Letter to the Honorable Gina McCarthy, Administrator of the Environmental Protection Agency - On Reducing Natural Gas Loss

Letter

Dear Administrator McCarthy:

We write with regard to the Environmental Protection Agency's (EPA) recently proposed standards to control methane pollution from new and modified oil and gas operations. We are pleased that EPA is moving forward and urge the agency to finalize the new and modified rule. In addition, we also recommend that EPA next consider an existing source rule for methane emissions.

Tackling methane is an integral part of avoiding the most serious human health and environmental consequences associated with climate change. Methane is a potent greenhouse gas, more than 80 times as potent as carbon dioxide within the first 20 years after it is emitted. The oil and gas industry alone accounts for more than 7 million tons of methane emissions annually.

Curbing methane emissions will provide significant co-benefits by reducing emissions of volatile organic compounds (VOC) that contribute to soot and smog -a serious air pollution problem that contributes to premature deaths and increased rates of asthma attacks - as well as toxic pollutants like benzene. By damaging the respiratory system, we know that smog harms some of our most vulnerable populations.

In addition, wasted methane gas equals an enormous amount of wasted revenue for both state and tribal governments. A recent report from the business consulting firm ICF International found that venting, flaring and leaks from oil and gas sites on federal and tribal land in New Mexico wasted $101 million worth of gas in 2013. New Mexico ranked highest in the nation for natural gas waste on public lands at 33.7 billion cubic feet. Not only is this bad for the environment, but it represents lost royalties to taxpayers totaling more than $42.7 million in forgone royalty revenue since 2009.

Oil and gas production is a major sector of New Mexico's economy, but we believe this development benefits our state and the nation most when it is done in an environmentally responsible way. Fortunately, the technology and know-how to minimize emissions from oil and gas facilities is readily available and affordable. EPA's final rule should take advantage of the ingenuity and availability of new technology and promote its use throughout the oil and gas system.

We strongly support many features of the proposed standard. The proposal would require for the first time the capture of methane and VOC emissions from hydraulically fractured oil wells, a major source of pollution. The proposed rule also contains common-sense standards for important sources of methane emissions from oil and gas facilities and equipment.

However, we believe there may be room for improvement as we understand that several critical sources of methane emissions were omitted from EPA's proposal. We would strongly encourage EPA to review additional sources and rigorous leak detection and repair standards to ensure the rule successfully incorporates best practices. By finalizing a strong new and modified rule, EPA will be well prepared to pursue a successful existing source rule as well.

We thank you for your attention to this important issue and look forward to working with you to achieve the strongest feasible standards to minimize methane emissions from new and existing sources in the nation's oil and gas sector.

Sincerely,

Tom Udall, United States Senator
Martin Heinrich, United States Senator
Ben Ray Luján, United States Representative
Michelle Lujan Grisham, United States Representative