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Comments on Oil and Gas Methane Emission Standards

The EPA has proposed New Source Performance Standards for methane and volatile organic compound (VOC) emissions from the oil and natural gas sector under Section 111 of the Clean Air Act. The EPA is proposing standards for several emission sources not currently covered by existing regulations for this category: hydraulically fractured oil well completions, and fugitive methane emissions from well sites, compressor stations, and pneumatic pumps. In addition, the EPA is proposing methane standards for certain sources that are currently regulated for VOCs only, such as hydraulically fractured gas well completions and equipment leaks at natural gas processing plants.

The proposed rule is necessary to reduce emissions from this sector, which is the largest contributor to U.S. anthropogenic methane emissions. Working with students in our Regulatory Policy Clinic, we recently submitted public comments to the EPA on this proposed rule.

While the EPA should not delay promulgating these new standards, we believe that the agency could strengthen the proposed rule by:

  • Identifying and evaluating a full range of alternatives, in order to maximize net social benefits;
  • Conducting a break-even analysis to determine whether the many unquantified benefits of the rule would support selection of more stringent alternatives;
  • Calibrating Optical Gas Imaging frequency according to benefit-cost analysis;
  • Regulating new and existing sources at the same time, to reduce emissions from existing sources and avoid grandfathering concerns; and
  • Considering greenhouse gas emissions trading in this or future rules.