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In 2013, the oil and gas industry in the Bakken formation of North Dakota flared 32% of all produced gas. Analysis shows that 57% of statewide flaring occurred at wells already connected to gathering pipelines, and the majority of flaring (72%) took place on private or state-owned land. While flaring rates were higher on the Fort Berthold Indian Reservation (46%) compared to the statewide average, rates on Federal public lands were slightly lower than those on private or state land.

The Clean Air Task Force (CATF) submitted comments to the California Air Resources Board (ARB) arguing against reducing indirect land use change (ILUC) emissions estimates for biofuels. CATF contends that the GTAP model used by ARB undercounts emissions by ignoring water scarcity constraints, failing to distinguish between commercial and non-commercial forests, and using flawed yield improvement assumptions. Specifically, CATF cites research showing that accounting for irrigation constraints can increase land-based emissions by 27.5%. The document also highlights that climate-driven drought in the US Midwest may decelerate corn yields and that the current framework ignores nitrous oxide emissions from increased fertilizer use required to sustain yield growth.

The report argues that EPA's regulation of greenhouse gas (GHG) emissions from existing power plants under Section 111(d) of the Clean Air Act will not jeopardize electric system reliability. Unlike the unit-specific MATS rule, Section 111(d) employs a 'cooperative federalism' model, allowing states to develop State Implementation Plans (SIPs) with significant flexibility. This includes 'inside the fence' options like heat-rate improvements and 'outside the fence' options such as emission-averaging, carbon budgets, and demand-side reductions. The author notes that current industry conditions—including low natural gas prices, underutilized natural-gas-fired combined-cycle (NGCC) capacity, flat electricity demand, and the growth of renewables—provide a buffer that supports reliable compliance. The report concludes that as long as EPA, states, and industry engage in timely planning, the regulatory framework provides sufficient latitude to maintain power system adequacy and security.

The author contends that voluntary programs like Natural Gas STAR are insufficient to achieve necessary methane reductions in the U.S. oil and gas sector, as emissions are projected to increase by 4.5% by 2018. Citing studies from NOAA, Harvard, and the University of Texas, the text asserts that actual methane leaks are substantially higher than EPA inventories suggest. Because proven reduction technologies are cheap or provide negative costs through captured gas, the author argues that federal regulation is required to move these 'best' practices to 'standard' practice by overcoming market barriers such as diverse ownership and lack of incentive.

The report analyzes the cost-effectiveness of using infrared cameras for leak detection and repair (LDAR) programs in the oil and gas sector, based on data from over 4,000 surveys in North America.

The report analyzes data from 4,293 surveys of oil and gas facilities to determine the economic viability of LDAR programs. It finds that while many individual facilities may experience a net cost, the aggregate abatement cost for gas plants and compressor stations is negative (net benefit), and remains very low for well sites. The study concludes that the vast majority of leaks are economic to repair once identified, and that increasing survey frequency further reduces emissions while keeping abatement costs relatively low.

The document argues that mass-based emission standards are superior to rate-based standards for regulating existing power plants because they avoid production incentives that can lead to emissions 'rebound' and conflicts with existing regional trading systems. Through economic modeling, the author compares a 'fossil budget' approach (covering all fossil units) and a 'coal budget/gas rate' approach. Both core cases are projected to reduce fossil sector carbon emissions by 26% to 27% relative to 2005 levels by 2020, primarily by displacing high-emission coal generation with existing natural gas combined cycle (NGCC) units. While the fossil budget approach provides stronger long-term price signals for zero-carbon investment, the coal budget/gas rate approach results in lower near-term emission credit prices ($20/tonne vs $34/tonne), lower wholesale price increases (6.9% vs 27.9%), and lower retail rate impacts (2.3% vs 4.1%).

The Clean Air Task Force (CATF) proposes that the EPA set specific emission rate standards for fossil-fueled utility boilers and natural gas combustion turbines to reduce CO2 emissions. This strategy aims to leverage existing natural-gas capacity to displace coal generation, resulting in significant carbon and pollutant reductions with minimal impact on retail electric rates.

The Clean Air Task Force (CATF) recommends that the EPA establish specific emission rate standards for existing fossil fuel-fired utility boilers (1,450 lbs/MWh) and natural gas combustion turbines (1,100 lbs/MWh). The proposal centers on a 'model' interstate emission credit trading rule that allows states flexibility in compliance, including the use of state-specific emission budgets. Analysis by The NorthBridge Group indicates this approach could reduce electric sector carbon dioxide emissions by 27 percent from 2005 levels by 2020, resulting in a total reduction of 636 million metric tons. The report argues that nearly 70 percent of these reductions would come from optimizing fossil dispatch. Beyond climate benefits, the proposal is estimated to avoid over 2,000 premature deaths annually due to reductions in sulfur dioxide and nitrogen oxides. The total monetized health and climate benefits are estimated at $34 billion in 2020, significantly outweighing the $9.4 billion compliance cost.

The analysis compares a 'No-Policy' scenario with a 'Policy Proposal' scenario for 2020, focusing on the upstream emissions from the production, processing, and transport of fuels. Under the base case using EPA figures, the policy proposal is projected to increase total upstream greenhouse gas emissions by 9.9 million metric tons (MMT) of CO2e, consisting of a 9.6 Tg increase in CO2 and a 0.3 Tg CO2e increase in methane. A sensitivity 'high case', which assumes non-hydraulic fracturing methane emissions are twice the EPA's 2011 reports, projects a total increase of 16.9 MMT CO2e. The document notes that upstream CO2 emissions are higher for natural gas (ratio of 0.108 to stack CO2) than for coal (ratio of 0.0193 to stack CO2).

The document outlines a method for capturing methane emissions from the seal oil degassing process in centrifugal compressors. By installing high-pressure separators and demisters, operators can recover up to 99% of entrained gas for use as fuel or for reinjection into the system. The analysis indicates that these systems are a cost-effective alternative to retrofitting compressors with dry seals, offering rapid payback periods and significant reductions in atmospheric venting.

The report analyzes data from 4,293 surveys to determine the economic viability of LDAR programs. It finds that while many individual facilities may face a net cost for a survey, the aggregate effect across a group of facilities is positive due to the high value of repairing major leaks. The study concludes that LDAR using IR cameras is a low-cost abatement method for methane and VOCs, with the most economic strategy being to repair almost all identified leaks.

A coalition of organizations expresses support for the Corn Ethanol Mandate Elimination Act of 2013, arguing that the federal mandate to blend up to 15 billion gallons of corn ethanol into gasoline annually is economically damaging and environmentally harmful.

The Clean Air Task Force (CATF) argues that the U.S. Environmental Protection Agency (EPA) should use its authority under Clean Air Act section 111(d) to mandate deep carbon dioxide reductions from existing fossil fuel-fired power plants. CATF asserts that these reductions are necessary to protect public health and meet President Obama's goal of reducing U.S. greenhouse gas emissions by 17 percent below 2005 levels by 2020. Based on analyses conducted with The NorthBridge Group, CATF claims that power sector carbon pollution could be reduced by more than 25 percent from 2005 levels by 2020 without increasing monthly bills for electric ratepayers, primarily by optimizing the dispatch of existing plants to favor efficient natural gas units over inefficient coal units.

The report highlights that kerosene lamps emit significantly more black carbon than previously estimated, contributing to global warming and severe health risks. It argues that replacing these lamps with solar LED and other off-grid alternatives is a cost-effective climate mitigation strategy with substantial co-benefits. While many initiatives already exist, the report suggests the CCAC could add value by raising high-level awareness, promoting quality standards, and supporting finance for SMEs and consumers, particularly in Sub-Saharan Africa and South Asia.

The document asserts that CCS is the only available technology allowing coal and gas power generation at near-zero emissions and is a 'Best System of Emission Reduction' under the Clean Air Act. It highlights the flexibility of the EPA's proposed rules, such as an emission limit of 1100 lbs/MWh and an eight-year compliance window, which allow for partial capture. The testimony provides evidence of CCS deployment in industrial and power sectors, including projects like the Dakota Gasification Plant and the Texas Clean Energy Project. It also addresses the economic viability of CCS, noting that enhanced oil recovery (EOR) can offset costs, and argues that U.S. geologic storage capacity is sufficient to handle power sector emissions for a century or more, countering concerns about induced seismicity.

The Clean Air Task Force supports the EPA's move to regulate greenhouse gas emissions from new power plants, asserting that carbon capture and storage (CCS) is a technologically ready and necessary tool for deep emissions cuts. The authors argue that CCS can reduce emissions from stationary sources by 90% and is essential for the U.S. to reach its target of an 80 percent reduction in carbon emissions by 2050. They reject industry claims that the technology is not commercially viable, citing decades of industrial use and existing projects like the Kemper plant in Mississippi and the Texas Clean Energy Project. The document emphasizes that the Clean Air Act is intended to be "technology-forcing," driving innovation and scaling of emissions control technologies similar to the historical adoption of sulfur dioxide scrubbers.

The policy brief contends that the Renewable Fuel Standard (RFS) has failed to deliver its promised benefits, instead increasing greenhouse gas emissions, food prices, and habitat destruction through the scale-up of corn ethanol. It criticizes the EPA for allowing 'advanced biofuels' like sugarcane ethanol and soy biodiesel to fill shortfalls in cellulosic biofuel production, which the authors claim drives indirect demand for more corn ethanol or palm oil. The document advocates for legislative or regulatory actions to prevent new increases in corn used for biofuels, specifically opposing the classification of corn-starch butanol as an advanced biofuel.

The report finds that current algal biofuel technologies are not yet economically or environmentally superior to fossil fuels, citing low energy return on investment (EROI) and high greenhouse gas emissions. While theoretical yields are high, large-scale commercialization is estimated to be years or decades away. The document argues that viability depends on integrating production with wastewater treatment, industrial flue gas for CO2, and the development of marine algae strains via molecular engineering to reduce freshwater and land demands.

The Clean Air Task Force (CATF) asserts that the Renewable Fuel Standard (RFS) has failed to reduce greenhouse gas (GHG) emissions, primarily because it has functioned as a mandate for corn ethanol. CATF argues that EPA's lifecycle analyses are flawed by relying on hypothetical 2022 production scenarios and ignoring current indirect land use change (ILUC) and the 'global rebound effect.' The document claims that cumulative GHG emissions from corn ethanol produced between 2010 and 2015 are 28% higher than those from gasoline. Furthermore, it states that the RFS contributes to global food insecurity by diverting crops and driving land conversion in tropical countries. CATF suggests transitioning to zero-carbon mobility fuels, such as ammonia, electricity, and synthetic hydrocarbons, rather than relying on biofuels.