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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />73 <br />This proposed regulation aims to reduce the waste of natural gas from mineral leases <br />administered by the BLM. This gas is lost during oil and gas production activities <br />through flaring or venting of the gas, and equipment leaks. While oil and gas production <br />technology has advanced dramatically in recent years, the BLM’s requirements to <br />minimize waste of gas have not been updated in over 30 years. The Mineral Leasing Act <br />of 1920 (MLA) requires the BLM to ensure that lessees “use all reasonable precautions to <br />prevent waste of oil or gas developed in the land . . . . “ 30 U.S.C. 225. The BLM <br />believes there are economical, cost-effective, and reasonable measures that operators <br />should take to minimize waste, which will enhance our nation’s natural gas supplies, <br />boost royalty receipts for American taxpayers, tribes, and States, and reduce <br />environmental damage from venting and flaring. <br /> <br />Waste Prevention, Production Subject to Royalties, and Resource Conservation: Proposed Rule, <br />81 Fed. Reg. 6616, 6616 (February 8, 2016). The BLM must consider federal rulemaking on <br />Order No. 9, and the implications that this rule would have on action in its planning level <br />decision-making, such as the establishment of mandatory requirements to prevent methane <br />venting, flaring, and leaks. <br /> <br /> The Western Environmental Law Center and our partners also recently submitted <br />comments on this proposed rule. These comments are incorporated herein, attached hereto as <br />Exhibit 123, and must also be considered by the UFO when undertaking the Uncompahgre <br />RMP/EIS planning process. See 40 C.F.R. § 1502.9(c)(1)(ii). <br />2. President Obama’s Climate Action Plan and Secretarial Order 3289. <br /> <br />President Obama’s Climate Action Plan explains that “[c]urbing emissions of methane is <br />critical to our overall effort to address global climate change.” See Climate Action Plan at 10. <br />More recently, in March 2014, the White House issued a “Strategy for Reducing Methane <br />Emissions,” which includes a directive to the Interior Department to reduce methane emissions: <br /> <br />Minimizing Venting and Flaring on Public Lands: <br />DOI's Office of Inspector General and the U.S. Government Accountability <br />Office have both criticized BLM's outdated requirements governing venting and <br />flaring for wasting Federal gas resources and associated royalties to the American <br />taxpayer. To reduce the loss of natural gas through the venting or flaring of <br />methane produced from Federal and Indian oil and gas leases, the BLM will <br />develop a draft rule, known informally as Onshore Order 9, and anticipates <br />releasing this proposed rule later this year. To aid in the development of the rule, <br />DOI has begun outreach to tribes, industry and other stakeholders.233 <br /> <br />The President’s call-for-action on methane is directly related to BLM’s authorities and <br />responsibilities, beyond the MLA, to reduce methane emissions. <br /> 233 White House, Strategy for Reducing Methane Emissions, (March 2014), available at: <br />http://www.whitehouse.gov/sites/default/files/strategy_to_reduce_methane_emissions_2014-03- <br />28_final.pdf (attached as Exhibit 1).