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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />80 <br />analysis of the proposed action. Wide ranges of technologies and BMPs have been identified in <br />numerous sources, including the BLM itself.234 <br /> <br />We believe that these additional measures must receive a hard look, and be adopted in the <br />UFO RMP/EIS because: (1) they can reduce methane emissions to help protect the climate; (2) <br />can minimize methane waste; (3) can have paybacks for industry from the sale of captured <br />methane, even at today’s low gas prices; and (4) because failure to adopt them as mandatory <br />methane emissions and waste mitigation measures in the RMP/EIS may well jeopardize the <br />ability of the UFO to require them in critical later stages of development, such as lease sales and <br />APDs after lease rights are conveyed. <br /> <br />Conservation Groups also believe that the UFO should require gas capture planning by <br />lessees and planning and timely development of gas gathering, boosting and processing <br />infrastructure to ensure that GHG emissions are reduced, that revenues from gas sales are <br />maximized for royalty payments for the federal and state governments, and that waste of this <br />important resource is minimized. <br /> <br />Moreover, the EPA, in a recently released white paper,235 also identifies additional field <br />use measures that reduce flaring and waste: <br /> <br />• Compression of natural gas for transport; <br /> <br />• Methane re-injection; <br /> <br />• Electric power generation for on-site use or connection to the grid. <br /> <br />Critically, another approach—outlined below and promoted by industry—has been <br />advanced to successfully reduce methane venting, flaring, and waste, and the UFO should <br />require production and midstream companies to conduct front-end planning employing these <br />techniques and provide the results of the plans to the UFO. In January 2014, the 500-member <br />North Dakota Petroleum Council (www.ndoil.org) recommended that the state oil and gas <br />regulator (“NDIC”) require the following: <br /> 234 See BLM, Best Management Practices for Fluid Minerals, available at: <br />http://www.blm.gov/pgdata/etc/medialib/blm/wo/MINERALS__REALTY__AND_RESOURCE <br />_PROTECTION_/bmps.Par.60203.File.dat/WO1_Air%20Resource_BMP_Slideshow%2005-09- <br />2011.pdf (attached as Exhibit 124); BLM, Montana/Dakotas, 2010 Oil and Gas Leasing EAs, <br />available at: http://www.blm.gov/mt/st/en/prog/energy/oil_and_gas/leasing/leasingEAs.html; <br />CARPP at Appendix L; EPA, Natural Gas STAR Program, available at: <br />http://www.epa.gov/gasstar/; and Susan Harvey, et al., Leaking Profits: The U.S. Oil and Gas <br />Industry Can Reduce Pollution, Conserve Resources, and Make Money by Preventing Methane <br />Waste (attached as Exhibit 125). 235 EPA, Office of Air Quality Planning and Standards, Oil and Natural Gas Sector <br />Hydraulically Fractured Oil Well Completions and Associated Gas during Ongoing Production <br />(April 2014), available at: https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas- <br />industry (attached as Exhibit 126).