Jun 28, 2024 Methane Budget Language Coalition Support Letter
Dear Chairman Simpson and Ranking Member Pingree:
This letter is submitted on behalf of the organizations listed below. These organizations want to express serious concerns regarding the impact of the Environmental Protection Agency’s (EPA) new methane emissions regulation (Subpart OOOOc) on oil and natural gas marginal well owners. We write to request that targeted regulatory relief be included in Title II of the report accompanying the Subcommittee on Interior, Environment, and Related Agencies’ FY 2025 appropriations bill. Specifically, we seek a tailored accommodation from the U.S. Environmental Protection Agency’s new final rule entitled, “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review,” 89 Fed. Reg. 16,820 (Mar. 8, 2024) (the “Final Rule”).
The Final Rule fails to adequately consider many important factors, including the extraordinary damage it will cause to thousands of marginal oil and gas wells (i.e., those that produce less than 15 barrels of oil per day and less than 90 Mcf of gas per day) that are vital to the energy security of our states and country. Many of these small family businesses will be forced to close their wells, resulting in the loss of thousands of good paying jobs, and harming the millions of people who rely on their energy output. Prior rulemakings in this area have recognized that accommodations for marginal wells are necessary, and we believe such careful balancing in this rule would have been appropriate, as well. …