Today’s comments about the EPA’s proposal sheds light on the methane issue. The editors said in substance (some quotation marks removed and formatting changed):
Oil and Natural Gas Sector: Emission Standards for New, Reconstructed,
and Modified Sources Reconsideration
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.
In addition to the Black Friday report referenced in our December 9, 2018 submission on
this matter, there is a wealth of published scientific evidence that methane leaks
associated with oil and natural gas production present a major climate change danger.
For example, one UN article states in part:
“The Problem with Methane
“Methane is a greenhouse gas as is carbon dioxide. Human activity has increased the amount of methane in the atmosphere, contributing to climate change. Methane is particularly problematic as its impact is 34 times greater than CO2 over a 100-year period, according to the latest IPCC Assessment Report. A significant source of human-made methane emissions is fossil fuel production. For example, methane is a key by-product of the rapidly rising global extraction and processing of natural gas. Other top sources of methane come from the digestive process of livestock and from landfills, which emit it as waste decomposes.
“The Growing Response to Climate Change
“The current level of response remains inadequate to keep the average global temperature rise below two degrees Celsius, beyond which expected climate change impacts become significantly worse. But action to curb human-generated greenhouse gas emissions is rapidly increasing at every level of government, business, cities and civil society as the many economic, social and environmental benefits of taking climate action become clear.“
UN Article, “Why Methane Matters”, Aug. 7, 2014. For the full article, please see:
“In addition, [as we stated in our December 9, 2018 comments] 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.
A twenty year time window is very conservative given the accelerating pace of climate
change related disasters.”
By itself, the UN article constitutes legally sufficient evidence to compel the conclusion
that the proposed regulation should be rejected as bad for the environment.
Also, the National Environmental Policy Act requires the preparation of a proper
Environmental Impact Statement before the regulation can be adopted because the
regulation constitutes a major federal action almost certain to tragically harm the
Andrew J. Yamamoto, Esq., Editor
Scott D. Pinsky, Esq., Environmental Law Editor