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Comments on BLM Rule to Control Fugitive Methane Emissions

We recently submitted comments to the Bureau of Land Management (BLM) regarding a proposed rule to reduce waste of natural gas from venting, flaring, and leaks during oil and gas production on federal and Indian lands. BLM has proposed making natural gas lost through these processes subject to royalty payments. In a set of joint comments with EDF and NRDC, we discuss the Social Cost of Methane and BLM’s authority to consider environmental benefits in its economic analyses. Our separate comments on the substance of the proposed standards suggest, among other things, places where the rule’s cost-benefit analysis should be clarified.