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Comments to EPA on Reconsideration of Methane Standards for New Sources

In 2016, EPA finalized a set of performance standards for new, reconstructed, and modified sources of methane and volatile organic compounds (VOCs) in the oil and natural gas sector. A recent proposal, however, aims to weaken the 2016 rule in a variety of ways, with the goal of reducing the regulatory “burden” on industry. We submitted comments that focus on inadequacies in the cost-benefit analysis accompanying the proposed rule.

Among other problems, EPA fails to estimate the extent to which several changes to federal monitoring and repair requirements will increase emissions relative to the 2016 rule. The agency also fails to estimate the emissions impacts of its proposal to allow compliance with certain state programs to substitute for compliance with federal performance standards, even though the requirements of those state programs differ significantly from federal requirements. Finally, the agency understates the climate and health costs associated with forgone methane reductions and fails to assign any value to forgone VOC reductions.

We also submitted joint comments, with a number of other organizations, that discuss the forgone benefits of emissions reductions and EPA’s skewed account of costs and benefits. Analysis of the proposal is arbitrarily limited in its short, seven-year timespan. A typical EPA regulatory analysis often includes reasonable cost-benefit estimates for at least 30 years. Another limitation is its application of the Social Cost of Methane, which is irrationally confined to domestic-only effects. Other missteps in the analysis are EPA’s failure to follow prescribed practices for dealing with uncertainty or to appropriately value unquantified benefits to climate and public health.