We recently submitted comments to the Bureau of Land Management (BLM) regarding a proposed rule to reduce waste of natural gas from venting, flaring, and leaks during oil and gas production on federal and Indian lands. BLM has proposed making natural gas lost through these processes subject to royalty payments. In a set of joint comments with EDF and NRDC, we discuss the Social Cost of Methane and BLM’s authority to consider environmental benefits in its economic analyses. Our separate comments on the substance of the proposed standards suggest, among other things, places where the rule’s cost-benefit analysis should be clarified.
Related Reading
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Comments to EPA on GHG Regulations for Fossil Fuel-Fired Power Plants
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Comments to OMB on Draft Update of Circular A-4
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Statement on New Greenhouse Gas Emissions Standards for Power Plants
Media Resources / May 11, 2023
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New Guidance Improves Consideration of Health, Equity, and Environmental Benefits in Regulations
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Revesz Nominated to Lead OMB’s Office of Information and Regulatory Affairs
Media Resources / September 2, 2022