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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 th e 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 regul ations expeditiously. While we anticipate that responses to the white papers will provide additional valuable informa tion 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, regulati on is both necessary and warranted.

Tightly regulating methane from the oil and gas i ndustry is absolutely critical to meeting the President’s publicly-stated pl edge to reduce greenhouse gas emissions by 17% by 2020. We know from a number of studies th at methane emissions from the oi l and gas sector are substantial -- about one-third of total US methane emissions. Methane and ot her harmful substances, from smog precursors to toxics like benzene, are releas ed and allowed to leak from wells, compressors,and pipelines, among other sources thr oughout the sector. Several recent studies 1 have confirmed that, overall, methane emissions are considerably higher than official i nventories 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 meth ane emissions left untouched by those standards, only rules that will reduce methane pollution from existing equipment, na tionwide, 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 increas e 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 re port by ICF International, found that industry could cut its methane emissions by roughly 40 percent below proj ected 2018 levels using proven technologies at an average annual cost of less th an one cent per thousand cubic feet of produced natural gas – a fraction of a percent of the revenue the industry r eceives for the gas.

Some companies are taking this issue seriously a nd going above and bey ond current regulatory requirements to reduce methane emissions on th eir 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 opportun ities 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 ra tes 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 fa ilure 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/S cienceMethane.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/ear ly/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 Meth ane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas Industries. http://www.edf.org/sites/default/file s/methane_cost_curve_report.pdfCurbing 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 provi de 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 meth ane 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