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The Abatement Cost of Methane Emissions from Natural Gas Production PDF

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The Abatement Cost of Methane Emissions from Natural Gas Production ∗ Levi Marks PRELIMINARY AND INCOMPLETE; PLEASE DO NOT CITE Abstract The fact that natural gas produces only about half as much carbon dioxide as coal when burned to produce electricity has led many to believe gas will play a vital role in the transition to sustainable energy. However, whether gas could serve as a “bridge fuel” critically depends on the cost of controlling methane emissions from the gas sup- ply chain. This paper examines firm behavior in response to changes in gas prices to empiricallyestimatetherelationshipbetweenpricesandmethaneemissionratesforthe extraction segment of the industry. Because optimally-behaving firms mitigate leakage onlyuptothepointatwhichtheirmarginalcostofabatementequalsthewholesalegas price, this estimated relationship can be mapped to an abatement cost curve. Results indicate that methane emissions from natural gas production can be reduced at very low cost relative to greenhouse gas emissions from other sectors. In particular, I esti- mate that a relatively modest emissions tax on methane equivalent to a $5/ton price on carbon would decrease methane emissions by 56 percent. Furthermore, extending these results to make an out-of-sample prediction, I estimate that a tax designed to fully internalize the social cost of methane would decrease emissions by 75 percent while increasing the net cost of gas extraction by less than one percent. This finding indicates natural gas is likely to remain highly competitive as an energy source under methane regulation. JEL: D22, H23, Q35, Q4, Q54 ∗UniversityofCalifornia,SantaBarbara. Email: [email protected]. IamgratefultoOlivierDeschenes, Matthew Zaragoza-Watkins, Kyle Meng, Ted Frech, Kristina Mohlin, David Lyon, Catherine Hausman, Cl´ement de Chaisemartin, Sarah Bana, and Matthew Wibbenmeyer for invaluable feedback and suggestions that helped shape this paper. I would also like to thank the Environmental Defense Fund for assistance in acquiring dataon natural gasproduction andprices. All errors are mine. This version: September 19, 2018. The most recent version can be downloaded here. 1 Introduction Naturalgashasmanyfeaturesthatmakeitanattractiveenergysourceformitigatingclimate change. It is abundantly available, the technology and infrastructure necessary to utilize it on a large scale are already in place today, and it is cost-competitive with coal for electricity generation while only producing about half the burn-point greenhouse gas (GHG) emissions. Furthermore, quick ramp rates make gas-fired generation well-suited for balancing out the intermittency of wind and solar power. These features have motivated the idea the transition to low-carbon energy could be made more efficient by switching first from other fossil fuels to gas and later from gas to renewables.1 However, this “bridge fuel” narrative has recently been called into question by a growing body of scientific studies uncovering the problem of methane leakage. Methane (CH ), the principal component of natural gas, is itself a greenhouse gas that 4 is shorter-lived than carbon dioxide (CO ) but vastly more potent, with warming effects 2 about 30 times stronger than CO on a 100-year time horizon.2 Alvarez et al. (2012) cal- 2 culate that if more than 3.2 percent of total production escapes into the atmosphere before being combusted for power production, natural gas is actually more harmful than coal on a warming-per-MWh basis. While there is still considerable uncertainty as to how much methane is presently being emitted, the true figure is likely to be in the neighborhood of that threshold, as most estimates range from 2 to 4 percent of total production (Alvarez et al., 2018; Sanchez & Mays, 2015; Moore et al., 2014). A comprehensive climate change mitigation policy that fails to account for methane leakage will therefore not only pass over low-cost abatement opportunities, but will also result in over-substitution to gas from other fossil fuels. On the other hand, if climate regulation does account for methane leakage, the continued cost-competitiveness of gas will 1See, for example, Jenner & Lamadrid (2013), Levi (2013), and Brown et al. (2009). 2This figure is drawn from the IPCC’s Fifth Assessment Report and is the factor used by the EPA’s Green- house Gas Reporting Program, a primary data source for this paper. Estimates of the 100-year warming potential of CH range from about 28-36 times that of CO (IPCC, 2013). 4 2 2 depend on the cost of reducing CH emissions from the gas supply chain. This paper informs 4 this question and others related to the development of methane regulation by estimating a marginal abatement cost curve (MACC) for the natural gas extraction industry, which currently accounts for nearly three-fourths of total methane emissions from the gas supply chain in the United States (EPA, 2017). The estimated MACC implies substantial low-cost GHG abatement opportunities com- pared to other sectors. In particular, I predict that an emissions tax or permit price on methane equivalent to a $5/ton carbon price would reduce emissions by roughly 56 percent.3 This represents a decrease of about 46 million tons of CO -equivalent emissions per year at 2 an annual net cost of $73 million, which is less than 0.1 percent of the wholesale value of all gas produced in the United States.4 Furthermore, though it is an out-of-sample prediction, I estimate that a methane price designed to fully internalize its social cost would reduce emissions by about 75 percent at a net cost of only $280 million.5 My empirical strategy relies on spatially linking natural gas production facilities to geographically-dispersedtradinghubstoexaminehowCH emissionratesrespondtochanges 4 in wholesale gas prices. I estimate this relationship using data on emissions from the EPA’s Greenhouse Gas Reporting Program (GHGRP), a federally-mandated survey covering the period from 2011-2016, and data on market prices and extraction activity from SNL and DrillingInfo, respectively.6 Because in this setting the pollutant itself is also a priced com- 3Note that accurately monitoring CH emissions from the gas supply chain presents a significant challenge 4 to successfully implementing an emissions tax or trading program at this time. Unlike smokestack CO 2 emissions,fugitiveCH emissionsareinherentlydifficulttomeasure. However,technologicaladvancements 4 arerapidlyloweringmonitoringcostsandmarket-basedinstrumentsmaystillbeeffectivelydeployedunder conditions of imperfect measurement (Montero, 2005; Cremer & Gahvari, 2002). 4This figure represents only physical costs and sets aside questions of how tax or permit revenue might be distributed. 5Average annual gas prices range from about $2-$6/Mcf over the study period, whereas the social cost of methane is about $27/Mcf. This figure is for emissions generated in 2020 assuming a 3 percent discount rate and normalized to 2018 dollars (EPA, 2016). 6While the GHGRP is the most comprehensive dataset of methane emissions currently available, it is importanttonotethatitdoesnotprovideadirectmeasurementofemissions,butratheranestimatebased onequipmentcountsandemissionfactors,recordsoffirmactivity,andvariousotherinputs. Asisdiscussed in detail in Section 3, in-depth scientific measurement studies have shown that it is relatively noisy fails to capture some important sources of CH emission sources altogether. The empirical strategy used in this 4 paper is designed to address these challenges to make use of the signal that is available in the GHGRP. 3 modity, the estimated relationship between abatement and price can be directly mapped to a relationship between abatement and cost. In other words, if firms are rational and there are no market failures, they will choose a level of leakage abatement that equates the expected value of a potentially captured unit of gas equal to the cost of the abatement activity re- quired to capture it. A hypothetical tax or permit price applied to methane emissions would therefore have the same effect on firms’ emitting behavior as would an increase in wholesale gas prices. I use this condition to simulate how firms’ emissions would change following the implementation of methane pricing, then aggregate these results to construct a sector-wide marginal abatement cost curve. Instead of calculating abatement costs using a bottom-up engineering approach, this em- pirical strategy relies on actual firm behavior. While engineering estimates for the costs of various abatement activities exist and are useful,7 they are limited in their ability to ex- trapolate abatement costs for entire sectors, firms, or even individual facilities because they cannot appropriately account for opportunity costs, learning costs, and other unobserved factors. This is well-documented for GHG abatement through investments in energy effi- ciency (Fowlie et al., 2018; Gillingham & Palmer, 2014; Allcott & Greenstone, 2012) and carbon sequestration (Lubowski et al., 2006; Stavins, 1999). In contrast, by implicitly cap- turing the firm’s decision-making process to employ the most efficient abatement measures first, the approach used in this paper is able to account for all factors that are observed by the firm but unobserved by the econometrician. This approach is particularly useful for predicting the effect of regulating methane using an emissions tax or trading program, as these instruments similarly incentivize firms to exploit the least costly abatement options first. This paper is broadly related to a sizable strand of literature in economics focused on estimating abatement costs. Economy-wide GHG abatement cost curves are most commonly estimated using computational general equilibrium models (Morris et al., 2012; Chen et al., 7See, for example, ICF (2016) or EPA (2015). 4 2007; Klepper & Peterson, 2006), but have also been estimated empirically in at least one instance (Meng, 2017). Sector-specific abatement costs have been empirically estimated by Cullen & Mansur (2017), who recover an abatement cost curve for the US electricity sector, and Anderson & Sallee (2011), who estimate the marginal abatement cost of tightening fuel economy standards, among others. Another approach has been to estimate abatement costs by using firm-level financial data to analyze how abatement expenditures respond to enacted regulatory policies (Isaksson, 2005; Dasgupta et al., 2001). This paper introduces a novel identification strategy based on the fact that the pollutant is also a priced commodity, and it is the first to empirically estimate an abatement cost curve for methane emissions from a sector of the natural gas industry. While I have applied this strategy to production, it may potentially be employed to estimate CH abatement costs for the gas processing and storage 4 sectors in the future.8 This paper also contributes to an emerging literature on methane leakage. Although a substantial literature has developed in science and engineering over the last decade exploring the nature and extent of the problem,9 so far methane leakage has received little attention from economists. One notable exception is Hausman & Muehlenbachs (2016), who reveal and quantify regulatory distortions that allow gas distribution utilities to pass the cost of leaked gas through to ratepayers, which results in inefficient levels of emissions. This paper differs along a number of key dimensions. First, instead of estimating abatement costs using public utilities’ financial data (which is not available for the production sector), I exploit firms’ first order condition for leakage abatement (which is not applicable to the distribution sector due to regulatory distortions). Second, instead of using “lost and unaccounted for gas” (the difference between a utility’s purchases and sales, a measure that has its own advantages and disadvantages), I use emissions data from the GHGRP. Finally, I estimate abatement costs for the production sector, which generates the majority of CH emissions 4 8This method is not applicable to the transmission or distribution sectors, which (at time of publication) are regulated such that pipeline owners are able to pass cost of lost gas through to their customers. 9See Alvarez et al. (2018) for a synthesis of recent studies and Brandt et al. (2014) for a compact overview of earlier research. 5 from the US natural gas industry (EPA, 2017). I begin by providing further background on methane leakage in the next section. Section 2 presents a model of firms’ extraction and leakage decisions that provides intuition for the empirics. Section 3 describes data sources for emissions, production, price, and other variables used in the analysis. Section 4 presents the empirical framework and results and compares them to other estimates of abatement costs, and Section 5 concludes. 1 Background Methane accounts for about 16 percent of greenhouse gas emissions worldwide, making it the second most important greenhouse gas following carbon dioxide (IPCC, 2014). Similarly to CO , significant quantities of methane are always being released into the atmosphere by 2 natural sources (primarily wetlands and organic decomposition), but recent human activity has accelerated this flow to levels that are disrupting global equilibrium climate. The three primary anthropogenic sources are agriculture, landfills, and natural gas systems, as gas used for heating and electricity generation is composed of around 90 percent methane. Although there is still considerable uncertainty as to how much gas is being emitted by each sector, the EPA’s Greenhouse Gas Inventory (GHGI) estimates that natural gas systems are presently the largest source in the US and that production is the largest source within the industry (see Figure 1).10 Higher rates of CH emissions in production compared to other sectors are 4 consistent with a lower commodity value prior to processing, transport, and storage. Production’s share of emissions has also increased dramatically over the last few decades, up from about 50 percent in 1990 to about 72 percent in 2015. The shift is partly due to improvements in the processing, transportation, storage, and distribution segments of the supply chain, but also due to the rise in unconventional extraction technologies such as hy- draulic fracturing (Howarth et al., 2011). Natural gas consumption in the United States has 10The GHGI is an EPA emissions monitoring project that is related to, yet distinct from, the GHGRP. While the GHGRP is focused on accurately tracking emissions for high-emitting facilities, the GHGI is focused on creating a comprehensive picture of all US emissions at the industry level. 6 Figure 1: Fugitive methane emissions from the various components of the natural gas supply chain (EPA Greenhouse Gas Inventory 2015 Estimates). (return) AdaptedwithpemissionfromAEMONGFR(2014) similarly increased following the shale gas revolution, as low prices have prompted exten- sive investment in gas-fired electricity generation. Gas is expected to continue to increase its share of the US energy mix in the short and medium-term future (EIA, 2017), making it imperative to account for fugitive methane emissions in any broad-based climate change mitigation strategy. Broadly speaking, CH is unintentionally released into the atmosphere at gas produc- 4 tion facilities through leaks in extraction, initial processing, and transmission equipment. It is also intentionally vented during certain procedures in well completions, workovers, and maintenance.11 Sites that employ hydraulic fracturing of shale formations release substan- tially more methane in the well completion process, as hydraulic fluids return some gas to the surface that is either uneconomical to capture or arrives before the pipes are installed to connect the well to the rest of the network. There is a high degree of heterogeneity in leak- age rates across facilities, which is reflected both in scientific measurement studies (Sanchez & Mays, 2015; Subramanian et al., 2015) and in the GHGRP, where production facilities’ 11Well completion consists of all activities between actual drilling and extraction of gas for sale, which includes installing equipment and testing, as well as hydraulic fracturing and retrieval of fluids for tight- gas reservoirs. Workovers describe major operations to repair or stimulate gas flow at existing wells. 7 emission rates vary from less than .01 percent to over 10 percent. Finally, natural gas is often found alongside petroleum, in which case it may be either vented, flared, or collected and sold (if it is economical to do so) by wells that primarily extract oil.12 As of now, regulations on methane emissions from oil and gas production are not well- established in the United States. In late 2016, the EPA introduced performance standards for new wells, processing plants, and compression stations. In 2018, however, the EPA’s new administration proposed amendments that would greatly weaken these requirements. Also in 2016, the Bureau of Land Management (BLM) finalized a policy to require wells located on federal and tribal lands to capture high percentages of gas in place of venting and flaring on the basis of conserving federal resources. However, this policy was never implemented and its future remains uncertain. In terms of local regulations, in 2014 Colorado introduced relatively strong performance standards for new and existing wells, including equipment mandates, waste-reducingproceduresduringwellcompletion, andsemi-annualleakdetection and repair.13 2 Theory This section develops a theoretical model of the production and emission decisions faced by natural gas production firms in order to motivate the empirical analysis of firms’ abatement costs. I begin by deriving firms’ first order conditions for leakage and abatement and proceed to demonstrate how a relationship between price and abatement costs can be mapped to a relationship between a potential emissions tax and abatement costs. 12Becauseoilandgasaresooftenco-located,petroleumandnaturalgasproductionfacilitiesarenotconcisely differentiated in the datasets used in this paper. 13The EPA regulations came into effect in August 2016. Because this policy affects all production in the UnitedStates,itsimpactshouldbepickedupbytimefixedeffects. However,resultsarerobusttoexcluding 2016. I control for Colorado regulations in the empirical analysis. 8 2.1 The Firm’s Problem Consider the instantaneous profit function of a gas production firm’s operations within a single basin: π = P (Q −L )−C(Q ,L ) (1) t t t t t t P is the price of gas in period t, Q is the quantity of gas the firm extracts in t, L is the t t t quantity of gas it leaks, and C(·) is its total cost. Because the quantity of gas leaked depends on the amount of gas flowing through the facility’s equipment, it is useful to decompose leakage into the product of extraction and a leakage rate R : t π = P (1−R )Q −C(Q ,R ) (2) t t t t t t In this framework, the firm’s problem consists of choosing how much to extract alongside choosing how careful to be to avoid leaks. This characterization makes it possible to separate C(·) into costs of extraction that are unrelated to the facility’s leakage rate (i.e., costs of obtaining leases, capital costs for equipment gas does not pass through) and costs that determine the leakage rate (i.e., the additional up-front capital costs for equipment that emits less, labor costs for leak detection and repair). If we assume leakage-related costs are separable for each unit of extraction, we can re-write the firm’s profit function as the following: π = P (1−R )Q −C (Q )−Q c (R ) (3) t t t t 1 t t 2 t Here, C (·) is the total cost of extraction not related to the leakage rate and c (·) is 1 2 the per-unit cost of having leakage rate R . This decomposition allows costs not associated t with leakage to be nonlinear in production. For example, one might imagine that the cost of acquiring new leases in a given basin increases as the firm increases production because 9 the total number of leases is finite. On the other hand, costs associated the leakage rate are assumed to be the same regardless of the firm’s level of production. For example, paying a worker to inspect one well site for leaks is assumed to cost the same amount whether the firm operates 50 wells or 5,000 wells. However, c (·) is explicitly nonlinear in R —in particular, 2 t it is decreasing and convex such that it approaches infinity as the leakage rate approaches zero. This captures the intuition that, due to diminishing returns, bringing the leakage rate down from 5 percent to 4.5 percent will be significantly cheaper than bringing it down from 1 percent to 0.5 percent. The firm’s first-order condition for Q sets the marginal revenue generated by extracting t one unit of gas equal to the marginal cost of extracting it: ∂C (Q ) 1 t P (1−R ) = +c (R ) (4) t t 2 t ∂Q t Note that the firm’s marginal revenue for one unit of extraction is lower than just the gas price, as only the portion that is not leaked may be sold. In the firm’s first-order condition for R , however, the firm’s marginal revenue of avoiding one unit of leakage is simply the gas t price, since the whole unit may be sold: ∂c (R ) 2 t P = − (5) t ∂R t Equation (5) forms the basis for the empirics: When maximizing profits, the firm chooses a leakage rate that sets the price equal to their marginal cost of leakage abatement.14,15 Intuitively, if one unit of gas can be sold for P , the firm will be willing to expend up to P t t to prevent it from being lost. 14Note that −∂c2(Rt) is actually positive because c is decreasing in R . ∂Rt 2 t 15The one-period framework presented here is useful for setting up a tractable empirical model, but it oversimplifies some important temporal aspects of the firm’s true decision making process. In Appendix A.1, I extend this framework to a dynamic model and discuss empirical applications that may become possible with better emissions data in the future. 10

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mate that a relatively modest emissions tax on methane equivalent to a $5/ton Methane (CH4), the principal component of natural gas, is itself a
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