Institute for Policy Integrity logo

Recent Projects

Comments on EPA’s Supplemental Proposal on Oil and Gas Sector Methane Standards

In November 2021, EPA proposed standards to regulate methane emissions from new and existing sources in the oil and natural gas sector. In December 2022, EPA issued a Supplemental Proposal to update, strengthen, and expand the standards. We submitted comments on EPA’s Supplemental Proposal and underlying Regulatory Impact Analysis (RIA). Our comments recommended that EPA strengthen its RIA to more fully capture the impacts of these standards by (1) extending the timeframe of its analysis to quantify net benefits past 2035, (2) monetizing ozone health benefits related to methane emissions reductions, (3) better monetizing and quantifying co-benefits, and (4) better quantifying the impacts of the super-emitter response program or using a breakeven analysis if further quantification is not possible.  

Our comments further recommended that EPA expand its distributional analysis of the impacts of the rule, require states to adhere to best practices for distributional analysis when they seek a variance to impose less stringent standards for specific facilities, use quantitative analysis and a multi-year comparison for its methane charge program equivalency determination, and reconsider whether to accelerate the timeline for compliance with state plans for select performance standards.  

We also submitted joint comments with nine other environmental groups on EPA's use of the Interagency Working Group’s social cost of greenhouse gases (SC-GHG) estimates in the Supplemental Proposal, offering further support for EPA’s use of discount rates and global valuations and affirming that these estimates are reflect a lower bound.