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Comments to EPA on Methane Emissions from Oil and Gas Operations

The Environmental Protection Agency (EPA) proposed revisions to New Source Performance Standards for methane and volatile organic compound (VOC) emissions from the oil and natural gas sector. We submitted comments focusing on EPA’s flawed legal and economic justifications for the rule.

EPA’s proposal would rescind methane limits for the entire oil and gas sector and rescind VOC limits for sources in the transmission and storage segments of the sector (but leave them in place for the production and processing segments). Our comments critique EPA’s claim that it is legally obligated to narrow the scope its existing standards. We also identify serious flaws in the agency’s cost-benefit analysis for the proposed action, which dramatically understates the cost of forgone methane reductions and unreasonably fails to quantify the cost of forgone VOC reductions. We also submitted joint comments criticizing EPA for drastically and inappropriately reducing its estimate of the social cost of methane emissions.