How to comment:
- Review the comments prepared by Indivisible Montgomery (below)
- Go to https://www.regulations.gov/docket?D=BLM-2017-0002
- Click the “Comment Now” button near the top right of the page
- Enter your comments in the text box; feel free to copy ours or write your own
- Click “Continue”
Comments on this rule change are CLOSED
Comment Text (for copy/paste into comment field)
I appreciate the opportunity to comment on the proposed delay of the waste prevention rule (BLM-2017-0002, RIN 1004-AE54).
Domestic natural gas production has increased dramatically in the United States in the past decade, rising from 19 million cft in 2006 to more than 28 million cft in 2016 (1). The Mineral Leasing Act requires the Bureau of Land Management (BLM) to use all reasonable precautions to prevent “waste of oil or gas developed in the land” (2). In November 2016, the BLM issued a rule aimed at reducing natural gas waste on public lands due to leaks, flaring, and venting, which replaced a prior, less effective regulation. This new regulation was promulgated to limit pollution, decrease waste of natural gas resources, and prevent loss of revenue payments to federal, state, and tribal governments. This rule sets flaring limits and requires natural gas producers to regularly inspect their equipment for leaks using the most up-to-date technology. Despite some operators taking such steps voluntarily, wasteful natural gas emissions from wells are increasing. Between 2009 and 2015, oil and gas producers on federal land vented, flared, or leaked 462 billion cft of natural gas, enough to power 6.2 million households for a year.
Under the Trump administration, BLM is proposing to delay implementation for 18 months while it considers how to modify or rescind the rule. I believe that this delay is both unnecessary, due to the strong reasons for preventing wasteful natural gas emissions, and unwise, because it contributes to more regulatory uncertainty in natural gas production.
Natural gas emissions are a clear threat both to the environment and human health. Methane, the principal component of natural gas, is 30 times more potent than carbon dioxide as a greenhouse gas, and contributes to climate change. This year, our country experienced record-breaking hurricanes and fires, both of which will be exacerbated by climate change. As a Maryland resident, I am particularly concerned about the effects of climate change on the Chesapeake Bay and its associated communities, which are major drivers of the Maryland economy. The waste prevention rule will prevent up to 180,000 tons of methane emissions per year over the next 10 years, and prevent the release of up to 270,000 tons of dangerous volatile organic compounds (VOCs), which have been shown to directly harm human health.
A poll of seven states in the interior west found 80 percent approval for using technology to prevent and minimize leaks(3), and 40 state officials in New Mexico have written BLM expressing the need for effective regulation of methane emissions in the oil and gas industry (4). I believe that the views of people living with extractive industries deserve to be heard and respected as part of the public-private partnership involved in resource extraction on public lands.
Lastly, I believe that this rule makes good financial sense. The Government Accountability Office estimates that federal and states governments lose up to $23 million in annual royalty payments alone due to leakage, and this does not account for the costs of continued environmental degradation. The natural gas industry already has reliable and affordable technology to capture and sell natural gas instead of flaring or venting it. In 2016, a BLM analysis suggested that the cost savings of natural gas recovery and the prevention of climate harms would range from $209 to $403 million, exceeding the estimated implementation cost of $114 to $275 million (5). Additionally, this rule will create jobs in the nascent methane mitigation industry and allow the US to become a world leader in what will be a critical sector as the world increases its use of natural gas.
This is a rare occasion where the incentives for industry and the government are remarkably aligned. There is simply no scientifically or economically sound argument for delaying implementation of this rule, and I strongly support maintaining the waste prevention rule under its current implementation timetable.
Thank you for your consideration,
References
(1) https://www.eia.gov/dnav/ng/hist/n9050us2a.htm
(2) 30 U.S.C. § 225
(3) Colorado College, https://www.coloradocollege.edu/dotAsset/18dc097b-dce9-4003-8630-12796a054c8f.pdf
(5) RIA p 4-6, https://www.regulations.gov/document?D=BLM-2016-0001-9127
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