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Comments on EPA Methane Rule Stay

The Environmental Protection Agency (EPA) recently paused certain requirements to reduce methane leaks and emissions from new oil and gas facilities. In its “notice of data availability” for the proposed stay, EPA claims that the compliance costs of reducing these emissions exceed the benefits to the public and to industry.

Our comments argue that EPA manipulated economics to make this claim. EPA undervalued the social cost of methane emissions and claimed that the forgone benefits of the rule are only $5.4 to 23 million per year, when EPA’s original estimates said the rule would create public benefits of $140-180 million per year.

Our comments explain why EPA’s initial estimates were based on the best available science and economic analysis. In its stay, EPA used an artificially low number for the social cost of greenhouse gases, which conflicts with guidance by the National Academy of Sciences and breaks from best practices for economic analysis. As such, we argue that the stay is arbitrary and capricious.