National Wildlife Federation

149 State St reet Montpelier, Vermont 05602 802.552.4325 (Jim Murphy Direct)
jmurphy@nwf.org

SENT VIA ELECTRONIC MAIL TO: oilandgas.whitepapers@epa.gov

June 16 , 2014

The Honorable Gina McCarthy Administrator, U.S. Environmental Protection Agency 1200 Pennsylvania Ave, NW Washington, D.C. 20460

Re: oilandgas.whitepapers@epa.gov

Dear Administrator McCarthy :

We write today on behalf of National Wildlife Federation’s more than four million member s and supporters nation ally to thank you for action you are already taking under the Clean Air Act to protect wildlife, children, and our environment from the dangers of unmitigated carbon pollution

. We also thank you for the opportunity to comment on the series of white papers EPA published examining the serious and solvable problem of methane pollution from oil and gas operations.

As the white pa pers and other information make clear, methane pollut ion has serious climate consequences and can be addressed in a manner that is achievable and cost effective. Reducing methane pollution would have numerous economic and environmental benefits, including capturing a resource that can be used to provide ener gy

. W e strongly encourage EPA to take the critical next

step in addressing climate change by establish ing binding limits on methane pollution from the oil and gas sector. These regulations are critical to ensuring that an increased reliance on natural gas for power generation actually delivers a benefit to our climate.

The National Wildlife Federation (NWF ) , one of the country’s oldest and largest conservation organizations dedicated to the protection of wildlife for future generations, submits the following

comments on th is critical action

. These comments are submitted in concert with nearly 20,000 additional public comments that have been submitted by our members across the country, all urging EPA to move forward with direct regulations requiring l imits on methane pollution from the oil and gas industry. We are also joined in our support for these regulations by several of our affiliateNWF et al. Comments on EPA Methane White Papers

June 16, 2014 Page 2

organizations, all of which have a vested interest in protecting their members in

- state from the impacts of unmiti gated methane pollution: Pennfuture, Environmental Advocates of New York, New Mexico Wildlife Federation, and West Virginia Rivers Coalition.

This effort is a part of the Administration’s Strategy to Reduce Methane Emissions

, announced in March of 2014, a critical piece of the Administration’s overarching Climate Action Plan. Regulations from EPA limiting methane pollution from the oil and gas sector are a critical to reducing carbon pollution in line with our international commitments to reduce national emissions by 17% below 2 005 levels by 2020.

L imiting methane leakage from the natural gas sector is necessary to ensuring that any short term

increase in reliance of natural gas in our power sector actually delivers on climate benefits. EPA’s white papers show that substantial opportunity exists to reduce methane pollution in a cost

- effective

and efficient manner . However, voluntary measures will not ensure that t hese benefits are fully

realized

. Moving forward with enforceable regulations that achieve measureable benefits are key to cutting methane pollution and eliminating unnecessary, wasteful emissions from gas and oil operations

.

NWF has for over three

- quarters of a century been the leading national organization in advocating for policies that benefit wild life for our chi ldren’s future. Oil and gas operations on both private and public land impact some of the most productive wildlife habitat areas in the c ountry.

Methane is a valuable commodity that is all too often needlessly wasted or literally burned into the atmosphere because gas and oil producers fail to take demonstrated and often low

- cost steps to
prevent this pollution . Methane is a powerful greenhouse gas pollutant

– between 20 and almost 90 times more powerful than carbon dioxide depending on the length of time it is in the atmosphere

– and a cause of severe localized pollution such as ozone that harms wildlife, people, and diminishes the enjoyment of the private and public lands it effects

.

It is clear from the white papers and other information that availab le technologies can significantly

reduce methane pollution at a low cost from major sources such as wells, compressors, and pipelines that trans port gas

. It is well documented tha t the oil and gas industry is one of the largest

sources of m ethane pollution, making up about one

- third of the nation’s total methane emissions. Increasingly

, studies are showing that methane pollutions levels are much higher than official inventories report , making the lifecycle carbon impacts of natural gas significantly more carbon intensive than previously believed.

While 2012 volatile organic compound standards adopted by EPA in 2012 will lower these

emissions so mewhat, additional rules targeting remaining methane pollution are needed to ensure these emissions are substantially reduced. Moreover, these rules are needed to ensure that market factors, such as fractured ownership of various phases of gas production that deter otherwise sensible capture efforts , do not act as reasons cheap, easy measures to capture pollution that can be used as a valuable commodity fail to occur. Enforceable federal standards will not deter companies or states that are taking actions now to curb methane pollution, and will instead ensure those efforts

are not ignored by actors who are currently free to ignore these protective measures.NWF et al. Comments on EPA Methane White Papers

June 16, 2014 Page 3

A rulemaking initiative by EPA would also complement a rulemaking effort by the Department of Interior’s Bureau of Land Management (BLM) intended to address methane waste from oil and gas operations on public lands. EPA rulemaking would ensure methane pollution on all lands

– i ncluding significant operations in the largely privately owned eastern states

– is addressed, and go hand

- in

- hand with BLM’s effort to ensure that waste is prevented, a valuable resource is captured

, and pollution is reduced

.

These long overdue actions by EPA and BLM would achieve a true multiple win by : (1) ensuring methane, a valuable fuel source, is not wasted but instead used to provide energy ; (2) reducing ground levels of pollution on public and private land s ; (3) improving pipeline safety by eliminating dangerous and explosive pipeline leaks; and ( 4 ) reducing carbon pollution that fuels climate change

.

A f ail ure to move forward with rules cutting methane pollutions poses several unacceptable threats

to wildl ife . It would miss an important opportunity to encourage the most efficient use of areas that are being subjected to oil and gas development , resulting in wasteful l osses of wildlife habitat . I t
would allow for ground level ozone and other pollution that harms wildlife and people and decreases the enjoyment and use of public lands . It would spur dangerous climate change. W ithout robust efforts to reduce greenhouse gas emissions, runaway climate change will cause massive species extinction, habitat disruption, droughts , floods, wildfires, and other events that will displace and present severe harms to wildlife.

We look forward to working with EPA to achieve a strong rule that is a key piece of an aggressive plan to affordably address dangerous climate change causing carbon pollution. Without ensuring significant reductions in methane pollution, the Administration’s signature efforts to curb carbon pollution will be dire ctly undermined. The technology and legal authority clearly exists to move

forward with cost

- effective methane pollution reduction that will have significant benefits

.

Recent studies like the National Climate Assessment have illustrated how alarming th e climate crisis is becoming and how essential it is that we take swift measures to address it. Reducing methane pollution is a very sensible , cost

- effective and beneficial measure EPA can take now. We

cannot afford to wait.

We again thank you for the effort to comment on these whitepapers , and look forward to working
with EPA to swiftly develop rules that address this significant and solvable threat to wildlife and

our climate

.

Sincerely,

Jim Murphy

Senior Counsel

, National Wildlife Federation

Peter Iwanowicz Executive Director, Environmental Advocates of New YorkNWF et al. Comments on EPA Methane White Papers

June 16, 2014 Page 4

Cindy Adams Dunn CEO and President, PennFuture

Garrett VeneKlassen Executive Director, New Mexico Wildlife Federation

Angie Rosser

Executive Director

, West Virginia Rivers Coalition