Widespread Public Demand and Support for Strong EPA Methane Pollution Rules
The oil and gas industry is the largest source of methane pollution in the United States. Methane pollution has 87 times the global warming power of carbon dioxide during its first 20 years in the atmosphere, and it leaks across every segment of the oil and gas supply chain. When emitted by the gas industry, methane is accompanied by smog-causing volatile organic compounds and air toxics, like the known carcinogen benzene. The extreme heat and precipitation caused by climate change is currently creating public health issues in communities across the country, while increased smog pollution contributes to respiratory issues like asthma, particularly in children, the elderly, and those with preexisting conditions. Air toxics like benzene are known to increase cancer risks in communities on the frontlines of the gas industry.
Clean Air Council has been supporting methane pollution standards for new and modified oil and gas facilities (well sites, compressor stations, and processing plants) since they were adopted by President Barack Obama in 2016. Known as the New Source Performance Standards (or “NSPS”), these standards apply to facilities built after September 2015. The Council strongly opposed the repeal of these standards during the Trump administration. In 2021, the Council urged the U.S. House and Senate to reverse Trump’s repeal, which they successfully accomplished using the Congressional Review Act. During President Biden’s administration, the Council has supported and successfully strengthened newly proposed standards to require inspections for leaks at all oil and gas wells, regardless of their size. These standards would update the NSPS for new and modified oil and gas facilities going forward and would also enact federal methane Emissions Guidelines for all existing oil and gas facilities for the first time ever. Once finalized, each state will then need to adopt its own standards for existing sources that are at least as strong as the Emissions Guidelines.
Since Biden took office, the U.S. Environmental Protection Agency (EPA) has taken a two-step approach to proposing air pollution standards for oil and gas facilities. The EPA proposed an initial version of the rule in November 2021 and held a public comment period, then incorporated feedback and released a “supplemental” version in December 2022 and held another public comment period.
During the most recent period, hundreds of thousands of residents, community groups, public health organizations, medical professionals and climate change experts called on the EPA to strengthen its proposed pollution standards to better protect impacted residents across the country. The Council supported residents, groups and other stakeholders in participating in a robust comment period for the latest rule proposal in the following ways:
- Mobilized supporters to submit 6,620 comments to the EPA demanding an end to the routine flaring of gas, which would reduce air and climate pollution
- Submitted technical comments with partners
- Encouraged 45 health professionals and academic public health experts to sign a letter emphasizing the importance of this proposed pollution standard, particularly for public health in Pennsylvania
- Testified at the EPA’s public hearings on the proposed pollution standard
- Assisted about 15 people in writing their public hearing testimony
- Assisted 17 community organizations in Philadelphia in writing a letter to the EPA explaining how greenhouse gas and volatile organic compound pollution from the gas industry significantly impacts air quality and climate change impacts in Philadelphia.
- Wrote a thorough analysis of the proposed rule that was published by the Pennsylvania Capital-Star in December 2022
- Supported a number of residents, including a Philadelphia block captain and former civic organization president, in submitting letters to the editor emphasizing the need for a strong federal pollution standard
- Supported 277 members in asking their local elected officials to sign on to a letter demanding the EPA strengthen the proposed methane standard, which was signed by 104 state and local elected officials
- Spoke on a webinar focused on the importance of the rule and areas where it can be improved. The webinar was a collaborative effort between Moms Clean Air Force, PennEnvironment Research & Policy Center, Clean Air Council, Environmental Defense Fund, the Evangelical Environmental Network, Environmental Health Project, and Physicians for Social Responsibility Pennsylvania.
- Partnered with local Westmoreland County organization Protect Penn-Trafford to speak on a webinar about technical aspects of gas drilling, the various types of air pollution it creates, and the specific aspects of the proposed EPA rule that will reduce air pollution.
The chorus of organizations, residents, elected officials, health professionals, and other stakeholders from across the country was heard loud and clear by the EPA. The EPA strengthened its proposal in several key ways:
- The EPA had initially proposed to exempt certain wells because of their size and was soliciting comments on whether to extend the zero-emitting equipment standard for pneumatic controllers used to control pressure at compressor stations. In the supplemental version of the rule, the EPA strengthened its proposal to require inspections at all gas wells and extend a zero-emission requirement for all pneumatic equipment used at well sites and compressor stations.
- The EPA is also now proposing the “Super Emitter Response Program” which will allow EPA-certified third-parties to monitor air pollution and require gas companies to fix equipment malfunctions after air pollution events are reported.
- The EPA also proposed to maintain air monitoring requirements for all gas wells until they are successfully plugged, ending the dangerous industry practice of abandoning leaking gas wells.
Increased inspections, zero-emission requirements, and third-party air monitoring in the proposed rules would, if adopted, all be major wins for frontline communities impacted by oil and gas pollution, as well as communities most vulnerable to the increasingly devastating impacts of climate change. While pleased with proposed improvements in the supplemental version of this rule, the Council continues to demand an end to the routine flaring and venting of methane gas unless in an absolute emergency.
The final version of the EPA’s standards for methane pollution from new and existing oil and gas facilities will be published later in 2023, beginning a timeline toward state compliance and enforcement for existing sources (no later than four-and-a-half years after publication). With your help, the Council will be advocating for improved air quality every step of the way.
Contact rzerbo@cleanair.org with any questions.
