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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 88 improve our knowledge base regarding GHG emissions from oil and gas production, providing some measure of clarity to this important issue by taking the requisite “hard look” NEPA analysis as part of its land use decision-making for the Uncompahgre RMP and EIS.264 Convincing evidence also exists to support the consideration of alternatives that would attach meaningful stipulations to areas open to oil and gas leasing, above and beyond the steps taken by the agency, here. As a prime contributor to short-term climate change over the next few decades, methane is a prime target for near-term GHG reductions. In fact, there are many proven technologies and practices already available to reduce significantly the methane emissions from oil and gas operations, further detailed below. These technologies also offer opportunities for significant cost-savings from recovered methane gas. Moreover, new research indicates that tropospheric ozone and black carbon (“BC”) contribute to both degraded air quality and global warming, and that emission control measures can reduce these pollutants using current technology and experience.265 Employment of these strategies will annually avoid a substantial number of premature deaths from outdoor air pollution, as well as increase annual crop yields by millions of metric tons due to ozone reductions. Indeed, reducing methane emissions is important not only to better protect the climate, but also to prevent waste of the oil and gas resource itself and the potential loss of economic value, including royalties. BLM should evaluate these technologies, analyzing the benefits of technological implementation versus current agency requirements. These benefits – as well as the proven, cost-effective technologies and practices that achieve these benefits – are documented by EPA’s “Natural Gas STAR” program, which encourages oil and natural gas companies to cut methane waste to reduce climate pollution and recover value and consolidates the lessons learned from industry for the benefit of other companies and entities with oil and gas responsibilities such as BLM.266 EPA has identified well over 100 proven technologies and practices to reduce methane waste from wells, tanks, pipelines, valves, pneumatics, and other equipment and thereby make operations more efficient.267 Though underutilized, EPA’s Natural Gas STAR program suggests the opportunity to dramatically reduce GHG pollution from oil and gas development, if its identified technologies and practices were implemented at the proper scale and supported by EPA’s sister agencies, such as BLM. For calendar year 2010, EPA estimated that this program avoided 38.1 million tons CO2 equivalent, and added revenue of nearly $376 million in natural gas sales (at $4.00/Mcf) – revenue which translates into additional royalties to federal and state governments for the American public.268 264 In this context, the 2010 SIR, while providing a basic literature review of GHG emissions sources, is merely a starting point for BLM’s responsibility to take a hard look at GHG emissions in the context of foreseeable drilling operations in the geologic formations proposed for leasing. 265 Drew Shindell, et al., Simultaneously Mitigating Near-Term Climate Change and Improving Human Health and Food Security, SCIENCE 2012 335, at 183 (attached as Exhibit 143). 266 See generally, EPA, Natural Gas STAR Program, available at: www.epa.gov/gasstar/. 267 See EPA, Natural Gas STAR Program, Recommended Technologies and Practices, available at: www.epa.gov/gasstar/tools/recommended.html. 268 See EPA, Natural Gas STAR Program, Accomplishments, available at: www.epa.gov/gasstar/accomplishments/index.html#three (attached as Exhibit 144). BLM should also take a look at EPA’s more detailed program accomplishments to provide a measure of what