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Comments to EPA on Federal Emissions Management from Oil and Gas Sources in Utah

The Environmental Protection Agency’s (EPA) Federal Implementation Plan (FIP) for managing emissions on the Uintah and Ouray Indian Reservation in Utah proposes control requirements for new, modified, and existing oil and natural gas sources. Despite forecasting that the requirements would lead to a substantial decrease in methane emissions, EPA severely underestimates resulting benefits through the use of an “interim” social cost of methane metric that disregards the best peer-reviewed science. We submitted joint comments detailing EPA’s failure to adequately monetize and evaluate the benefits of the FIP.