards. Because AOGCC has allowed the state to fall
behind on waste gas enforcement and regulations, that clearly is not the case.
Thank you for taking these comments into consideration.
Chapter 6 err 18 ZQtoP
Oil and Gas Sector A0GCC
Important Introductory Note __ --
This report contains a range of potential mitigation measures identified by the Alaska
Mitigation Advisory Group (MAG). These include measures the MAG believes need more
analysis and development before they should be considered for implementation. If ultimately
included in the Alaska Climate Change Strategy recommended by the Governor's Climate
Change Sub -Cabinet; these measures should be identified as options for further study only.
This report also describes measures where the benefits and feasibility of implementation are
more certain. These may require much less analysis or development before they could be
considered for implementation. Although called 'recommendations" in this report, the following
options fall into the former category — those requiring further study:
• OG -2 — Reductions in Fugitive Methane Emissions
• OG -3 — Electrification of North Slope Oil and Gas Operations, With Centralized
Power Production and Distribution
• OG -4 — Improved Efficiency Upgrades for Oil and Gas Fuel -Burning Equipment
• OG -5 — Renewable Energy Sources in Oil and Gas Operations
• OG -6 — Carbon Capture (From North Slope High -0O2 Fuel Gas) and Geologic
Sequestration With Enhanced Oil Recovery
• OG -7 — Carbon Capture (From Exhaust Gas at a Centralized Facility) and Geologic
Sequestration With Enhanced Oil Recovery
• OG -8 — Carbon Capture (From Exhaust Gas) and Geologic Sequestration Away From
Known Geologic Traps (Not recommended at this time)
Reducing the greenhouse gas (GHG) emissions of oil and gas (O&G) operations in Alaska will
be expensive. These expenses, which will be borne by industry, the state, and the consumer,
could be decreased by policies developed by the state.
The best chance to implement any of the O&G policy options is through improved economics.
This could be accomplished by reducing the technological and regulatory costs of implementing
these options, and by increasing the benefits from carbon sequestration (e.g., enhanced oil
recovery and value for carbon.)
To enable the actions necessary for major emission reductions, Alaska can provide and/or
continue leadership in a number of broad policy areas, including:
• Adopting a straightforward carbon regulatory framework;
• Recognizing and addressing existing regulatory conflicts and complexities;
M.
• Developing a workforce ready for a GHG-constrained world;
• Understanding impacts on Alaska's revenues and investment;
• Analyzing developments over time that can make reductions more viable; and
• Advocating the importance of Alaska O&G to national energy security.
Each of these policy areas is discussed in this chapter. Also provided are the background
necessary to understand the Alaska O&G setting with respect to emission reductions, and an
overview of the individual policy recommendations, their potential for reducing GHG emissions,
and their possible costs.
Overview of GHG Emissions
While Alaska contributes a very small percentage (0.7%) of U.S. GHG emissions, significantly
reducing the concentration of GHG in the atmosphere will require all states to contribute to the
reductions. It is important for the state to understand the implications and tradeoffs that will be
inherent in reducing its GHG emissions. The O&G industry—including production, exploration,
refining, and pipelines—is Alaska's largest stationary source of GHG emissions, accounting for
29% of all anthropogenic (human -related) sources.' As such, the industry has been the focus of
much effort by the Alaska Climate Change Mitigation Advisory Group (MAG).
Currently there are two areas of O&G production in Alaska—the North Slope, which generates
–81% of O&G emissions, and Cook Inlet, which generates –10% of the emissions. Refining and
pipelines each contributes about 5%. (Figures 6-1 and 6-2). The industry emissions are
primarily related to combustion products from natural gas turbines.
I DRAFT Alaska Department of Environmental Conservation, "Report of Improvements to the Alaska Greenhouse
Gas Emission Inventory" (includes Final Alaska GHG Inventory and Reference Case Projection), January 2008.
Available at: http://www.climatechanjzc.alaska.gov/docs/jzh2 ei rpt.pd
6-2
Figure 6-1. Total CO2e emissions (-15 MMtCO2e) sorted by Alaska oil and gas
production, refining, and pipelines
11
E
N
C
N I
N
E
W
d
N
Cook Inlet OK. North Slope O+G Refining Pipelines
Alaska Oil and Gas Emissions
CO2e = carbon dioxide equivalent; MMtCO2e = million metric tons of carbon dioxide equivalent; O+G = oil and gas.
Figure 6-2. Total CO2e emissions (-12 MMtCO2e) sorted by North Slope facility
to ,
N 9
C
O
Y g
u
Y
Cd
G
C g
O
E 5
N
C
O
N
N 3
E
W
CU 2
N
0
U s
0
Badaml Endlrott
Prudhoe Kuparuk Osburne Wine Northstar Alpine
Bey Fleld Field
North Slope Facilities
■ Natural Gas
In Diesel
CO2e = carbon dioxide equivalent; MMtCO2e = million metric tons of carbon dioxide equivalent; O+G= oil and gas.
The majority of the known and developed Cook Inlet oil and gas operations are nearing the end
of their economic life. Cumulative oil production of 1,335 million barrels of oil represents about
6-3
95-96 % of the estimated ultimate recovery (EUR) and cumulative gas production of 7,112
billion cubic feet of gas represents nearly 84 % of EUR.2 Because of the diverse nature of the
Cook Inlet facilities they were determined to be extremely difficult to quantify and had a limited
remaining life over which to amortize the investments; therefore, Cook Inlet was not quantified
in these deliberations.
Exploration activity in the arctic regions (such as the National Petroleum Reserve -Alaska, the
Beaufort and Chukchi Outer Continental Shelf, or the Nenana Basin or Bristol Bay) and fixture
development of known resources were not considered or quantified in these deliberations.
Consequently, the geographic focus of the MAG was directed toward the existing facilities and
fields of the North Slope. Here, the cumulative production of oil and natural gas liquids is about
70% of EUR. The gas has not yet been brought to market, but is being used as fuel and for
reinjection to maintain reservoir pressure. Impacts associated with a future natural gas pipeline
were not included in the quantification, other than a presumed market value for North Slope gas
starting in 2020.
It is important to understand that location and field life have significant economic impact on
these technology-based options.
Alaska's emissions account for 0.7% of all U.S. emissions. Of the 52 million metric tons of
carbon dioxide equivalent (MMtCO2e) emissions generated in Alaska, 15 MMtCO2e are related
to the O&G industry. This represents a much higher percentage than the U.S. average, and
reflects the fact that the vast majority of fuel produced in Alaska is shipped to consumers outside
of Alaska (Figure 6-3).
' AOGCC December 31, 2008 Production Report, and 2004 DOE Report- South -Central Alaska Natural Gas Study
http://www.netl.doe.gov/technologies/oil-pas/ReferenceShelf/RefShelf archive html Wreports04
6-4
Figure 6-3. Alaska energy flow (trillion Btu)
Alaska's Energy Flow
2006 - Trillion BTU
3500 V
31100
2500 _
2000
1500
loco '
500 /
0 � /
Petroleum-Crude0ii Natural Gas Coal
and Products
■ReiniAted •Exported ■Onsitewe ■In Staleuse
Source: Alaska Energy Authority energy diagram produced by the Alaska Center for Energy and Power, based on
data from the University of Alaska—Anchorage Institute of Social and Economic Research, the Alaska Department of
Natural Resources, the U.S. Army Corp of Engineers, and the U.S. Energy Information Administration.
Btu = British thermal units.
The MAG recommends that the information contained in this report be used by state officials to
inform the federal climate change debate as to the impact on Alaska's O&G sector, from cap -
and -trade program(s), carbon taxes, command -and -control programs, or combinations thereof.
Care should be taken that state and federal policies do not inhibit current and future Alaska
exploration and production.
The MAG emphasizes that the technical policies presented here are not intended or supported as
recommendations ready for immediate implementation or justifications for specific state
mandates at this time. Rather, they represent an important fust step in understanding the issues,
and require detailed technical and economic analysis before actual policies can be crafted.
Key Challenges and Opportunities
The MAG has made a high level analysis of eight technology options to reduce GHG emissions
in Alaska's O&G sector. Most of these options will be expensive in today's current context.
Alaska can improve their cost-effectiveness by providing and/or continuing leadership in several
broad policy areas.
Adopting a Straightforward Carbon Regulatory Framework
The MAG believes that multiple layers of carbon regulation would hinder emission reductions
and needlessly decrease the viability of Alaska's economy. The MAG recommends that Alaska
6-5
remain an observer in the Western Climate Initiative process. The MAG also recommends the
state participate in regulatory development at the federal level, and take actions necessary to
efficiently implement a federal program, with strong emphasis on avoiding duplication of or
conflict with state regulations, as well as understanding the efforts and resources that will be
required for compliance with all programs.
The federal government will impose GHG regulations and requirements independent of Alaska.
State actions in this regard would be redundant, impose regulatory confusion, and increase
compliance costs (two separate GHG reporting regimes, two separate cap -and -trade tracking
mechanisms, etc). Multiple regulatory programs will create a confusing environment in which to
analyze and execute emission reductions projects, and will lead to increased uncertainty and cost
of accomplishing reductions.
Any early emission reductions in the Alaska O&G sector must be creditable toward a federal
program, because there are only a discrete number of such opportunities. Encouraging early
action will help maximize emission reductions. A state- or regional -level program does not
ensure this will occur.
There are existing regulatory impediments to reducing GHG emissions. Significant emission
reductions could occur by building a large, high -efficiency central power plant that could service
multiple fields on the North Slope. Existing barriers to centralized power include royalty
payments for gas used to generate electricity that crosses unit boundaries; the prospect of
increased regulations through creation of a public utility; and existing provisions of the Clean Air
Act (CAA). (For example, the CAA provisions do not currently allow balancing increases in
criteria pollutant emissions such as nitrogen oxides for carbon emissions.)
Also, technologies that limit GHGs can sometimes complicate or erode the effectiveness of
technologies currently in place to limit emissions of other criteria pollutants. Several technology
options (more energy-efficient turbines and fuel gas CO2 removal) would likely require double
investment in both carbon and criteria pollutant reduction systems. There may be ways to allow
reasonable tradeoffs between carbon and criteria pollutants, provided the impacts on ambient air
quality are acceptable.
Developing a Workforce Ready for a GHG-Constrained World
Alaska should consider how climate change regulation and the need for emission reductions will
affect the state government workforce, and more broadly the statewide economy. A trained and
experienced workforce, both for Alaska and industry, will be critical to the implementation of
any large emission reductions efforts.
Of particular note, GHG reduction technologies will create significant additional workloads for
state permitting and regulatory agencies. Current staffmg levels and training of the staff at state
regulatory agencies are likely unable to provide the required permits in a timely manner. Alaska
should ensure that it has a trained and experienced workforce to implement the large permitting
and regulatory changes for O&G operations within its agencies to help facilitate the
implementation of the GHG reduction options.
M
Understanding Impacts to State Revenues and Investment in Alaska
The regulation of GHG emissions will forever change the landscape of energy production in
Alaska. It is likely that Alaska's gas resources will become more valuable, while the value of
petroleum resources will decrease, which in turn will profoundly change Alaska's economy. If
GHG reduction requirements add economic burden to current and future Alaska production,
existing field life could be shortened, and future development could be transferred outside the
state, region, or country.
It is also critical for the state to understand the impact a GHG project with associated major
capital expenditures and potential tax credits would have on its short- and long-term revenue
streams.
Advocating the Importance of Alaska Oil and Gas to National Energy Security
Government policies to lower GHG emissions being debated at the state and federal levels could
weaken Alaska's O&G sector, unless they recognize that GHG emission targets must take into
account that until enough low -to -no -carbon emission fuels are available, Alaska's O&G
resources are still critical to national energy security.
Alaska should participate in the federal legislative and rulemaking process by commenting and
providing input to the U.S. Congress and U.S. Environmental Protection Agency on proposed
reporting rules. Communicating the significance of Alaska O&G to national energy security
should be an important part of a broader advocacy effort to help manage the potential impacts on
state revenue and investment. Energy -exporting states, such as Alaska are in the minority, and
the importance of maintaining a strong domestic conventional energy base should be a critical
point in the federal debate. Heavy oil is likely the most significant proven O&G resource and
source of state revenue, remaining to be developed after natural gas. Without appropriate
balance between climate change and energy security issues, the major investments necessary to
develop heavy oil are likely not to occur.
If GHG reduction costs make O&G production in Alaska not cost-effective, end users of Alaska
petroleum energy would turn to other petroleum -producing regions to meet their energy
demands. The GHGs associated with that energy production would simply be emitted in a
different part of the world, negating the efforts to reduce GHG levels, and with an associated
effect of reducing national energy security.
Analyzing Developments That Can Make Reductions More Viable
The MAG recognizes that an extensive amount of work has gone into understanding existing
conditions and developing these policy recommendations. The MAG emphasizes that more
efforts to address complex technological and economic issues are needed. The evaluations
modeled a simple development case for each option to define boundaries sufficient to estimate
costs. These development cases were intended to portray broadly how a technology might be
deployed on a large scale. The real world is much more complex than these models; the unique
boundaries established by individual projects will determine their viability.
The MAG recommends that an economic study be undertaken by the University of Alaska to
integrate all aspects of Alaska's economic factors related to incentives. This study should model
the economic impacts that GHG reduction policies will have on both the state and private
industry. With the exception of ongoing conservation efforts discussed in policy option OG -1,
none of the options modeled appears to be economically viable for private -sector investment at
this time. The quantification model did not factor in state and federal tax policy or any cost for
carbon. The MAG recommends further analysis of tax policy on investments in the eight
options, and on any new government incentives that would improve the return on private -sector
investment.
Further, technical studies should be undertaken to refine the current work in developing viable
technology options, specifically the aspects of:
• Developing a centralized power production and distribution system for the O&G production
areas on the North Slope of Alaska.
• Replacing the older combustion equipment in service on the North Slope with newer, more
efficient equipment. The study should be used to determine any barriers associated with the
upgrades, and provide recommendations on how to overcome these barriers.
• Using renewable wind energy to supplement electrical production on the North Slope. The
study should identify any barriers associated with a centralized electricity production and
distribution system and recommend how to overcome them.
• For carbon capture projects deriving value from enhanced oil recovery (EOR), conducting
technical analysis to choose appropriate CO2 capture technology and the best reservoir for
CO2 injection to maximize economics, especially relating to EOR benefits.
• For carbon capture projects away from known geologic traps, conducting technical analysis
to include the size and type of facilities modifications, choice of appropriate combustion CO2
capture technology, and either the search for nearby sequestration opportunities or the
planning for a pipeline to known reservoirs with proven seals.
Finally, the studies should address the best mix and size of projects, viewed economically both
short and long term. Whereas it may look more efficient in the short term to capture and inject
carbon emissions, from a long-term perspective it is preferable to focus on energy efficiency
options first. It takes energy to capture and inject carbon from exhaust streams—up to 30%
more energy than is required in a non -capture scenario. It is far better resource management to
first minimize the amount of carbon to be captured, and then treat a smaller volume of exhaust
gases.
Overview of Policy Recommendations and Estimated Effects
The eight steps developed by MAG are predominantly "technology options" that require major
capital investment to implement. This section provides a brief overview of each option
recommended for further review. Appendix I. Oil and Gas Policy Recommendations contains
the complete report for each O&G policy.
The GHG reductions estimated for each option are not additive. Based on high-level estimates, a
reasonable combination of technologies could reduce emissions –5 MMtCO2e, at an average cost
of $163 per metric ton (t). Alternative combinations could raise or lower the cost, as well as
raise or lower the amount of reductions. Every combination of the eight technology options was
t:II:I
not rigorously analyzed, but the MAG is unanimous in recommending that such analysis is
necessary to evaluate the best mix of options.
The scenarios presented here can be grouped into categories of emissions avoided, conservation
and energy efficiency, and emissions captured and stored [carbon capture and storage and/or
reuse (CCSR)].
The MAG analyzed the eight options assuming 2008 O&G activity. Production of estimated
O&G reserves in Alaska could create dramatic increases in production activity, with
corresponding upward pressure on GHG emissions. If those predicted O&G reserves are not
produced, the overall economics of the Trans Alaska Pipeline System would deteriorate, with a
corresponding upward pressure on costs, but a downward trend for GHG emissions.
Quantification of options OG -2 through OG -8 for emission reduction potential, net present value
(NPV), and cost-effectiveness is provided in Table 6-1. For OG -1, the broad nature of
conservation measures precluded specificity that would allow economic quantification to be
conducted. A unique situation exists on the North Slope, in that the natural gas used to power
the operations has no "real" cost to the producers. Because of that, until that gas can be sold (i.e.,
a gas pipeline exists), there is no economic credit given to saving fuel. However, there are at
least two significant values to natural gas on the North Slope:
• The gas is currently re -injected into the oil reservoir, maintaining pressure and increasing
ultimate oil recovery.
• In the case of a gas pipeline, gas saved will eventually become gas sold.
Both these aspects were considered long term and difficult to quantify, and their value was not
represented in the relatively short-term quantifications presented here.
Oil and Gas Policy Descriptions
The O&G sector includes emissions and mitigation opportunities related to O&G operations,
including exploration, production, transport, and refining of O&G. In addition, geologic
sequestration is included, regardless of the source of the emissions (as in OG -8.)
The O&G quantification followed all economic assumptions as directed by the MAG (including
a 5% discount rate), with the exception of the amortization date. Due to the large and phased
nature of the capital investments inherent in several of the options, the MAG chose to amortize
out to 2035, instead of 2025, resulting in a reduced cost per ton estimate for GHG reductions.
M
Table 6.1. Summary List of Alaska Climate Change Mitigation Policy Recommendations
6�C1
GHG Reductions (MMtCO2e)
Net
Present
Cost-
PolicyValue
No.
Policy Options
(million
Effective -
ness
Levelof
Total
2015
2020
2025
2010-
2009$)
(2009$
Support
2025
2010-
/tCO2e)
2025
OG -1
Best Conservation Practices
Not Quantified
Unanimous
OG -2
Reductions in Fugitive
Methane Emissions
0.2
0.2
0.2
3.2
$181.4
$57
Unanimous
Electrification of North
Slope Oil and Gas
OG -3
Operations, With
-
3.0
4.4
26.6
$7,791.0
$293
Unanimous
Centralized Power
Production and Distribution
Improved Efficiency
OG -4
Upgrades for Oil and Gas
0.5
2.1
2.1
19.7
$1,600.1
$81
Unanimous
Fuel -Burning Equipment
Renewable Energy
OG -5
Sources in Oil and Gas
0.7
0.7
0.7
8.0
$2,603.4
$327
Unanimous
Operations
Carbon Capture (From
North Slope High -0O2
OG -6
Fuel Gas) and Geologic
-
0.9
0.9
7.8
$1,368.8
$176
Unanimous
Sequestration With
Enhanced Oil Recovery
Carbon Capture (From
Exhaust Gas at a
OG -7
Centralized Facility) and
Geologic Sequestration
-
1.8
1.8
16.1
$3,094.1
$192
Unanimous
With Enhanced Oil
Recovery
Carbon Capture (From
Exhaust Gas) and
Unanimously
OG -8
Geologic Sequestration
0.7
0.7
0.7
8.0
$7,937.7
$994
not
Away From Known
recommended
Geologic Traps
at this time
Sector Total Before
Adjusting for Overlaps
2.1
9.4
10.8
89.4
$24,576.5
Sector Total After
Adjusting for Different
0.21
6.7/
10.0/
62.9/
$15,300/
$243/
Implementation
0.8
4.8
4.8
46.2
$7,500
$163
Strategies*
Reductions From Recent
Actions (CAFE
0
0
0
0
0
Standards)
6�C1
NOTES:
Policy options were modeled on generic, publicly available industry data from North Slope oil and gas operations.
Thus, the results must only be used to help direct more precise modeling, which would include, for example, taxes,
royalties, individual oil and gas facility data, and specific engineering studies.
Net Present Value" used in the summary table above would be regarded in the oil and gas industry as "Net Present
Cost." Positive numbers in the two right-hand columns indicate that an investment in the policy would generate a
financial loss.
"Net Present Value" and "Cost -Effectiveness" values do not apply in Cook Inlet or any other oil and gas basin, due to
vastly different production life, geographic distribution, and physical constraints.
Due to the analytical methodology, "Cost Effectiveness" is likely lower than the break-even cost of carbon needed to
make a project economically feasible.
None of the modeling included the impact of short-term production loss to implement the policies OG -2 though OG -7.
These policies are technology-based opportunities for reducing greenhouse gas emissions (GHG), not policies to be
directly implemented by Alaska.
The GHG savings estimates presented here are not additive. Policies have significant, sometimes complete, overlap
in targeted GHG emissions.
CAFE = corporate average fuel economy; CO2 = carbon dioxide; GHG = greenhouse gas; MMtCO2e = million metric
tons of carbon dioxide equivalent; $/tCO2e = dollars per metric ton of carbon dioxide equivalent; OG = oil and gas.
'This range shows emissions reductions and costs if only the more cost-effective options were implemented, i.e.,
dropping sequestration away from geologic sources (013-8) and keeping the rest (the first set of figures). The second
set represents removal of the central electrification (OG -3) and sequestration away from geologic sources (OG -8).
OG -1. Best Conservation
This option relates to companies' ongoing efforts to reduce GHG emissions using common-sense
measures that minimize fuel consumption. Specific initiatives are already being developed to
suit the needs of specific conservation opportunities.
The option is largely behavior -based and is achieved by continuing to encourage individuals to
make good conservation choices and, through repetition, for those choices to become habits.
Implementing this option does not require large capital projects. A specific model and set of
assumptions were not developed from which economic quantification could be conducted, as
indicated in the discussion above.
OG -2. Reductions in Fugitive Methane Emissions
6� JL.L
This option relates to the technical and economic feasibility of reducing fugitive and wet -seal
emissions by first determining where leaks occur, and then planning the optimal corrections.
Steps for this determination are:
• Official refinements to fugitive methane inventories developed by the Alaska Department of
Environmental Conservation and the Center for Climate Strategies in 2007 (current
inventories dramatically overestimate the fugitive emissions).
• Assessment of potential reductions and associated costs to reduce fugitive and wet -seal
methane emissions.
6'difil
OG -3. Electrification of North Slope Oil and Gas Operations, With Centralized Power
Production and Distribution
This option relates to the technical feasibility and economics of electrification of the largest
North Slope O&G operations with centralized power production and distribution. The
centralized power system could eventually be configured to serve Alaska's major O&G
operations throughout the North Slope, and possibly to known expected expansion areas.
Electrifying the hydrocarbon recovery activities, while centralizing the power generation
turbines and taking advantage of improved efficiencies, could significantly reduce the North
Slope hydrocarbon recovery activity GHG emissions by up to 36%. This has some dependency
on the scale of the electrification of the hydrocarbon recovery activities. Very few activities
could not be converted from fuel -burning power to electrical power.
—
Improved Efficiency Upgrades for Oil and Gas Fuel -Burning Equipment
This option relates to the technical feasibility and economics of improving the efficiency of fuel -
burning equipment at North Slope O&G operations.
Upgrading any less efficient turbines to more efficient turbine technologies provides potential to
significantly reduce the North Slope hydrocarbon recovery activity GHG emissions, by reducing
the amount of fuel burned. The GHG savings has some dependency on the scale of the upgrades
and the change in efficiency. Small changes in efficiency probably will not be economically
viable. Some equipment is already at a high efficiency and would not be upgraded. Looking at
this as a stand-alone option, analyses suggest a gross estimate of about 17.5% reduction in GHG
emissions through the upgrading of fuel -burning equipment.
Renewable Energy Sources in Oil and Gas Operations
This policy relates to the technical feasibility and economics of augmenting electrical power
production at the Central Production Facility at Prudhoe Bay with wind power. Electrifying the
hydrocarbon recovery activities, through the use of renewable energies to augment electric
power production, has the potential to reduce North Slope hydrocarbon recovery activity GHG
emissions relative to the amount of power that could be replaced. This option is dependent on
OG -3, electrification of O&G facilities.
OG -6. Carbon Capture (From North Slope High -0O2 Fuel Gas) and Geologic Sequestration
With Enhanced Oil Recovery
This option relates to the technical feasibility and economics of CO2 separation from produced
gas, transport, and geologic sequestration from gas used for fuel in and around Prudhoe Bay.
The technical goal is to remove and sequester the 101/o-12% CO2 from the natural gas produced
at Prudhoe before that gas is burned in power generators. The geologic sequestration should
utilize a reservoir where EOR can improve the economics.
6-12
OG -7. Carbon Capture (From Exhaust Gas at a Centralized Facility) and Geologic
Sequestration With Enhanced Oil Recovery JA
This option relates to the technical feasibility and economics of post -combustion CO2 capture,
transport, and geologic sequestration in or near existing Alaska O&G fields, including the upside
of initial EOR.
Quantification for this option is focused on the Central Gas Facility (CGF) at Prudhoe Bay, as
preliminary studies have shown CCSR would have the highest possible efficiencies at this
facility due to the concentration and sizes of the turbines. The CGF accounts for —16% of all
North Slope emissions.
OG -8. Carbon Capture (From Exhaust Gas) and Geologic Sequestration Away From Known
Geologic Traps
This option relates to the technical and economic feasibility of CO2 capture, transport, and
geologic sequestration far from O&G infrastructure, in areas where a nearby storage reservoir is
not proven. The capture and storage aspects, while similar in many aspects to those described in
OG -7 for exhaust gas sources near existing Alaska O&G fields, differ in that there are no known
reservoirs nearby. That means either a long pipeline needs to be built to either the North Slope
or Cook Inlet, or an exploration program to prove up an appropriate storage reservoir needs to be
executed.
This option also deals with emissions outside the O&G sector (Figure 6-4).
Figure 6-4. Interior Alaska CO2e emissions sources, including non-O&G sources
AFB = Air Force Base; CO2e = carbon dioxide equivalent; MMtCO2e = million metric tons of carbon dioxide
equivalent; OG = oil and gas; UAF = University of Alaska -Fairbanks
6-13
0.5
0.45
0.4
0.35
C4
0.3
U
0.25
0.2
-- — ■ Coal
0.15
■ Natural Gas
0.1
■ Diesel/Oil
0.05
-- _-_
0
— - -
FlintHills
Aurora
UAF North Healy Eilson
North
Chena
Power Pole Power AFB
Pole
Power
Plant Power Plant
Refinery
Plant
Plant
AFB = Air Force Base; CO2e = carbon dioxide equivalent; MMtCO2e = million metric tons of carbon dioxide
equivalent; OG = oil and gas; UAF = University of Alaska -Fairbanks
6-13
December 18, 2018
Vi .r `ice V L. U
Hollis French, Chair and Commissioners
Alaska Oil and Gas Conservation Commission DEC $ 2013
333 W. 7th Avenue®�
Anchorage, AK 99501
CC
Subject: 12/18/18 Public Hearing to Prevent all Non -Emergency Venting and Flaring
Docket #: OTH-18-057
Chairman French and Commissioners:
Thank you for the opportunity for public comments afforded by this public hearing. I am
unable to participate in the hearing and therefore submit these written comments.
I urge the Commission to exercise its authority under 20 AAC 25.235 and direct your
staff to undertake a review of the required reports submitted by oil and gas producers when
they release, vent, or burn natural gas. It is my understanding that the producers' operations
fairly routinely result in the venting or flaring of natural gas at their North Slope and Cook Inlet
facilities, which appear to not meet the intent of these regulations that limit gas disposition
generally only to emergency situations, de minimis amounts, or under lease terms. According to
20 AAC 25.235(e), the AOGCC has the obligation to review flaring or venting of gas incidents
and classify as waste any release, burning or escape that violates good oil field engineering
practices and conservation purposes. Repeated producer reports of "emergency" incidents
does not sound like good practices and certainly does not conserve the gas resource. In the late
1970s as a US Fish & Wildlife biologist I observed North Slope gas flaring as an unfortunate
practice; it's an inexcusable waste 40 years later!
While I recognize that the AOGCC focuses on oil/gas field operations, the commission
should also acknowledge that methane, the major component of natural gas, becomes a highly
potent greenhouse gas when emitted from oil and gas production facilities. A July 2018 report
published in the journal Science indicates that methane emissions from U.S. oil and gas
operations are substantially higher than the U.S.EPA has estimated and Alaska's emissions are a
contributor to the climate impact. As a climate conscious world becomes more aware of the
impacts of methane emissions, oil and gas producers will come under increasing fire for their
leaks, venting and flaring. The AOGCC will also be criticized for not limiting the waste of natural
gas, and its climate impact. The public wants cleaner energy!
Some reputable operators elsewhere in U.S comply with current methane rules. Some
states, such as Colorado and Wyoming, have worked cooperatively with industry to establish
methane standards that work for business and the environment. Indeed, ExxonMobil issued a
May 23, 2018 press release wherein it touted its commitment to a 25% decrease in natural gas
flaring and 15% decrease in methane emissions by 2020 (compared with 2016 levels).
ExxonMobil and BP signed onto a 2017 set of guiding principles for reducing methane
emissions. It's time to put their endorsement into action on Alaska's North Slope!
And the AOGCC can jump start this by conducting a serious review of the 20 AAC
25.235(b) reports submitted by Alaska's oil and gas producers. The AOGCC can constructively
regulate the industry and get the companies to improve their field practices, clean up their act
and stop wasting the gas resources.
Thank you for your time and attention to this matter.
Sincerely,
Gretchen Keiser
3271 Nowell Ave
Juneau, AK 99801
Alaska Oil and Gas Association
121 W. Fireweed Lane, Suite 207
Anchorage, Alaska 99503-2035
Phone: (907) 272-1481 Fax: (907) 279-8114
Email: moriarty@aoga.org
Kara Moriarty, President & CEO
December 18, 20183q
Commissioner Hollis French, Chair DEC 18 2018
Alaska Oil & Gas Conservation Commission p�
333 W. 7th Avenue A®IG �l C
Anchorage, AK 99501
Submitted by E -Mail to: iodv.colombiena alaska.gov
Re: Kate Troll Petition re: Non -Emergency Venting /
Flaring.
Dear Commissioner French:
Please accept the following brief comments opposing Ms. Troll's petition regarding non -emergency
venting and flaring. The Alaska Oil and Gas Association ("AOGA") is the professional trade
association for the oil and gas industry, representing the majority of oil and gas exploration,
production, refining and transportation companies in Alaska. In short, AOGA's membership endorses
the Alaska Oil & Gas Conservation Commission's ("AOGCC") current regulation' regarding venting
and flaring.
Ms. Troll's petition seeks to prevent all non -emergency venting and flaring, a suggestion which is not
only impractical but also unsafe. As a best management practice, oil and gas operators use all
reasonable precautions to prevent the waste of oil and gas resources. However, the venting or flaring of
some natural gas is a practically unavoidable consequence of oil and gas development.
For example, during routine operations including, but not limited to, well drilling, production testing,
and/or well purging, some gas that reaches the surface cannot be feasibly captured, used, or sold. When
this occurs, the gas must either be combusted or released to the atmosphere. During normal production
operations, as well volumes fluctuate or if there is an equipment failure, the production facility needs
to have a safe place for all the excess volume of gas to be immediately relieved. Routine and
continuous flaring of pilot and purge gas during non -emergency situations is a key component to the
safe development of oil and gas reserves. Pilot and purge gas is continuously flared as part of the
facility's safety design to safely ignite excess gas brought to surface during emergency situations such
as process upsets, equipment failures, and emergency shut downs.
Flare systems are designed to the American Petroleum Institute's ("API") standards to maximize
facility safety, and minimize flare gas volumes. Further, flaring, venting, and fugitive emissions by the
oil and gas industry are currently regulated in Alaska by not only AOGCC, but also the Alaska
Department of Environmental Conservation ("DEC"), Environmental Protection Agency ("EPA"), and
'See: 20 AAC 25.235.
Commissioner Hollis French, Chair
Alaska Oil & Gas Conservation Commission
December 18, 2018
Page 2
the Bureau of Land Management (`BLM") on federal leases. The combination of these current
regulations ensure that all flaring or venting operations are done safely with minimal waste of
resources.
Based on the foregoing, AOGA's members endorse AOGCC's regulation in its current form and
respectfully request it remain unchanged.
Respectfully submitted,
KARA MORIARTY
President & CEO
i
NOTICE OF PUBLIC HEARING
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION COMMISSION
Re: Docket Number: OTH-18-057
Petition to hold a public hearing to prevent all non -emergency venting and flaring
By letter dated November 5, 2018, Kate Troll requested a hearing to be held by the Alaska Oil and
Gas Conservation Commission (AOGCC).
The request for a hearing is granted. A public hearing will be held December 18, 2018 at 10:00
a.m. at 333 West 7' Avenue, Anchorage, Alaska 99501.
If, because of a disability, special accommodations may be needed to comment or attend the
hearing contact the AOGCC at (907) 279-1433 no later than December 13, 2018.
Hollis S. French
Chair, Commissioner
NOTICE OF PUBLIC HEARING
STATE OF ALASKA
ALASKA OIL AND GAS CONSERVATION C1
Re: Docket Number: OTH-18-057
Petition to hold a public hearing to prevent all non -emergency venting and flaring
By letter dated November 5, 2018, Kate Troll requested a hearing to be held by the Alaska Oil and
Gas Conservation Commission (AOGCC).
The request for a hearing is granted. A public hearing will be held December 18, 2018 at 10:00
a.m. at 333 West 7`h Avenue, Anchorage, Alaska 99501.
If, because of a disability, special accommodations may be needed to comment or attend the
hearing contact the AOGCC at (907) 279-1433 no later than December 13, 2018.
//signature on fileH
Hollis S. French
Chair, Commissioner
STATE OF ALASKA
ADVERTISING
ORDER
NOTICE TO PUBLISHER
SUBMIT INVOICE SHOWING ADVERTISING ORDER NO., CERTIFIED
AFFIDAVIT OF PUBLICATION WITH ATTACHED COPY OF ADVERTISMENT.
ADVERTISING ORDER NUMBER
p f
AO-I9-013
FROM: AGENCY CONTACT:
Jody Colombie/Samantha Carlisle
Alaska Oil and Gas Conservation Commission DATE OF A.O. AGENCY PHONE:
333 West 7th Avenue 11/9/2018 907 279-1433
Anchorage, Alaska 99501
DATES ADVERTISEMENT REQUIRED:
COMPANY CONTACT NAME:
PHONE NUMBER: ASAP
FAX NUMBER:
(907) 276-7542
TO PUBLISHER:
Anchorage Daily News, LLC
SPECIAL INSTRUCTIONS:
PO Box 140147
Anchorage, Alaska 99514-0174
TYPE OF ADVERTISEMENT:
r LEGAL r DISPLAY W CLASSIFIED i— OTHER (Specify below)
DESCRIPTION PRICE
OTH-18-057
Initials of who prepared AO:
Alaska Non -Taxable 92400185
SUBMIT INVOICE SHOWING ADVERTISING
ORDER NO., CERTIFIED AFFIDAVIT OP
PUBLICATION WITH ATI'ACnEDCOPV OF
ADVERI'ISMENT TO:
AOGCC
333 West 7th Avenue
Anchorage. Alaska 99501
Pae I of l
Total of
All Pa es $
REF Type Number
Amount Date Comments
1 PVN IVCO21795
2 AD AO-19-013
3
4
FIN AMOUNT SY Act. Template PGM LGR Object FY DIST LIQ
1 19 A14100 3046 19
2
3
4
5
Purchasing Au r Na e:'H
Purchasing Authority's Signature Telephone Number
1. A.O. andrece mg agency na a st appear on all invoices and documents relating to this purchase.
2. The state Is registered for tax fro B sactions under Chapter 32, IRS code. Registration number 92-73-0006 K. Items are for the exclusive use of the state and not ter
resale.
DISTRIBUTION:
Division Fiscal/Original AO
Copies: Publisher (faxed), Division Fiscal, Receiving
Form: 02-901
Revised: 11/9/2018
Carlisle, Samantha J (DOA)
From:
Sent:
To:
Subject:
Attachments:
Please see attached.
Carlisle, Samantha J (DOA)
Friday, November 9, 2018 10:45 AM
AOGCC Public Notices@ list.state.ak.us
Public Hearing Notice OTH-18-057
Public Hearing Notice OTH-18-057.pdf
Samantha Carlisle
Executive Secretat-y- III
Alaska Oil and Gas Conservation Commission
333 West 7'f Avenue
Anchorage, AK 99501
(907) 793-1223
CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information from the Alaska Oil and Gas
Conservation Commission (AOGCC). State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and/or
privileged. information. The unauthorized review, use or disclosure of such information may violate state or federal law. If you are an
unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake
in sending it to you, contact Samantha Carlisle at (907) 793-1323 or Samamha.Carlisle..iTalaska.eov.
Bernie Karl
K&K Recycling Inc.
P.O. Box 58055
Fairbanks, AK 99711
George Vaught, Jr.
P.O. Box 13557
Denver, CO 80201-3557
Gordon Severson
3201 Westmar Cir.
Anchorage, AK 99508-4336
Darwin Waldsmith
P.O. Box 39309
Ninilchik, AK 99639
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P.O. Box 60868
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nniruncnnc erooawucao
STATE OF ALASKA
THIRD JUDICIAL DISTRICT
Sarah Jennett
being first duly sworn on oath deposes and says
that he/she is a representative of the Anchorage
Daily News, a daily newspaper. That said
newspaper has been approved by the Third
Judicial Court, Anchorage, Alaska, and it now
and has been published in the English language
continually as a daily newspaper in Anchorage,
Alaska, and it is now and during all said time
was printed in an office maintained at the
aforesaid place of publication of said newspaper.
That the annexed is a copy of an advertisement
as it was published in regular issues (and not in
supplemental form) of said newspaper on
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and that such newspaper was regularly
distributed to its subscribers during all of said
period. That the full amount of the fee charged
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Subs ed and swam to be r me
this 1 th day of November, 18
Notary Publi in and for
The State f aska.
Third Division
Anchorage, Alaska
MY COMMISSION EXPIRES
alal
/ r
NOTICESTATE OF ALASKAR���V
ALASKA OIL AND GAS CONSERVATION COMMISSION
Re: Docket Number: OTH-18-057 prevent all non -
Petition to holda public hearing to p
emergency venting and flaring
By letter dated November 5, 2018, Kate Troll requested a hearing
to be held by the Alaska Oil and Gas Con$ervabon Commission
(AOGCC). ..
The ic
held December 18, hearing20t 1granted0 a. . t 3331west 7th Avewill nue
Anchorage, Alaska 99501.
If, because of a disability, special accommodations may be
(90 d 27to 9-1433 no later thaan Decemberd the 13, 201contact the AOGCC at
//signature on file//
Hollis S. French
Chair, Commissioner
"%-A_ .
Notary Public
BRITNEY L. THOMPSON
State of Alaska
—mmission Fxpires Feb 23, 2019
1
November 5, 2018
Kate Troll
PO Box 240128
Douglas, AK 99824
RECEIVED
Hollis French, Co -Chairman f yU 0 8 2018
Dan Seamount, Commissioner®�7 V C
Cathy Foerster, Commissioner
Alaska Oil and Gas Conservation Commission
337 W. 7' Avenue
Anchorage, AK 99501
Dear AOGCC,
I submitted a petition signed by forty-six Alaskans over a month ago and have not gotten a
response. I would like the Commission to consider my petition as falling under AS 31.05.060. I
am by this letter moving the commission to consider my petition at a public hearing.
Sincerely yours,
/1�
Kate Troll
outheast
onference
N
OCT G GU!
i' l"1 �� x
-, r
t.a
612 W. Willoughby Ave. Suite B PO Box 21989 Juneau, AK 99802-1989 (907) 523-4350 fax 463-5670 www.seconference.org
Hollis French, Co -Chairman
Dan Seamount, Commissioner
Cathy Foerster, Commissioner
Alaska Oil and Gas Conservation Commission
337 W. 7`h Avenue
Anchorage, AK 99501
We Alaskans implore you to prevent all non -emergency venting and flaring from Alaska oil and gas wells.
As you are aware methane is a potent greenhouse gas, roughly 30 times more potent that carbon
dioxide. Furthermore, the Alaska Oil and Gas Conservation Commission's existing policies call for
minimizing "waste." (20 AAC 25.235). Stopping the venting and flaring of methane on the North Slope
and Cook Inlet is considered to be the low -hanging fruit for Alaska to take a meaningful step in reducing
harmful greenhouse gas emissions. In fact, it was a recommendation unanimously supported by the oil
and gas representatives involved in Governor Palin's Mitigation Advisory Group (March 2008); yet no
government official has ever acted on this mitigation recommendation. With climate change now front
and center in all regions of Alaska, the Commission should feel further obligated to minimize this
harmful waste of methane.
Print Name- gn u e A aska City of Residence
1
� k��
$.-ivaQ�w jlor��2
U
Hollis French, Co -Chairman
Dan Seamount, Commissioner
Cathy Foerster, Commissioner
Alaska Oil and Gas Conservation Commission
337 W. 7`h Avenue
Anchorage, AK 99501
We Alaskans implore you to prevent all non -emergency venting and flaring from Alaska oil and gas wells.
As you are aware methane is a potent greenhouse gas, roughly 30 times more potent that carbon
dioxide. Furthermore, the Alaska Oil and Gas Conservation Commission's existing policies call for
minimizing "waste." (20 AAC 25.235). Stopping the venting and flaring of methane on the North Slope
and Cook Inlet is considered to be the low -hanging fruit for Alaska to take a meaningful step in reducing
harmful greenhouse gas emissions. In fact, it was a recommendation unanimously supported by the oil
and gas representatives involved in Governor Palin's Mitigation Advisory Group (March 2008); yet no
government official has ever acted on this mitigation recommendation. With climate change now front
and center in all regions of Alaska, the Commission should feel further obligated to minimize this
harmful waste of methane.
Print Name Signature laska City of Residence
/�
M
