Methane leaks in Oil and Gas wells exacerbate climate change problems by rele4asing methane into the environment. Methane is a potent climate change pollutant causing perhaps 84 to 87 times more damage than carbon dioxide over the next 20 years.

Unfortunately, but not surprisingly, the Trump Administration has proposed to allow oil and gas producers increase methane pollution

This evening, the editors of InternationalMosaic.com, their opening round of objections to the “gassy” proposal. The editors said:

Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Reconsideration

ID: EPA-HQ-OAR-2017-0483-0005

We are writing, both as editors of InternationalMosaic.com and individually, to provide comments on and objections to the proposal to allow increased pollution (emissions) in the oil and natural gas sector.

As acknowledged by a flock of federal agencies, including the EPA, the climate change problem is urgent. The report released on November 23, 2018 (“Black Friday”) states in part:

“Climate change is projected to significantly affect human health, the economy, and the environment in the United States, particularly in futures with high greenhouse gas emissions and limited or no adaptation. Recent findings reinforce the fact that without substantial and sustained reductions in greenhouse gas emis­sions and regional adaptation efforts, there will be substantial and far-reaching changes over the course of the 21st century with negative consequences for a large majority of sectors, particularly towards the end of the century.

“The impacts and costs of climate change are already being felt in the United States, and changes in the likelihood or severity of some recent extreme weather events can now be attributed with increasingly higher confidence to human-caused warming (see CSSR, Ch. 3). Impacts associated with human health, such as premature deaths due to extreme tempera­tures and poor air quality, are some of the most substantial (Ch. 13: Air Quality, KM 1; Ch. 14: Human Health, KM 1 and 4; Ch 29: Mitigation, KM 2).“

Fourth National Climate Assessment, pages 58-59. For the full report please see: https://nca2018.globalchange.gov/downloads/.

In addition, because the proposed increased pollution most notably will include the release of methane, the short-term impact will even be greater. Using a twenty-year time frame, methane has a 84 to 87 times greater impact than a similar carbon dioxide release. See:https://unfccc.int/news/new-methane-signs-underline-urgency-to-reverse-emissions A twenty year time window is very conservative given the accelerating pace of climate change related disasters.

By itself, the Black Friday study constitutes legally sufficient evidence to compel the conclusion that the proposed regulation should be rejected as bad for the environment.

In addition, the National Environmental Policy Act requires the preparation of a proper Environmental Impact Statement before the regulation can be adopted.

Sincerely,

InternationalMosaic.com

Andrew J. Yamamoto, Esq, Editor

Scott D. Pinsky, Esq., Environmental Law Editor