Dear Director Donovan:
We write to respectfully request prompt consideration and review of significant new rules being developed by the Bureau of Land Management (BLM) and Environmental Protection Agency (EPA) to reduce the waste of methane in oil and gas production. In terms of federal lands, New Mexico is the nation's leading producer of oil and number two for gas.
Too much of New Mexico's natural gas is being lost due to venting, flaring and leaks. A NASA study has identified a methane hot spot the size of Delaware over the San Juan Basin--the highest concentration in the nation--in an area of high oil and gas production. This methane pollution represents a significant economic loss to the state of New Mexico and the nation. When natural gas is vented or flared, it is not included in calculations used to determine royalty payments. As a result, both the state of New Mexico and all American taxpayers lose out on royalties owed on the production of these federally owned minerals.
This wasted natural gas is also a significant public health issue. Though methane is the largest constituent of natural gas, other toxic pollutants like benzene are often released at the same time. Methane waste also contributes to smog, increasing the potential for ozone non-attainment in areas with heavy oil and natural gas development.
Lastly, curbing methane pollution is critical as a part of our nation's efforts to combat climate change. Pound for pound, methane is more than 80 times more potent than carbon dioxide in the first 20 years after its release and is already responsible for a quarter of man-made warming we are experiencing today, according to the Intergovernmental Panel on Climate Change.
We recognize that oil and gas producers have an economic incentive to minimize methane losses and the industry is improving its practices. However, federal action is necessary to ensure that steps to limit methane releases are applied consistently across the industry. Rules to reduce the impact of methane releases on public health, while ensuring that Americans receive fair compensation for the production of federal minerals, are critical to reducing methane waste and pollution. Thank you for your work to review these proposed rules in a timely manner.