Methane is an extremely potent greenhouse gas - about 85 times more potent than carbon dioxide over a 20-year period. The EPA is proposing to weaken a regulation that requires equipment monitoring and timely repair of detected leaks. The new rule would worsen climate and other public health impacts.
(1) Submit your Comment to EPA. By December 17th, click here to submit your comment at regulations.gov.
(2) Share your comment with your members of congress.
- Senator Dianne Feinstein: (415) 393-0707, (310) 914-7300, (202) 224-3841, or email.
- Senator Kamala Harris: (415) 355-9041, (213) 894-5000, (202) 224-3553, or email.
Find your Representative:
- Rep. Mark DeSaulnier - 11th district: (510) 620-1000, (202) 225-2095, or email.
- Rep. Nancy Pelosi - 12th district: (415) 556-4862, (202) 225-4965, or email.
- Rep. Barbara Lee - 13th district: (510) 763-0370, (202) 225-2661, or email.
- Rep. Jackie Speier - 14th district: (650) 342-0300, (202) 225-3531, or email.
- Rep. Eric Swalwell - 15th district: 510-370-3322, 202-225-5065, or email.
Note: It is best to personalize or modify the wording. You do not need to be a scientist or expert to submit your comments. Add any personal experience you, your family or friends are having with the effects of climate change. You may also create your own comments using information from the references below.
My family and friends are being directly affected by climate change. The historic 2018 fires in California have destroyed the homes of friends and severely damaged public lands. Smoke from the fires reached unprecedentedly unhealthy levels in my community, far from the fires, themselves. For several days, public health experts told us to stay indoors or wear protective masks outside. My community is struggling to plan for sea level rise and reduced water supplies due to diminishing winter snow pack. It is well-documented that these are climate-related events.
Both the Intergovernmental Panel on Climate Change’s (IPCC’s) most recent report, “Global Warming of 1.5°C,” and the recent US interagency report, “The Fourth National Climate Assessment,” contain clear and overwhelming scientific evidence that global warming is proceeding faster than earlier predicted and is the result of human activities. Both reports stress that we must do much more to reduce emissions of greenhouse gases and make changes much more rapidly if we are to limit global warming to a 1.5°-2° C increase. Methane is an extremely potent greenhouse gas and a major contributor to serious smog-related respiratory illnesses. The strongest possible protections should be in place to quickly reduce and eliminate methane leaks.
Yet EPA’s proposal would weaken the current common-sense and cost-effective requirements established in 2016. The proposal would reduce the frequency of methane leak detection, double the time allowed for repairing leaks, and allow operators to use less reliable methods for detecting and eliminating leaks.
Natural gas, of which methane is the primary component, has been touted as a possible transition fuel from more polluting and warming coal and oil. But the potential for it to be less harmful depends greatly on limiting methane leaks during drilling, extraction, processing and transportation. If adopted, this rule will move us in the wrong direction, increasing releases of a highly potent greenhouse gas and worsening serious methane-related health effects. EPA’s own estimates show that the proposed rule prioritizes projected industry profits over protecting the public. It would increase methane emissions by at least 380,000 tons between 2019 and 2025 while saving the oil and gas industry $484 million. This is both inappropriate and unnecessary, since low-cost technology is readily available, and it is cost-effective for industry to control its emissions.
EPA’s analysis shows that jobs will be lost if the proposal is implemented. Currently, more than 60 firms in 45 states employ over 6000 people who manufacture and sell leak detection and control technology for this industry.
EPA’s own data shows that weakening the standards will cost the public up to $54M over seven years. But the Agency is not considering the real and much greater cost of climate and health impacts outside of the U.S. - even though it is scientifically clear that climate and health impacts are not contained within the boundaries of one country.
I urge EPA to withdraw this proposal and continue to enforce the existing methane detection and repair requirements.
Methane (CH4, the primary component of natural gas) is a greenhouse gas with a powerful global warming effect over the relatively short term. The global warming potential of methane is about 85 times that of CO2 over a 20 year time period. It has been estimated that methane emissions explain about 25% of the man-made global warming we are currently experiencing. Oil and gas production sources produce nearly 1/3 of all U.S. methane emissions. Rapid transitioning away from fossil fuels in transportation, electricity production, industry and agriculture are key to avoiding the devastating effects of unchecked global warming.
The Clean Air Act requires the EPA to identify and regulate point sources of air pollution that contribute significantly to poor air quality and hence endanger public health or welfare. Crude oil and natural gas facilities have been identified as major sources of air pollution. New Source Performance Standards (NSPS) for methane emissions from oil and gas facilities built, modified or reconstructed after 9/18/15 on public or private lands were issued by the EPA in June 2016.
The oil and gas industry petitioned the government to reconsider this 2016 NSPS Rule claiming that it was too expensive. In response the Trump administration’s EPA proposed its new rule which would scale back the monitoring and repair of methane leaks considerably. Specifically the proposed rule would include 1) reducing monitoring of methane leaks at low production well sites from semiannually to annually, 2) reducing monitoring of methane leaks at compressor stations from quarterly to semiannually or annually, 3) increasing the allotted time for repairing leaks from 30 days to 60 days, and 4) no longer requiring the “best system of emissions reductions”.
Justification for making changes to the 2016 NSPS Rule rests on faulty analysis in several areas: 1) The social cost of methane (estimate of its harmful effects on public health and the environment) was reduced from $1400 per ton of methane (used in 2016) to $53 per ton (used in 2018). The $1400 estimate was developed by an interagency working group of experts and was based on the best data and scientific methods available in 2016. This interagency group of experts was disbanded by the current EPA and instead the outdated estimate of $53 per ton used by the Bush administration was readopted. 2) Methane emissions from the oil and gas sector were assumed to be less substantial than outside experts have estimated them to be. 3) The assumption that the reduction in monitoring frequency and the doubling of time allowed for repairing leaks will not increase the rate of methane emissions in the industry is not supported by evidence.
- Save EPA
- Environmental Defense Fund
- Global Warming of 1.5 ºC, IPCC
- Fourth National Climate Assessment
- National Academies of Science, Engineering, Medicine, Improving Characterization of Anthropogenic Methane Emissions in the United States, 2018.
- United Nations Climate Change, Why Methane Matters, August 2014.
- Environmental Defense Fund, The Business Case for Curbing Methane Emissions