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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />84 <br />Administration).240 A recent report by Climate Central addresses the leak rates estimated by <br />various sources and the impacts of this new information on assertions that natural gas is a cleaner <br />fuel than coal, ultimately concluding that given the losses from oil and gas sources it would be <br />decades before switching electricity generation from coal to natural gas could bring about <br />significant reductions in emissions.241 While the UFO has identified the issue of fugitive <br />emissions and waste, Conservation Groups urge the agency to strengthen this path through <br />additional hard look analysis and enforceable mitigation requirements. <br /> <br />Oil and natural gas systems are the biggest contributor to methane emissions in the <br />United States, accounting for over one quarter of all methane emissions.242 Moreover, methane <br />emissions in the planning area are further compounded by massive contributions from area coal <br />mines—in particular the West Elk Mine—as well as significant oil and gas production and <br />emissions in the Piceance Basin and Uintah Basin, both of which impact planning area air <br />quality. In light of serious controversy and uncertainties regarding GHG pollution from oil and <br />gas development, as noted above, the agency’s quantitative assessment should account for <br />methane’s long-term (100-year) global warming impact and, also, methane’s short-term (20- <br />year) warming impact using the latest peer-reviewed science to ensure that potentially significant <br />impacts are not underestimated or ignored. See 40 C.F.R. § 1508.27(a) (requiring consideration <br />of “[b]oth short- and long-term effects”). <br /> <br />Again, the UFO assumes that methane is 21 times as potent as carbon dioxide (“CO2”) <br />over a 100-year time horizon,243 a global warming potential (“GWP”) based on the <br />Intergovernmental Panel on Climate Change’s (“IPCC”) Second Assessment Report from <br />1996.244 However, the IPCC recently updated their 100-year GWP for methane, substantially <br />increasing the heat-trapping effect to 36.245 A Supplementary Information Report (“SIR”), <br />prepared for BLM’s oil and gas leasing program in Montana and the Dakotas, further explains <br />that GWP “provides a method to quantify the cumulative effect of multiple GHGs released into <br /> <br />240 Robert W. Howarth, Assessment of the Greenhouse Gas Footprint of Natural Gas from Shale <br />Formations Obtained by High-Volume, Slick-Water Hydraulic Fracturing (Rev’d. Jan. 26, 2011) <br />(attached as Exhibit 129). See also Robert W. Howarth et al., Venting and Leaking of Methane <br />from Shale Gas Development: Response to Cathles et al. (2012) (attached as Exhibit 130); Eric <br />D. Larson, PhD, Climate Central, Natural Gas and Climate Change (May 2013) (attached as <br />Exhibit 131). 241 See Larson (attached as Exhibit 131). 242 Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2011 (attached as Exhibit 122). 243 See 78 Fed.Reg. 19802, April 2, 2013 (EPA proposal to increase methane’s GWP to 25 times <br />CO2). <br />244 INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, Second Assessment Report (1996) <br />(attached as Exhibit 132); see also U.S. Environmental Protection Agency, Methane, available <br />at: http://www.epa.gov/outreach/scientific.html. 245 See INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, Working Group I Contribution to the <br />IPCC Fifth Assessment Report Climate Change 2013: The Physical Science Basis, at 8-58 (Table <br />8.7) (Sept. 2013) (attached as Exhibit 113).