By Dr Jasmin Cooper, Research Associate, Sustainable Gas Institute
Since 2020 the EU has been proactive in its approach to tacking methane emissions and in October 2020, the Commission published its Methane Strategy (European Commission, 2020), which outlined the Commission’s goal of cutting emissions by 35-37% by 2030 (relative to 2005) across Member States. In October 2021, the EU co-launched the Global Methane Pledge (European Commission, 2021a) and in December 2021 the European Commission released their framework on how to tackle methane emissions in the energy sector (European Commission, 2021b). This framework outlines the Commissions legislative approach for how cuts to methane emissions are to be made, and how to ensure all Member States achieve the necessary cuts. The Regulation introduced addresses methane from oil and gas and coal but emissions from biomass are not included. It aims to develop a union-wide framework that is homogenous in its approach and standards, with a large focus on transparency in emissions reporting and verification. To cut methane emissions, the Regulation focuses on improving emissions monitoring and reporting, eliminating venting and flaring and establishing minimum standards in leak detection and repair.
Improve accuracy and transparency in emissions reporting
The Regulation outlines the rules on how methane emissions from oil, gas and coal production, storage, transport and distribution within the EU’s borders are to be accurately measured, reported and verified. To ensure operators are implementing the measures set out in the Regulation, each Member State must appoint at least one competent authority to oversee compliance with the Regulation. To verify emissions, independently accredited verified will review the emissions reports submitted by the operators and ensure these follow the requirements set out in the Regulation. The International Methane Emissions Observatory will be given a verification role in emissions data and the information produced will be made available to the public and the Commission.
Actions to cut emissions in the oil and gas sector
The Regulation specifies that upon entry of the Regulation, operators must submit emissions reports for all of their operated and non-operated assets on an annual basis. The first report gives source level emission estimates estimated using emission factors. In subsequent reports, emissions are estimated using direct measurement methods with emissions verification by site-level emissions measurements.
To mitigate methane emissions in oil and gas, the Regulation sets out specific rules for leak detection and repair (LDAR), venting and flaring:
Leak detection and repair
Within three months of entry of the Regulation, operators need to submit their LDAR programme, which outlines the surveys to be carried out. By month six of entry of the Regulation, all relevant components an operator is responsibility for must have been surveyed. In the surveys, a leak is defined as 500 ppm methane and all components found to emit this amount or more must be repaired or replaced immediately, or as soon as possible (but no later than five days after detection).
Limits to venting and flaring
Under the Regulation, both venting and flare are banned except under specific circumstances e.g. emergencies and malfunctions. Flaring is preferred over venting, but only when re-injection, on site utilisation or entry into a gas market is not possible for non-economic reasons. If an operator wishes to vent or flare gas, they must demonstrate that venting or flaring is necessary and must notify the necessary authorities of any venting and flaring event within 48 hours of the event initiating.
Actions to cut emission in the coal sector
To tackle methane emissions from coal mines, an approach similar to oil and gas is outlined. Specifically, the Regulation focuses on ventilation shafts in underground mines, drainage systems and open coal mines. The Regulation largely focuses on improving emissions measurement and monitoring but also prohibits venting and flaring in mines, except for emergencies. For abandoned coal mines, operators are required to measure and monitor emissions from all abandoned and closed coal mines and to report the emission measured on a yearly basis.
Addressing emissions from outside the EU’s borders
The Regulation has a large focus on transparency in emissions data but states that the Union is committed to working with exporting countries to tackle methane. To improve transparency, countries who supply fossil fuels to EU Member States are required to provide the Member State with data on methane emissions: emissions measurements, reporting and what emission abatement measures are being carried out. To aid in improving transparency in emissions data, exporting countries will be incentivised to sign up to international partnerships and coalitions that aim to cut methane emissions, such as OGMP 2.0. The Commission will assess the submitted information on data quality and detail of monitoring, reporting and emissions verification applied by the exporting country. This data will use used to create a methane transparency database, which will be made available to the public for free.
In addition to this database, the Commission will also establish a global methane monitoring tool, using satellite data and emissions data provided by operators. This tool will also be made available to the public and will be used to provide information and updates on the magnitude, occurrence and location of high methane emitting sources.
Does it go far enough?
Following on from the EU Methane Strategy, it is good to see the Commission lay out clear rules for how methane emissions are to be cut. However, while it does tackle key areas in methane abatement such as emissions data quality and accuracy, there are areas which are lacking and could be improved upon revisions to the Regulation:
- The Regulation does not outline technologies to be used in emissions monitoring, particularly in LDAR and instead chooses to allow Member States flexibility such that LDAR technologies can be innovated and developed.
- Emissions from coal outside of mining are not included. Methane can also be emitted during coal waste management, handling, processing and transportation.
- It does not specify penalties to Member States or operators who fail to meet the obligations outlined, and individual Member States are to lay down their rules on penalties. However, the Regulation does specify that penalties must be effective, proportionate and dissuasive.
- The Regulation could go further in applying pressure to fossil fuel exporters. It does not specify actions for exporters whose emissions and reporting standards are not on par with what is to be expected.
European Commission 2020. COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on an EU strategy to reduce methane emissions. Brussels, BE: European Commission
European Commission. 2021a. Launch by United States, the European Union, and Partners of the Global Methane Pledge to Keep 1.5C Within Reach [Press Release]. Brussels, BE. Available: https://ec.europa.eu/commission/presscorner/detail/en/statement_21_5766.
European Commission 2021b. Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on methane emissions reduction in the energy sector and amending Regulation (EU) 2019/942
COM/2021/805 final. Brussels, BE: European Commission