Volume of GHG Emissions From Oil Extraction/Refining in Saudi Arabia - Research Assessment Answer

Research Assessment Answer

• What is the volume of GHG emissions from oil extraction/refining in Saudi Arabia (or, if it is not possible to find this, extrapolate an estimate based on a country with a similar volume of refining)? What are the current laws governing and technologies used with respect to these processes in Saudi Arabia that are relevant for understanding GHG emissions?

• What is the mechanism that the paper would propose to implement stronger requirements? It will also be important to not only describe the technologies identified by EPA for reducing emissions from oil refinement, but to also provide the legal context in which they are applied in the United States. Under the Clean Air Act, in most jurisdictions, states will determine what constitutes Best Available Control Technology to be included in relevant permits - the EPA memo on which the paper presently relies is meant to guide states in those determinations. Refineries built or significantly modified after January 2011 are subject to pre construction Prevention of Significant Deterioration permitting under the CAA (which requires major sources, including refineries, to implement the best available control technology). BACT technology is decided on a case-by-case basis in consideration of both the emissions reduction and its cost. Since 2012, a number of petroleum refineries have made modifications significant enough to require PSD permits and these facilities have been subject to rate-based GHG emissions limits. Notably, however, EPA has not issued New Source Performance Standards for petroleum refineries under the Clean Air Act, apparently having determined that it can achieve reductions in GHG emissions through restrictions imposed on other pollutants from refineries. For a good explanation, see GHG REGULATION AND THE POLITICS OF CLIMATE CHANGE IN THE OIL AND GAS INDUSTRY, 61 RMMLF INST 11-1 (2015) , 11-18.

• Global carbon intensity of crude oil production, Mohammad
• Masnadi et al http://science.sciencemag.org/content/361/6405/851 (of note, this study indicates that Saudi Arabia has relatively low carbon intensity in terms of its oil refining because it flares little gas and has resources with low water content, which means less energy goes into treating and separating the oil). used with respect to these processes in Saudi Arabia that are relevant for understanding GHG emissions?
• What is the mechanism that the paper would propose to implement stronger requirements? It will also be important to not only describe the technologies identified by EPA for reducing emissions from oil refinement but to also provide the legal context in which they are applied in the United States. Under the Clean Air Act, in most jurisdictions, states will determine what constitutes Best Available Control Technology to be included in relevant permits – the EPA memo on which the paper presently relies is meant to guide states in those determinations. Refineries built or significantly modified after January 2011 are subject to pre-construction Prevention of Significant Deterioration permitting under the CAA (which requires major sources, including refineries, to implement the best available control technology). BACT technology is decided on a case-by-case basis in consideration of both the emissions reduction and its cost. Since 2012, a number of petroleum refineries have made modifications significant enough to require PSD permits and these facilities have been subject to rate-based GHG emissions limits. Notably, however, EPA has not issued New Source Performance Standards for petroleum refineries under the Clean Air Act, apparently having determined that it can achieve reductions in GHG emissions through restrictions imposed on other pollutants from refineries. For a good explanation, see GHG REGULATION AND THE POLITICS OF CLIMATE CHANGE IN THE OIL AND GAS INDUSTRY, 61 RMMLF INST 11-1 (2015), 11-18.

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