U.S. Environmental Protection Agency
EPA Docket Center
Docket ID No. EPAHQ-OAR-2021-0317
Mail Code 28221T
1200 Pennsylvania Ave NW
Washington, DC 20460.
January 31st, 2022
Dear Administrator Michael Regan:
Re: Docket ID No. EPA-HQ-OAR-2021-0317
We are writing in support of the U.S. Environmental Protection Agency’s efforts to cut methane pollution and urge the agency to strengthen the Proposed Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review.
Methane pollution from the oil and gas industry is fueling the climate crisis and threatening public health and safety. We need strong methane protections like those adopted in Colorado and those adopted or set to be adopted in New Mexico. These national-leading safeguards include a prohibition on routine flaring, frequent inspections for all well sites regardless of emission thresholds, increased inspections to protect disproportionately impacted communities and those living closest to well sites, and strong requirements to retrofit existing oil and gas well sites with zero-bleed or zero-emission pneumatic devices.
Each year, the oil and gas industry releases 16 million metric tons of methane into the atmosphere. Methane is a greenhouse gas more than 80 times more potent than carbon dioxide for the first 20 years it’s in the air and is responsible for a quarter of the warming that we are experiencing today. Reducing methane pollution from the oil and gas industry is the single fastest, most cost-effective way to slow the rate of warming today.
There is no time to waste. Climate change is already putting our health, our economy, our environment and communities at risk. Longer, more intense wildfire seasons costing tens of millions in damages each year and displacing families. This summer, Colorado had the worst ozone season ever on record, driven in part by oil and gas pollution and western wildfires super fueled by climate change. Most recently, tragedy struck when the destructive Marshall fire, fueled by warmer and drier than usual weather destroyed the homes and displaced thousands of Coloradans.
In southeastern New Mexico, farmers saw temperatures that averaged seven degrees above normal in 2020. In Santa Fe, a wildfire charred five square miles on the outskirts of town and darkened skies for weeks. And currently, nearly three-fourths of the state is experiencing severe drought, as state officials grapple with plans to ensure critical water supply for cities, farmers, ranchers and more.
While Colorado and New Mexico are leading the way on action to cut methane pollution, the simple truth is that states cannot go it alone. We need a strong federal floor to ensure that methane emissions from oil and gas operations are cut nationwide in order to meet President Biden’s climate goals. Also, oil and gas pollution does not stop at the state border. We need strong federal methane rules to address regional air quality problems.
Our organizations urge the U.S. EPA to strengthen the proposed methane rules through the following:
1) Making sure ALL wells, regardless of their Potential to Emit (PTE), are subject to frequent Leak Detection and Repair requirements.
2) Requirements to end routine flaring and allocating the proper enforcement to ensure unlit flares aren’t venting methane.
3) Developing a community monitoring program that engages with frontline and disproportionately impacted communities, educates and certifies community members, and requires immediate follow up on complaints filed by those certified community members.
Again, please ensure that the final proposed EPA methane rules live up to the standard set by our states.
Thank you for the opportunity to comment.
Alliance of Nurses for Healthy Environments – Colorado
Center for Civic Policy
Citizens for Clean Air
Climate Advocates Voces Unidas
Conservation Colorado
Conservation Voters New Mexico
Health Action New Mexico
Healthy Air & Water CO
League of Oil and Gas Impacted Coloradans
Moms Clean Air Force
National Parks Conservation Association
NAVA Education Project
Navajo Nation Dependents of Uranium Workers Committee
Navajo Nation Head Start Parent Policy Council
New Mexico and El Paso Interfaith Power and Light
New Mexico Sportsmen
ProgressNow Colorado
ProgressNow New Mexico
Partnership for Responsible Business
Santa Fe Green Chamber of Commerce
Sierra Club – Rio Grande Chapter
Waterkeeper Alliance
Western Colorado Alliance
Western Environmental Law Center