My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
2017-05-25_REVISION - C1996083
DRMS
>
Day Forward
>
Revision
>
Coal
>
C1996083
>
2017-05-25_REVISION - C1996083
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
5/31/2017 6:58:38 AM
Creation date
5/26/2017 8:37:53 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1996083
IBM Index Class Name
Revision
Doc Date
5/25/2017
Doc Name Note
(Citizen Concerns)
Doc Name
Comment
From
Andrew Forkes-Gudmundson
To
DRMS
Type & Sequence
TR112
Email Name
CCW
JRS
Media Type
D
Archive
No
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
199
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />69 <br />regulatory actions that are projected to influence [methane or nitrogen oxide] emissions in a <br />manner consistent with how [carbon dioxide] emission changes are valued.”223 Like the social <br />cost of carbon, the social cost of methane is presented as a range of figures across four discount <br />rates; it is based on results from three integrated assessment models; displayed in dollars per <br />metric ton of emissions; and increases over time because emissions become more damaging as <br />their atmospheric concentrations increase.224 Like the social cost of carbon, the social cost of <br />methane has been subject to peer review and will be updated by the IWG to ensure it reflects the <br />best available scientific information.225 The IWG estimates that each additional ton of methane <br />emitted in 2020 will cause between $540 and $3,200 dollars (measured in $2007).226 <br /> <br />BLM should use the best tools available to it in order to fully analyze and disclose the <br />climate impacts of its proposal. Given that both the social cost of carbon and social cost of <br />methane have been adopted by the IWG, which includes a dozen federal offices and agencies <br />including the Department of Interior, BLM should use these tools to evaluate the climate impacts <br />of its draft plan for the Uncompahgre planning area, which, as noted, anticipates generating more <br />than half a billion tons of CO2-e over the next two decades. <br />F. Methane Emissions and Waste <br /> <br />Methane emission rates can differ quite dramatically from one oil and gas field to the <br />next, and, depending on the type of mitigation and emission controls employed, natural gas <br />production emissions have been found to average 5.4%—ranging anywhere from 1% to 12% of <br />production.227 A series of peer-reviewed studies have shown leakage rates for individual sources <br />in the natural gas supply chain and in Western basins to be much higher than that estimated by <br />EPA.228 <br /> <br />223 Id. at 3. 224 Id. at 7. 225 Id. at 3. 226226 Id. at 7. For comparison purposes, the current social cost of carbon values for CO2 <br />emissions in 2020 range from $120 to $123 per ton. 227 A.R. Brandt et al., Methane Leaks from North American Natural Gas Systems, 343 Science <br />733 (finding average methane emissions from natural gas production of 5.4%) (attached as <br />Exhibit 114) 228 See, e.g., David T. Allen et. al., Measurements of Methane Emissions at Natural Gas <br />Production Sites in the United States, Proceedings of the National Academy of Sciences, August. <br />19, 2013 (finding emissions as low as 1.5% of production at select sites) (attached as Exhibit <br />115); Austin L. Mitchell et al., Measurements of Methane Emissions from Natural Gas <br />Gathering Facilities and Processing Plants: Measurement Results, 49 Environ. Sci. Technol. <br />3219 (2015) (finding leakage rates from gas gathering and processing infrastructure eight times <br />greater than EPA estimates) (attached as Exhibit 116); David T. Allen et al., Methane Emissions <br />from Process Equipment at Natural Gas Production Sites in the United States: Pneumatic <br />Controllers, 49 Environ. Sci. Technol. 633, 636, 638 (2014) (finding leakage rates from <br />pneumatic controllers three times greater than EPA estimates) (attached as Exhibit 117); David <br />R. Lyon, et al., Aerial Surveys of Elevated Hydrocarbon Emissions from Oil and Gas Production <br />Sites, 50 Environ. Sci. Technol. 4877 (2016) (finding high leak rates from storage tanks)
The URL can be used to link to this page
Your browser does not support the video tag.