Advocates for Cherry Valley * Advocates for Morris * Alaska Wilderness League * Appalachian Mountain Club 

Appalachian Voices * Athens County Fracking Action Network * Catskill Citizens for Safe Energy 

Center for Effective Government * Chesapeake Climate Action Network * Citizens Campaign for the Environment 

Citizens' Environmental Coalition * Citizens for Water * Clark Resource Council * Clean Air Carolina 

Clean Air Task Force * Clean Water Action * Concerned Citizens Ohio * Damascus Citizens for Sustainability 

Earth Day Network * Earthjustice * Earthworks * EcoFlight * EnviroHancement * Environment America 

Environment New York * Environmental Advocates of New York * Environmental and Energy Study Institute 

Environmental Defense Fund * Environmental Justice Committee * Environmental Protection Information Center 

Gas Drilling Awareness for Cortland County * Great Old Broads for Wilderness * Greenwich Citizens Committee 

Heartwood * Klamath Forest Alliance * Landscape Alternatives L.L.C. * League of Conservation Voters 

League of Women Voters * Los Padres ForestWatch * Milford Doers * Mom's Clean Air Force 

National Wildlife Federation * Natural Resources Defense Council * Nature Abounds 

Northern Plains Resource Council * NYH20 * Otsego County Conservation Association 

Otsego 2000 Inc. * Pavillion Area Concerned Citizens * PennFuture * Pipeline Safety Coalition 

Powder River Basin Resource Council * Residents of Crumhorn Mountain * ROAR Against Fracking 

Safe Climate Campaign * Shalefield Stories-Friends of the Harmed * Southern Alliance for Clean Energy 

Sullivan Area Citizens for Responsible Energy Development * SustainUS * The Endocrine Disruption Exchange 

U.S. Climate Plan * Western Environmental Law Center * Western Organization of Resource Councils 

Western Resource Advocates * WildEarth Guardians 

The Honorable Gina McCarthy 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue N.W. 

Washington, DC 20460 

June 16, 2014 

Dear Administrator McCarthy, 

We write to express support for the Environmental Protection Agency’s work to set the stage for 

oil and gas industry methane regulations through the series of white papers issued in April. 

Based on the information contained within those papers, we strongly urge the Agency to move 

forward with such regulations expeditiously. While we anticipate that responses to the white 

papers will provide additional valuable information on strategies to reduce emissions from oil 

and gas, data the Agency has today makes clear that available technologies can cheaply and 

significantly reduce emissions from key sources in this industry, including all of those covered 

by the Agency’s white papers. Given the damage from these emissions and the low-cost 

opportunity to reduce them, regulation is both necessary and warranted. 

Tightly regulating methane from the oil and gas industry is absolutely critical to meeting the 

President’s publicly-stated pledge to reduce greenhouse gas emissions by 17% by 2020. We 

know from a number of studies that methane emissions from the oil and gas sector are substantial 

-- about one-third of total US methane emissions. Methane and other harmful substances, from 

smog precursors to toxics like benzene, are released and allowed to leak from wells, compressors, 
and pipelines, among other sources throughout the sector. Several recent studies1

 have confirmed 

that, overall, methane emissions are considerably higher than official inventories report. EPA’s 

volatile organic compound (VOC) standards adopted in 2012 will mitigate some of this methane, 

specifically from a subset of new and modified sources in the sector. However, due to the 

substantial amount of methane emissions left untouched by those standards, only rules that will 

reduce methane pollution from existing equipment, nationwide, are an adequate response to this 

pollution. 

Additionally, the methane problem is growing due to the domestic oil and gas boom: horizontal 

drilling and high-volume hydraulic fracturing are giving developers access to more gas and oil 

supplies, resulting in more pollution. In fact, a recent study shows that emissions from U.S. oil 

and gas operations are projected to increase 4.5% by 2018, despite EPA’s 2012 oil and gas 

rules.2 This growth is in part due to the 2012 rules’ poor coverage of methane emissions from oil 

development, making clear the need for enhanced standards that will reach these sources of 

methane. 

Methane leaks and venting are all wasteful, and the majority can be prevented at low cost - in 

many cases at a net gain to producers and society over a short return period - since the retained 

or captured gas can be used on-site or sold. As the white papers themselves show, leaks and 

venting contributing significantly to the methane problem are very inexpensive to address. One 

source included in the white papers, a recent report by ICF International, found that industry 

could cut its methane emissions by roughly 40 percent below projected 2018 levels using proven 

technologies at an average annual cost of less than one cent per thousand cubic feet of produced 

natural gas – a fraction of a percent of the revenue the industry receives for the gas. 

Some companies are taking this issue seriously and going above and beyond current regulatory 

requirements to reduce methane emissions on their own, and even supporting state efforts to 

adopt standards for methane. However, a variety of market conditions disincentivize or inhibit 

companies from maximizing the available opportunities to reduce methane. These conditions 

include diverse ownership of the different parts of the system, ownership transfer of the gas 

moving through the system, higher rates of return from other investments, lack of knowledge of 

best practices, lack of incentive by independent contractors, or a simple lack of interest. 

Collectively, these factors result in a market failure with respect to methane, and regulations 

must be established to prevent the resulting wasteful and harmful pollution. Action by EPA 

would complement soon-to-be-proposed Bureau of Land Management methane waste rules 

governing oil and gas operations on federal lands and build on the work of several states. 

																																																								

1 Brandt, A. R., et al., Methane Leaks from North American Natural Gas Systems, 2014, Science, available at 

http://www.novim.org/images/pdf/ScienceMethane.02.14.14.pdf. 

Miller, S. M., et al., Anthropogenic Emissions of Methane in the United States, 2013, PNAS, available at 

http://www.pnas.org/content/early/2013/11/20/1314392110.abstract. 

Pétron, G. et al., A New Look at Methane and Non-Methane Hydrocarbon Emissions from Oil and Natural Gas 

Operations in the Colorado Denver-Julesburg Basin, 2014, J. GEOPHYSICAL RESEARCH: ATMOSPHERES, 

available at http://onlinelibrary.wiley.com/doi/10.1002/2013JD021272/abstract. 2

 ICF International. 2014. Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore 

Oil and Natural Gas Industries. http://www.edf.org/sites/default/files/methane_cost_curve_report.pdf
Curbing methane is a “win-win-win-win” that can save fuel, reduce greenhouse gas emissions, 

improve air quality, and improve pipeline safety, and our organizations stand at the ready to 

support swift action. Doing so is a critical near-term step toward implementation of President 

Obama’s Climate Action Plan and continued U.S. leadership on climate protection and healthier 

air. Some of our organizations separately provide detailed comments regarding each of the 

Agency’s five white papers, and all of us look forward to working with and supporting the 

Agency in crafting new rules to reduce methane pollution from the oil and gas industry. 

Sincerely, 

Advocates for Cherry Valley 

Advocates for Morris 

Alaska Wilderness League 

Appalachian Mountain Club 

Appalachian Voices 

Athens County Fracking Action Network 

Catskill Citizens for Safe Energy 

Center for Effective Government 

Chesapeake Climate Action Network 

Citizens Campaign for the Environment 

Citizens' Environmental Coalition 

Citizens for Water 

Clark Resource Council 

Clean Air Carolina 

Clean Air Task Force 

Clean Water Action 

Concerned Citizens Ohio 

Damascus Citizens for Sustainability 

Earth Day Network 

Earthjustice 

Earthworks 

EcoFlight 

EnviroHancement 

Environment America 

Environment New York 

Environmental Advocates of New York 

Environmental and Energy Study Institute 

Environmental Defense Fund 

Environmental Justice Committee 

Environmental Protection Information 

Center 

Gas Drilling Awareness for Cortland County 

Great Old Broads for Wilderness 

Greenwich Citizens Committee 

Heartwood 

Klamath Forest Alliance 

Landscape Alternatives L.L.C. 

League of Conservation Voters 

League of Women Voters 

Los Padres ForestWatch 

Milford Doers 

Mom's Clean Air Force 

National Wildlife Federation 

Natural Resources Defense Council 

Nature Abounds 

Northern Plains Resource Council 

NYH20 

Otsego County Conservation Association 

Otsego 2000 Inc. 

Pavillion Area Concerned Citizens 

PennFuture 

Pipeline Safety Coalition 

Powder River Basin Resource Council 

Residents of Crumhorn Mountain 

ROAR Against Fracking 

Safe Climate Campaign 

Shalefield Stories-Friends of the Harmed 

Southern Alliance for Clean Energy 

Sullivan Area Citizens for Responsible 

Energy Development 

SustainUS 

The Endocrine Disruption Exchange 

U.S. Climate Plan 

Western Environmental Law Center 

Western Organization of Resource Councils 

Western Resource Advocates 

WildEarth Guardians