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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />83 <br />4. The Capture of Methane Is Critical Due to Its Global Warming <br />Potential. <br /> <br />As discussed in Section II.D.2., above, in the context of coal mine methane, it is critically <br />important to reduce methane waste from fossil fuel production in order to limit climate damages. <br />Ensuring compliance with the agency’s methane waste obligations through proper analysis and <br />documentation in the NEPA process is important: technologies and practices change, and the <br />UFO’s duty to prevent degradation and waste cannot be excused just because the agency <br />apparently lags behind the technological curve. The GAO’s 2010 report noted that BLM’s <br />existing waste prevention guidance—Notice to Lessees and Operators (“NTL”) 4a—was <br />developed in 1980, well before many methane reduction technologies and practices were <br />developed and understood. GAO also found that NTL 4a does not “enumerate the sources that <br />should be reported or specify how they should be estimated.”238 Problematically, GAO noted <br />“that [BLM] thought the industry would use venting and flaring technologies if they made <br />economic sense,” a perspective which assumes – wrongly – that markets work perfectly in the <br />absence of necessary regulatory signals and is belied by the lack of information about the <br />magnitude of methane waste and the documented, if still poorly understood, barriers to the <br />deployment of GHG reduction technologies and practices. Id. at 20-33. Compounding the <br />problem, GAO also “found a lack of consistency across BLM field offices regarding their <br />understanding of which intermittent volumes of lost gas should be reported to [the Oil and Gas <br />Operations Report].” Id. at 11. BLM, to its credit, conceded: “existing guidance was outdated <br />given current technologies and said that they were planning to update it by the second quarter of <br />2012.” Id. at 27. <br /> <br />Indeed, a Report released by NRDC identified that “[c]apturing currently wasted methane <br />for sale could reduce pollution, enhance air quality, improve human health, conserve energy <br />resources, and bring in more than $2 billion of additional revenue each year.”239 Moreover, the <br />Report further identified ten technically proven, commercially available, and profitable methane <br />emission control technologies that together can capture more than 80 percent of the methane <br />currently going to waste. Id. Such technologies must also be considered in BLM’s alternatives <br />analysis. <br /> <br />Preventing GHG pollution and waste is particularly important in the natural gas context, <br />where there is an absence of meaningful lifecycle analysis of the GHG pollution emitted by the <br />production, processing, transmission, distribution, and combustion of natural gas. Although <br />natural gas is often touted as a ‘cleaner’ alternative to dirty coal, recent evidence indicates that <br />this may not, in fact be the case – and, at the least, indicates that we must first take immediate, <br />common sense action to reduce GHG pollution from natural gas before it can be safely relied on <br />as an effective tool to transition to a clean energy economy (a noted priority of this <br /> <br />238 See GAO-11-34 (2010) at 11, 27 (attached as Exhibit 121). 239 Susan Harvey, et al., Leaking Profits: The U.S. Oil and Gas Industry Can Reduce Pollution, <br />Conserve Resources, and Make Money by Preventing Methane Waste (March 2012) (attached as <br />Exhibit 125).