at the written ?tates Washington, EN: 20510 November 2, 2017 The Honorable Ryan Zinke Secretary US. Department of the Interior 1849 Street, NW. Washington, DC. 20240 Dear Mr. Secretary: We write in strong opposition to the Bureau of Land Management?s (BLM) recent announcement that it intends to pursue a new rulemaking to repeal or revise the agency?s methane waste prevention rule and any unlawful attempts to delay enforcement of the existing rule. We support the rule because it prevents the unnecessary waste of a public resource, and makes sure that American taxpayers get fair value in return for commercial use of that public resource. The rule updated BLM regulations that had become obsolete over the past 35 years. The increased oil and gas development on public lands including widespread use of horizontal drilling and tracking can pose signi?cant risks to clean air, clean water, human health, wildlife, and local communities. Numerous independent reports and investigations, including those from the U.S. Government Accountability Of?ce (GAO), documented that outdated policies did not take account of currently available technologies that reduce waste from venting and ?aring. The GAO has repeatedly found that the Department of the Interior (DOI) can do more to minimize waste of public oil and gas resources.1 GAO has continued to place the management of federal oil and gas resources in its ?High Risk List? of federal programs that are especially vulnerable to waste, fraud, abuse, and mismanagement.2 Wasted natural gas from oil and gas operations across the United States is estimated at approximately $2 billion every year and would be enough gas to heat over 7 million homes. This includes an estimated $330 million worth of natural gas just from public and Tribal lands that could be prevented through the rule. The administration has a statutorily required obligation to prevent the waste of this valuable resource on public lands, a resource that belongs to the taxpayers. The American people deserve to get a proper return on this natural gas resource, and any attempt to roll back this rule would represent a giveaway to industry polluters. If the rule is delayed, the BLM itself estimates that an additional 175,000 to 250,000 tons of methane and volatile organic compounds would pollute the air we breathe. And yet the BLM found that implementation of the rule would reduce average company pro?ts by only 0.15 percent and, 1 See GAO-16-607 Interior Could Do More to Account for and Manage Natural Gas Emissions; GAO-11-34 Opportunities Exist to Capture Vented and Flared Natural Gas, Which Would Increase Royalty Payments and Reduce Greenhouse Gases; GAO-O4-809 Opportunities to improve Data and Reduce Emissions 2 HIGH-RISK SERIES: Progress on Many High-Risk Areas, While Substantial Efforts Needed on Others if savings from increased revenues from increased gas sales are taken into account, the net economic bene?t to industry could be as much as $46 million per year3. Protecting the health and safety of the American people is inarguably a core function of government and the rule?s requirements are based on well-reasoned science. Capturing and preventing methane emissions will reduce exposure of hazardous pollutants in our local communities and will provide economic bene?ts to industry. The Department?s stated rationale for moving to repeal or revise the rule is not supported by the facts. There is no credible evidence that the rule will cause marginal wells to shut-in, will drive industry away from federal and Tribal lands, or will result in job loss. The state of Colorado enacted similar methane control rules in 2014, and has not experienced any of these negative consequences. Since the BLM rule went into effect on January 17, 2017 there has been no evidence of any signi?cant negative impacts on economic activity in the oil and gas sector. Given the paucity of information provided by BLM in its Federal Register notice, and the great public interest in this rule, we respectfully request the public comment period be extended an additional 60 days, to a total of 90 days, and that public hearings especially in the Western US. be added to ensure adequate opportunity for public involvement. We also ask that you ensure the social cost of methane used to evaluate the bene?ts of the rule conforms to a science-based approach and re?ects the October 4, 2017 decision in the Northern District of California District Court. Finally, the Federal District Court rejected the attempt to delay compliance with the Methane and Waste Prevention Rule, and ordered BLM to immediately enforce all provisions of the rule that have taken effect. We urge you to fully implement those provisions without further delay. 6? War Tom Udall United States Senator Sincerely, 9 er of Con?ress Maria Cantwell RailLM. Grij'alva United States Senator Member of Congress 7 3 Regulatory Impact Analysis for: Revisions to 43 CFR 3100 (Onshore Oil and Gas Leasing) and 43 CFR 3600 (Onshore Oil and Gas Operations); Additions of 43 CFR 3178 (Royalty-Free Use of Lease Production) and 43 CFR 3179 (Waster Prevention and Resource Conservation), US. Bureau of Land Management, November 10, 2016. 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