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Comments on EPA’s Failure to Monetize Forgone Emission Reductions in CTG Withdrawal

EPA is soliciting comments on the proposed withdrawal of its control techniques guidelines (CTG) for the oil and natural gas industry. EPA supports its proposed withdrawal of the CTG with an analytical memorandum on avoided costs and forgone emission reductions. The agency monetizes the alleged avoided costs down to the dollar, but EPA fails to monetize the forgone emission reductions. Our joint comments illustrate how the proposed withdrawal’s costs outweigh its benefits, by applying the Social Cost of Methane to EPA’s quantified foregone emissions reductions. We argue that by only quantifying the volume of forgone methane reductions, instead of monetizing the associated damages to the environment, public health, and welfare, EPA obscures the very real and readily monetizable negative consequences of its proposed withdrawal.