Deadline for Public Comments on this Rollback Notice
December 17, 2018
Read the Proposal:@ https://www.gpo.gov/fdsys/pkg/FR-2018-10-15/pdf/2018-20961.pdf
Comment on the notice @
Public Hearing: TBA
What’s at Risk, How to Comment and Talking Points
The Existing Standards and the Trump Administration Proposed Rollback
EPA proposed to weaken standards issued in 2016 that were designed to significantly reduce climate changing methane and other air pollution from the oil and gas industry. Although some of the proposed changes clarify provisions of the 2016 rule, key provisions reduce the frequency of monitoring emissions and provide more time before leaks must be repaired. These provisions will harm public health and the environment by increasing emissions of methane, smog-forming volatile organic compounds (VOCs) and toxic air pollutants.
The standards apply to new, reconstructed and modified processes and equipment used in oil and gas extraction and production. The proposed changes would save the oil and gas industry up to $85 million annually or up to $484 million over the 2019-2025 time period. EPA estimates that the public would forgo up to $54 million in benefits over that time. But this figure is greatly underestimated. EPA did not count damage to public health and the environment from the effects of climate change beyond US borders, where most of the world’s population lives; from increased ozone smog formation due to increased methane and VOC emissions; or from increased air toxics emissions. In other words, EPA did not count most of the forgone benefits.
How to Submit Your Comment to EPA
EPA will accept public comments up until midnight Eastern Standard Time on December 17, 2018. To find Docket information and to submit comments use this link: https://www.regulations.gov/comment?D=EPA_FRDOC_0001-23033
If you wish to submit comments by mail, fax, or other means, see the directions in the Federal Register notice for this proposal at: https://www.gpo.gov/fdsys/pkg/FR-2018-10-15/pdf/2018-20961.pdf. Comments on this proposal must be identified by the following Docket ID: EPA-HQ-OAR-2017-0483. To see the full EPA public comment policy go to: https://www.epa.gov/dockets/commenting-epa-dockets. This web page also provides information about CBI or multimedia submissions, and general guidance on making effective comments.
What to Say
First, explain why you’re commenting on this proposed withdrawal – why it matters to you. If you have relevant expertise, say so. You don’t have to be an expert to make a valid and valuable comment, but if you do have expertise, share your knowledge. If you have information relevant to the rule (for example, news articles about events in your community or anecdotal information showing how the public is impacted) include that information and highlight it. Be constructive and civil. Don’t write a lot if less will do.
Suggested Talking Points
The oil and gas industry is the largest source of methane emissions.[i] Methane, the primary component of naturall gas, is a powerful greenhouse gas. Methane along with VOCs and air toxics can leak from the equipment and activities all along the oil and gas production chain.
Greenhouse gas pollution (GHG) is the primary cause of recent climate change, threatening the lives, health, and well-being of my family, other Americans, and people around the globe. Climate change fueled by GHGs has wide-ranging, life-changing impacts. These impacts are already being felt in the U.S. and worldwide and will get worse over time. Impacts that we are all seeing include:
More frequent and intense heat waves and record high temperatures that lead to more heat-related illnesses and deaths, especially among the poor and elderly;
More frequent and intense droughts, wild fires, damaging storms, and floods that cause deaths and injuries as well as property and infrastructure damage;
Northward migration of tropical diseases; increased health problems from smog pollution; and increased production of allergens and the respiratory problems they cause;
Changes to the oceans that kill coral, fish, and mammals; changes in the ranges of plants and animals, or their outright extinction;
Damage to crops and fisheries; and potential increases in world hunger and other destabilizing changes;
Climate change affects disproportionately threaten the health and welfare of vulnerable people in the U.S. and around the world, including children, the elderly, the poor, and native peoples. Climate scientists warn that climate change already has exacerbated extreme weather and can be expected to have even greater effects in the future.5
Climate change threatens to impose terrible costs. The National Oceanic and Atmospheric Administration reports that between 1980 and October 6, 2017, extreme weather disasters cost $1.3 trillion in inflation-adjusted damage and resulted in 9,905 deaths, and that's not counting Hurricanes Harvey, Irma, and Maria.5
Climate change is also a driver of the increasing number and severity of wildfires in the U.S.7 More than two million acres had burned in 111 large fires in 12 states by mid-August 2018.8 An early estimate of the property damage caused by Hurricane Florence was between $17 billion and $22 billion.[ii]As of this writing 36 people have died as a result of Florence.[iii] Possible rapid changes in climate that could cause even more abrupt and severe impacts for people and ecosystems. [For more information including scientific sources, click here]
This proposed rule reduces the requirements for the oil and gas industry to monitor oil and gas operations for methane leaks, eliminates all monitoring at wellhead-only sites (producing oil or gas fields after all drilling has ceased), and increases the time that operators have to repair leaks once they are discovered. All of these provisions will increase methane emissions.
Delay in controlling methane would be a dangerous mistake. While CO2is the dominant cause of climate change, methane is an extremely potent greenhouse gas because it absorbs more energy per unit mass than does CO2. As EPA’s web site notes, methane has a global warming potential about 86 times that of carbon dioxide over 20 years. Smart policy would reduce emissions of methane as well as carbon dioxide (CO2). Methane stays in the atmosphere only 12 years, according to EPA. CO2 can stay in the atmosphere for hundreds of years. If we want to make progress in the near future toward reducing atmospheric concentrations of GHGs, we must reduce methane emissions.
There are other reasons to control methane as well. Methane emissions contribute to the loss of stratospheric ozone that protects us from harmful radiation from the sun. In the troposphere (the lower portion of the atmosphere, where we live and breathe), methane emissions lead to higher ozone smog concentrations, which is linked to a wide range of respiratory health effects, including aggravation of asthma, increased emergency room visits and hospital admissions,and deaths. EPA says the oil and gas sector is the largest industrial source of emissions of volatile organic compounds (VOCs), a group of chemicals that react in the atmosphere to form ground-level ozone (smog). VOC emissions from the oil and gas industry include hazardous air pollutants such as benzene, ethylbenzene, and n-hexane. These pollutants, also known as toxic air pollutants, are pollutants known or suspected to cause cancer or other serious health problems such as reproductive effects or nervous system problems.
There is another reason that reducing methane emissions makes smart policy sense. Unlike most other greenhouse gases, there is readily available technology to control methane emissions from oil and gas development. Because methane is the main ingredient in natural gas – a valuable product, many companies are now controlling their emissions and finding it cost effective. In a recent study that surveyed companies that were complying with a Colorado state regulation, more than 7 in 10 said that they were paying very little for leak detection and repair and 1 in ten reported coming out ahead because frequent monitoring and rapid repair allowed them to capture more of the leaking methane which has economic value.[iv] Recently a number of multinational companies, including ExxonMobil and BP, signed on to a voluntary agreement with the Environmental Defense Fund to reduce their methane emissions. [v] In September of this year, The Oil and gas Climate Initiative, a group of the largest oil companies from around the world, agreed to reduce methane emissions from natural gas extraction by more than 20% by 2025.[vi]
In the US, there is a growing industry in methane leak detection and mitigation with more than 60 firms with locations in 45 states employing over 6000 employees who manufacture and sell technology to detect and reduce methane emissions from oil and gas facilities.[vii] EPA did not calculate the employment impacts of the proposed rollback but concedes that some jobs would be lost.
EPA in its economic analysis admits that the rollback will cost up to $54 million dollars over seven years. But the real cost is much higher. EPA simply did not count the cost of climate change benefits forgone outside of the United States, where most of the world’s population lives; from increased ozone smog formation due to increased methane and VOC emissions; and the serious effects of increased emissions of air toxics.
There Is More That You Can Do
It would be great if well-reasoned, fact-based comments were enough to win the day, but in today's deregulatory environment, raising the political stakes of regulatory rollbacks is crucial to stopping or slowing them down. Submitting comments is a good first step. For rules that are particularly important to you, please consider taking one or more of the following steps, too. These methods can help to mobilize public opinion and spur elected leaders to fight the destructive changes that the Trump Administration is promoting.
The upcoming November elections give us a potent opportunity to let our elected leaders know that public protections are important to us and how we vote. Write to your members of Congress and other elected officials. Let them know your concerns and ask them to weigh in on this rollback and speak out publicly in favor EPA’s existing statements on this issue. These links make it easy to write your members of Congress (your representative in the House of Representatives and your two senators). If you're willing to register with Countable, this link -- https://www.countable.us/ -- allows you to identify your members of Congress and send a message to all three at once. Or, you can write them separately -- you can use https://whoismyrepresentative.com/ or https://www.usa.gov/elected-officials/ to find your members' email contact forms or snail mail addresses.
Let your state officials know that you are concerned about this issue. In the absence of federal leadership, it is vitally important that states and local governments fill the void. Write to your elected leaders, get involved with local activists who are encouraging local or state action. Voice your concern and encouragement in the media, social media, at local meetings, and at every opportunity.
Write letters to the editor and even op-eds in your local papers. Letters to the editor should be fairly brief. Get involved with local activists.
Organize or participate in campaigns to make phone calls or write letters to members of Congress and make phone calls to radio stations during call-in days or take other actions to spread the word.
Inform your local officials about these issues and ask them to make a public statement or submit comments on a proposed rollback if your jurisdiction has a stake in these issues.
Bring up these issues at town hall meetings.
Spread the word via social media. Tag your elected officials so they know how you feel.
Join or organize demonstrations.
Talk to your friends, colleagues and neighbors and encourage them to comment and otherwise join in this effort.
Links for More Information
National Academies of Science, Engineering, Medicine, Improving Characterization of Anthropogenic Methane Emissions in the United States, 2018. https://www.nap.edu/catalog/24987/improving-characterization-of-anthropogenic-methane-emissions-in-the-united-states
United Nations Climate Change, Why Methane Matters, August 2014. https://unfccc.int/news/new-methane-signs-underline-urgency-to-reverse-emissions
Environmental Defense Fund, The Business Case for Curbing Methane Emissions http://business.edf.org/projects/featured/natural-gas/the-business-case-for-methane-mitigation
ENDNOTES [i]EPA, Inventory of US Greenhouse Gas Emissions and Sinks, 1990-2016, https://www.epa.gov/ghgemissions/overview-greenhouse-gases#methane
[ii]CNBC,“Hurricane Florence damage estimated at $17 billion to $22 billion and could go higher — Moody's Analytics” September 17, 2018. https://www.cnbc.com/2018/09/17/moodys-hurricane-florence-damage-estimated-at-17-to-22-billion.html
[iii]Aljazeera, “Florence: Death toll climbs to 36 as women in sheriff's van drown” September 19, 2018. https://www.aljazeera.com/news/2018/09/florence-death-toll-climbs-36-women-sheriff-van-drown-180919193732199.html
[iv]Keating Research Inc., The Colorado Case Study on Methane Emissions: Conversations with The Oil and Gas Industry, April 2016. http://keatingresearch.com/wp-content/uploads/2016/04/Colorado-Methane-Regulation-7-Survey-Research-Memo-4-10-2016-Final-Version.pdf
[v]EDF, “Exxon joins counterparts in new call for increased methane action including regulations”, December 2017. http://blogs.edf.org/energyexchange/2017/12/01/exxon-joins-counterparts-in-new-call-for-increased-global-methane-action-including-regulations/
[vi]Houston Chronical, “Biggest energy companies pledge 20 percent methane emissions reduction”, September 24, 2018. https://www.houstonchronicle.com/business/energy/article/Biggest-energy-companies-pledge-20-percent-13252920.php
[vii]Datu Research Find and Fix: Job Creation in the Emerging Methane Leak Detection and Mitigation, March 2017. https://www.edf.org/sites/default/files/find-and-fix-datu-research.pdf