Comment on the EPA’s Proposed Waste Emissions Charge for Methane from Oil and Gas Infrastructure

Please use this link to submit a formal comment: 

https://www.federalregister.gov/documents/2024/01/26/2024-00938/waste-emissions-charge-for-petroleum-and-natural-gas-systems#open-comment 

Feel free to directly copy and paste or edit Clean Air Council’s suggested comment into the Federal Register comment form linked above.

When prompted “Tell us about yourself! I am…” please select “An Individual.” 

Please also fill out the petition below so Clean Air Council can track your engagement.

Comments are due March 26, 2024.

 

Suggested Comment:

The U.S. Environmental Protection Agency’s (EPA’s) proposed Waste Emissions Charge (WEC) is a tool to reduce methane emissions from the oil and gas industry. The WEC would assess a commonsense fee on the nation’s largest oil and gas polluters and hold them accountable for their emissions. It would also incentivize companies to take action now to reduce their emissions and comply with federal methane standards once they are in effect in all states. I support this rulemaking as an important step in combating the climate crisis. 

There are still a number of ways that the EPA can strengthen the WEC to protect impacted communities, promote methane reductions, and hold operators accountable.

I urge EPA to preserve some and strengthen other key aspects of its proposed rule in the following ways:

1. Continue making the regulatory compliance exemption available only once final methane standards and associated state plans are approved and in effect in all states. Operators must also demonstrate full compliance across facilities.

2. Ensure emissions netting provisions are more protective by continuing to base “common ownership” on a common owner or operator, and not the parent company, to reduce the number of facilities that can be used to offset emissions that may exceed the limit. Additionally, limit the geographic scope of netting by state to reduce likelihood of emissions reductions in one state enabling excessive emissions to harm communities in another state.

3. Designate the chief operator of a facility with multiple owners or operators as the entity responsible for meeting WEC obligations by default.

4. Only grant permitting delay exemptions on a case-by-case basis that require operators to demonstrate the absolute necessity of a requested gathering or transmission pipeline for gas offtake; does not consider any litigation-related delays; and requires evidence from operators that no other means of gas rerouting or on-site usage is possible before allowing exempted gas to be flared.

5. Include requirements under the well plugging exemptions to show wells are properly plugged and are no longer polluting.

Thank you for meaningfully considering my comment.