Dear Administrator Wheeler:
We write to add our voices to the widespread opposition to the Environmental Protection Agency's (EPA) proposal to reverse progress in limiting methane pollution. The EPA's proposed changes to the 2012 and 2016 New Source Performance Standards (NSPS) for the Oil and Natural Gas Sector will, according to the EPA's own analysis, increase air pollution from the transmission and storage of oil and gas, causing preventable damage to public health and our environment.
As you know, methane is one of the most potent greenhouse gases driving climate change--84 times more powerful than carbon dioxide in the first two decades after its release. Nearly 30 percent of harmful methane emissions in the United States come from the oil and gas sector, a key reason for EPA's previous actions to require oil and gas companies to curb this super-pollutant from the beginning of production.
The standards now targeted by EPA are both inexpensive and simple for industry to meet. These low-cost requirements are already seen as successful in top oil and gas producing states, such as Colorado and Wyoming, where companies have reduced methane emissions while increasing their overall profits. Leading oil and gas companies have invested millions in technologies and practices to reduce their methane emissions from facilities and equipment, and these companies are speaking out on the need for EPA methane regulation.
The proposed amendments to the NSPS would reverse the United States' progress on this issue--taking us from forward-looking to woefully negligent. Ignoring both the public interest and benefits to industry, EPA is attempting to weaken these standards, which could allow emissions of over 340,000 metric tons of methane, over 9,000 tons of volatile organic compounds, and 270 metric tons of hazardous air pollutants in the first five years alone.
The agency's claim that its proposed changes are cost-saving measures is contradicted by companies such as Shell, BP, ExxonMobil, and Equinor. Each of these companies has spoken in support of continued EPA regulation of methane, putting the EPA at odds with the industry it is claiming to help.
EPA is failing to live up to its charge of protecting the environment. Instead, it is proposing to weaken a commonsense pollution standard that, combined with exempting transmission and storage facilities and weakening current standards as EPA has proposed, will result in 5 million metric tons of methane emissions each year--enough gas to heat 4 million homes.
The United States must continue to lead in reducing emissions of harmful super pollutants such as methane. Tackling methane's contribution to climate change is an easy and concrete action we can take right now. It is also an opportunity to curb increasing rates of respiratory illnesses, other negative health effects, and premature deaths.
Thank you for your consideration. We urge you to withdraw your proposal and keep these critical public health and climate change protections in place.