Wednesday, October 2, 2019

S 2469 Introduced – METHANE Act

Last month Sen Udall (D,NM) introduced S 2469, the Methane Emissions from Transmission Harm American Neighborhoods and the Environment (METHANE) Act. The bill would require DOT to promulgate regulations to detect and reduce pipeline emissions of methane.


Section 2(a) would amend 49 USC 60109; adding a new subsection (h), Leak Detection Requirements. This would give DOT 2-years (1-year to establish regulations) to require “operators of distribution pipelines shall use advanced leak detection technology” {new §60109(h)(1)}. That technology would entail {new §60109(h)(2)(A)} “a high sensitivity methane detector mounted on a vehicle or aircraft, including a drone, equipped with Global Positioning System technology, if that high sensitivity methane detector and Global Positioning System technology”. The detector/GPS unit would be required to {new §60109(h)(2)(B)}:

Collect latitude and longitude coordinates and methane concentration data simultaneously;
Measure methane concentrations in parts per billion; and
Collect data points at a rate of at least twice per second.

Emission Reduction

Section 2(b) would add a new §60142 to 49 USC. This section would give DOT 1-year to establish new regulations to require pipeline owner/operators to {new §60142(a)}:

Use the best available technology to capture natural gas when making repairs to the pipeline facility;
Use the best available technology, including, as applicable, advanced leak detection technology described in section 60109(h)(2), to search for and identify leaks in the pipeline facility;
Develop or participate in a replacement or repair program for pipeline facilities;
Report to the Secretary any event that involves a release of gas from a pipeline facility that results in an unintentional estimated gas loss of 50,000 cubic feet or more.

That ‘replacement or repair program’ would be used for facilities that {§60142(a)(3)}:

Are of a design, age, or material known to be leaky; or
Are known to be leaky based on operating history.

Section 60142(b) would require the amendment of the term ‘incident’ in 49 CFR 191.3 to include a release threshold of 50,000 cubic feet in that definition.

Moving Forward

Udall and three of his 14 cosponsors are members of the Senate Commerce, Science, and Transportation Committee. They may have enough influence to see the bill considered in Committee. The bill, however, has little chance of being approved in Committee due to the lack of support from Republicans who would object to the monitoring requirements and pipeline maintenance requirements. Similarly, this bill would have no chance to make it to the floor of the Senate.


There are some problems with the assumptions used to justify this legislation. The ‘parts per billion’ standard is not a very accurate requirement without specifying what number of parts per billion. It could range from 1ppb a technically challenging standard for a drone mounted detector to 100 ppb which should be readily achievable.

The next problem is that the measurement data required to be collected will be of little use in detecting and/or isolating any but the largest leaks. That is because two additional data points would be necessary for determining the source/rate of the leak. Those data points are wind direction and speed. Without those measurements, it would be virtually impossible to determine what the leak rate would be and difficult to track down the location. It might not even be possible to determine if the detected methane emissions were from a pipeline.

Finally, it is not clear if this is a pipeline safety measure (as one would suspect from a bill that amends PHMSA related portions of the USC) or if it is an environmental measure. For a pipeline safety bill, one would be concerned with methane concentrations approaching the flammability limits of methane (5% in air). If safety were the sole concern, then the ppb detection limit would not really be required and less expensive detectors (in the low ppm levels) could be used. If one were interested in reducing the fugitive emissions of a strong greenhouse gas, then the ppb detection limit would be more reasonable (still ignoring the lack of wind data). There is nothing, however, in the legislation that would indicate that it would be an environmental bill (which would have gone to at least one other committee for consideration).

All in all, I suspect that this is a political campaign bill that will be used to exemplify the environmental credentials of the cosponsors of the bill.

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