National Wildlife Federation

149 State Street

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 members and 

supporters nationally 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 papers and other information make clear, methane pollution 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 energy. We strongly encourage EPA to take the critical next 

step in addressing climate change by establishing 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 this 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 limits on methane pollution from the oil and 

gas industry. We are also joined in our support for these regulations by several of our affiliate 

 

 

 
NWF 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 unmitigated 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 2005 levels by 2020. 

Limiting 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 these 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 wildlife for our children’s future. Oil and gas operations on both private 

and public land impact some of the most productive wildlife habitat areas in the country.

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 available technologies can significantly 

reduce methane pollution at a low cost from major sources such as wells, compressors, and 

pipelines that transport gas. It is well documented that the oil and gas industry is one of the largest 

sources of methane 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 somewhat, 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 –

including 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 lands; (3) improving pipeline safety by eliminating 

dangerous and explosive pipeline leaks; and (4) reducing carbon pollution that fuels climate change. 

A failure to move forward with rules cutting methane pollutions poses several unacceptable threats 

to wildlife. 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 losses of wildlife habitat. It 

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. Without 

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 directly 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 the 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 York
NWF 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