LWVUS urges the US Environmental Protection Agency (EPA) to take additional measures to reduce methane air pollution from the oil and gas industry.
February 13th, 2023
Administrator Michael Regan
Environmental Protection Agency
Office of the Administrator
1200 Pennsylvania Ave, N.W.
Washington, DC 20460
Dear Administrator Regan:
As organizations that care about public health as well as the fate of our planet’s climate, we greatly appreciate the Environmental Protection Agency’s (EPA’s) commitment to address methane emissions from new and existing oil and gas pollution under the Clean Air Act. We write to support key improvements and additional strengthening of the Supplemental Proposal to Reduce Methane and Other Harmful Pollution from Oil and Natural Gas Operations, to reduce methane air pollution from new and existing sources of oil and gas development as much and as quickly as possible.
While the best and most just solution to the climate crisis is to transition away from fossil fuels and embrace a clean energy economy, utilizing the full power of the Clean Air Act now will reduce harm to frontline communities living with oil and gas development and help curb further global warming. Reducing methane pollution from the oil and gas industry will also help capture harmful emissions. These include smog- and soot-forming volatile organic compounds, which cause serious heart and lung conditions like asthma attacks and bronchitis, and hazardous air pollutants such as benzene and xylene, known human carcinogens.
Methane pollution from the oil and gas sector is accelerating the pace of climate change and harming the health of our families and communities — and it is a problem that is only getting worse. Oil and gas infrastructure is also next to or nearby some of our most treasured natural and cultural sites on public lands, areas warming at nearly twice the rate of the rest of the country and experiencing dramatic impacts from a changing climate. There is no time to waste, and we cannot miss out on this opportunity to create the strongest standards possible under the Clean Air Act to limit pollution from the oil and gas industry.
Where EPA has proposed protective standards, the agency should follow through and finalize those standards as quickly as possible. These include eliminating the use of outdated, intentionally-polluting pneumatic controllers and requiring a transition to zero-emitting solutions, strong leak detection and repair requirements that cover all polluting wells, and a requirement that abandoned wells are subject to monitoring until closure and that oil and gas companies submit a closure plan and conduct a post-closure survey.
While we are encouraged by the November 2022 draft rule, additional improvements must be made in order to protect nearby communities and help tackle the impending climate crisis. We urge the EPA to:
● Eliminate routine flaring - The EPA must ensure that operators at wells capture associated gas and strictly limit flaring of that gas to instances in which it is necessary for safety or maintenance reasons.
● Expand the threshold for storage tanks. The supplemental rulemaking did not expand the applicability threshold for storage vessels, which are prevalent throughout communities impacted by oil and gas development.. The EPA should strengthen the standards to address emissions from storage tanks by making the standards applicable to more tanks.
● Include more robust community and third-party monitoring in the Super Emitter Response Program. The EPA must provide a clear pathway for communities and third parties to participate and engage in this program. The EPA must ensure that data from approved monitoring technologies are accessible to all, including the use of Optical Gas Imaging cameras.
These important gaps on critical issues must be addressed to prioritize public health, protect frontline communities, and hold oil and gas companies accountable. In addition to these improvements, we also urge the EPA to move as quickly as possible to implement and finalize these rules. Communities and the climate are being harmed right now. It is critical that EPA moves quickly to finalize national rules. Once the ink dries and these rules are enacted, states must quickly work to write State Implementation Plans (SIPs) to show how they will implement and enforce new federal standards on the ground. In cases where a State Implementation Plan falls short of meeting federal standards, the EPA must swiftly issue a Federal Implementation Plan (FIP) to eliminate industry self-policing and regulatory capture.
We must couple strong methane regulations to control air pollution from oil and gas development with throwing the full weight of our resources behind decarbonizing our economy to address the climate crisis. Stopgap measures like methane pollution standards will reduce climate pollution and protect communities in the short term, until this country makes the necessary transition away from dirty, dangerous fossil fuels.
See Attached Letter for Signatories