BALTIMORE, MD (February 14, 2023) – Attorney General Brown has submitted comments, as part of a multistate coalition, supporting the Environmental Protection Agency’s (EPA) supplemental proposal to strengthen regulation of emissions from new, modified, and reconstructed facilities in the oil and natural gas sector, and to, for the first time, regulate methane emissions from existing facilities, which comprise the majority of the emissions in this sector.
The EPA estimates that the proposed supplemental proposal will reduce emissions of methane by 36 million tons, volatile organic compounds (VOCs) by 9.7 million tons, and hazardous air pollutants by 390,000 tons between 2023 and 2035. In the comments, the coalition supports EPA’s supplemental proposal, which updates, strengthens, and expands standards proposed in November 2021, and the coalition identifies additional ways to further strengthen the supplemental proposal.
“The EPA’s current proposal to strengthen emissions regulations contains provisions that are more robust than previous standards, taking critical steps toward curbing climate change,” said Attorney General Brown. “In addition, the proposal advances environmental justice for the overburdened communities – which often suffer harms disproportionate to other communities –in which these methane-emitting oil and gas facilities exists.”
Methane is a super pollutant up to 83 times more potent as a greenhouse gas than carbon dioxide in its ability to trap heat in the atmosphere. The production, processing, transmission, and storage of oil and natural gas are the largest single industrial source of methane emissions in the U.S. For nearly a decade, states have urged the EPA to regulate methane emissions from the oil and natural gas sector as a central component in the fight against climate change.
In the comments, the coalition expresses strong support for EPA's supplemental proposal, which addresses several issues that were raised by the coalition’s comments on EPA’s 2021 proposal, and argues that certain elements of the supplemental proposal should be strengthened, including by:
· Requiring a shorter repair period for methane leaks if the well site is located in proximity to an already overburdened community;
· Adding restrictions on the amount of time that operators are allowed to idle wells and limiting the number of idle wells that an individual owner can hold;
· Prohibiting routine flaring with an exception only for safety and emergencies;
· Lowering the threshold for defining super-emitter emission events; and
· Designing the super-emitter response program to maximize community participation.
In filing the comments, Attorney General Brown joins the Attorneys General of California, Colorado, Connecticut, Delaware, the District of Columbia, Illinois, Maine, Massachusetts, Michigan, Minnesota, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, Washington, and Wisconsin, as well as the City of Chicago.
The EPA estimates that the proposed supplemental proposal will reduce emissions of methane by 36 million tons, volatile organic compounds (VOCs) by 9.7 million tons, and hazardous air pollutants by 390,000 tons between 2023 and 2035. In the comments, the coalition supports EPA’s supplemental proposal, which updates, strengthens, and expands standards proposed in November 2021, and the coalition identifies additional ways to further strengthen the supplemental proposal.
“The EPA’s current proposal to strengthen emissions regulations contains provisions that are more robust than previous standards, taking critical steps toward curbing climate change,” said Attorney General Brown. “In addition, the proposal advances environmental justice for the overburdened communities – which often suffer harms disproportionate to other communities –in which these methane-emitting oil and gas facilities exists.”
Methane is a super pollutant up to 83 times more potent as a greenhouse gas than carbon dioxide in its ability to trap heat in the atmosphere. The production, processing, transmission, and storage of oil and natural gas are the largest single industrial source of methane emissions in the U.S. For nearly a decade, states have urged the EPA to regulate methane emissions from the oil and natural gas sector as a central component in the fight against climate change.
In the comments, the coalition expresses strong support for EPA's supplemental proposal, which addresses several issues that were raised by the coalition’s comments on EPA’s 2021 proposal, and argues that certain elements of the supplemental proposal should be strengthened, including by:
· Requiring a shorter repair period for methane leaks if the well site is located in proximity to an already overburdened community;
· Adding restrictions on the amount of time that operators are allowed to idle wells and limiting the number of idle wells that an individual owner can hold;
· Prohibiting routine flaring with an exception only for safety and emergencies;
· Lowering the threshold for defining super-emitter emission events; and
· Designing the super-emitter response program to maximize community participation.
In filing the comments, Attorney General Brown joins the Attorneys General of California, Colorado, Connecticut, Delaware, the District of Columbia, Illinois, Maine, Massachusetts, Michigan, Minnesota, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, Washington, and Wisconsin, as well as the City of Chicago.