Oil and Gas Methane Pollution Report

1Oil and Gas Methane Pollution: An Invisible Threat to Wildlife and Economic Opportunity for Communities
Oil and Gas Methane Pollution
An Invisible Threat to Wildlife and Economic
Opportunity for Communities
NOVEMBER 2016

2 Oil and Gas Methane Pollution: An Invisible Threat to Wildlife and Economic Opportunity for Communities
Oil and Gas Methane Pollution
An Invisible Threat to Wildlife and
Economic Opportunity for Communities
Copyright © 2016 National Wildlife Federation
Lead Authors: Shannon Heyck-Williams, Lauren Anderson, and Jim Murphy.
We wish to thank the following contributors to this report: Dave Dittloff, David Ellenberger, Tara Losoff,
Tracy Sabetta, Andy Schulteiss, Frank Szollosi, Garrit Voggesser, and Kate Zimmerman.
Suggested citation: Heyck-Williams, S., L. Anderson, and J. Murphy. 2016. Oil and Gas Methane Pollution:
An Invisible Threat to Wildlife and Economic Opportunity for Communities. National Wildlife Federation:
Washington, DC.
Cover image: Pronghorn. Photo: Flickr.
National Wildlife Federation
1990 K Street NW
Washington, DC 20006
www.nwf.org

Oil and Gas Methane Pollution: An Invisible Threat to Wildlife and Economic Opportunity for Communities
Table of CONTENTS
Executive Summary...................................................................... 1
Overview: Methane Pollution...................................................... 3
Origins in the Oil and Gas Industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Threats to Wildlife and Outdoor RecreatioN............................. 6
Our National Parks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Glacier National Park. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Grand Teton National Park . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Cuyahoga Valley National Park. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Rocky Mountain National Park. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Compounding Concerns for Wildlife: Oil and Gas Infrastructure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Economic Considerations ........................................................... 9
Wasted Gas and Lost Revenues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Reducing Pollution is Cost-Effective . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Voluntary and Regulatory Efforts—Status and Limitations......10
Regulatory Efforts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
U.S. Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
State Efforts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
The Colorado Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Ohio: Challenges and Opportunities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Voluntary Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Conclusion and Policy Recommendations .................................. 15
Endnotes..................................................................................... 16

Oil and Gas Methane Pollution: An Invisible Threat to Wildlife and Economic Opportunity for Communities1
ethane gas pollution is a serious threat to
wildlife. As a climate “super pollutant,”
methane has over 80 times the climate-
altering potential as carbon dioxide (CO2) in the
near term (over the next two decades), and is the
second leading cause of climate change behind CO2.
Fortunately, steps can be taken to protect wildlife
by dramatically reducing methane pollution from
its leading source, the oil and gas industry. This
report outlines the wildlife-related threats posed
by uncontrolled methane pollution from oil and gas
operations and details how we can significantly curtail
this threat while capturing a valuable resource that is
now being wasted.
Wildlife are under siege from human-caused climate
change, which is accelerating at an alarming rate.
Changes to our climate are having profound impacts on
critical wildlife habitat, causing habitat ranges to shift
or be lost, increasing incidence of pests and invasive
species, decreasing available food and water, and
speeding the rate of species extinction. Indeed, climate
change is partly to blame for a mass extinction event
that some scientists say is now underway.
EXECUTIVE SUMMARY
M
Cutthroat trout. Photo: Latham Jenkins.

Oil and Gas Methane Pollution: An Invisible Threat to Wildlife and Economic Opportunity for Communities 2
report makes the following recommendations, which
should be implemented by this Administration and the
next to curtail the methane threat to wildlife:
• Propose, finalize, and implement strong
Environmental Protection Agency rules limiting
methane pollution from existing sources in the oil and
gas industry.
• Successfully implement recent federal rules
limiting methane pollution from new and modified oil
and gas sources.
• Finalize a proposed rule by the Bureau of Land
Management that would substantially curtail methane
waste from both existing and new sources of gas and oil
production on public and tribal lands.
• Continue to support state efforts to reduce methane
pollution from oil and gas operations, such as the
strong standards in place in Colorado.
• Continue to support voluntary efforts that
produce results.
Examples of current climate impacts to wildlife and
associated outdoor recreation are already troubling:
• Cold weather-dependent moose are declining
dramatically in northern states as milder winters fail to
kill parasitic ticks.
• Trout streams in the West are becoming too warm
in many months to support fishing, threatening key
species like bull trout and cutthroat trout. For instance,
bull trout in Montana are at risk of losing up to 92
percent of their suitable habitat.
• Bat species could disappear from their maternal
range (range used by female bats when raising their
young) in the Cuyahoga National Park and other places
in the Northeast if warming trends continue.
• Warmer, dryer summers and warmer, shorter winters
in our national parks are allowing mountain pine
beetles to thrive and destroy vast swaths of publicly-
owned forests.
• A massive fish kill has recently broken out in the
Yellowstone River in part because waters were too
warm and shallow.
Methane is the chief component of natural gas, and
is also a by-product of some oil production. Methane
accounts for more than one-tenth of the greenhouse
gases released due to human activity, with the oil and
gas sector comprising the largest industrial source of
that pollution. Much of this pollution is pure waste.
Throughout the oil and gas supply chains, an
enormous amount of methane is often either
intentionally vented or flared into the atmosphere or
allowed to escape through leaky wells, pipes, pumps,
and other equipment. This is not only polluting the
atmosphere, it is wasting enough fuel to provide heat
for 6.5 million homes.
Methane pollution is a problem we can solve with
cost-effective measures. The U.S. has adopted a goal to
reduce methane emissions from the oil and gas industry
by 40-45 percent by 2025. This goal can be met. This Indiana bat. Photo: USFWS.

in conjunction with crude oil reservoirs (i.e., as
associated natural gas). As a result, methane pollution
can originate in the oil sector as a byproduct of oil
extraction.5
For the purposes of this report, however,
we will group the associated impacts of natural gas
and oil industry emissions together, reflecting the close
relationship between the two systems.
According to the U.S. Environmental Protection Agency,
nearly eight million tons of methane pollution were
emitted from the oil and gas sector overall in 2014.6
This number is about 30 percent higher than the
agency’s previous estimates.7
Pollution levels may
still be underestimated, due to the opportunities for
emissions to occur at many different points throughout
the oil and gas supply chains. Furthermore, EPA
projects that absent additional regulation, methane
emissions from the oil and gas industry will grow by 25
ethane is a super pollutant that has over
80 times the impact on climate change as
carbon dioxide over the course of a 20-
year period.1
Methane accounted for approximately 11
percent of total U.S. greenhouse gas emissions in
2014 and was the second most prevalent greenhouse
gas emitted after carbon dioxide. Oil (petroleum)
and natural gas systems make up nearly one-third
of U.S. methane emissions and together are the
largest pollution source.2
Natural gas consists largely of methane.3
Intentional
and accidental release of methane from natural gas
represents a waste of a valuable energy resource and
a risk to wildlife, human health, and natural resources
from a range of impacts. Methane has the potential
to be released to the atmosphere throughout the
natural gas supply chain. Natural gas is also found
OVERVIEW: METHANE POLLUTION
M
82% Carbon Dioxide
10% Methane
5% Nitrous Oxide
3% Fluorinated Gases
33% Natural Gas and Petroleum Systems
22% Enteric Fermentation
20% Landfills
9% Coal Mining
8% Manure Management
6% Other
U.S. Greenhouse Gas Emissions, by Gas4
82% Carbon Dioxide
10% Methane
5% Nitrous Oxide
3% Fluorinated Gases
33% Natural Gas and Petroleum Systems
22% Enteric Fermentation
20% Landfills
9% Coal Mining
8% Manure Management
6% Other
U.S. Methane Emissions, by Source8

and storage comprise the second largest source and
are responsible for 27 percent of methane emissions.18
Solutions aimed at these stages would yield especially
significant benefits for overall industry efforts to curb
methane pollution.
While production and transmission contribute most
to methane pollution from the oil and gas sector, other
segments of the supply chain also emit methane and
should adopt emissions reduction solutions. For
example, in looking just at distribution, one report
notes that “[f]inding and fixing leaks at large, above-
ground distribution facilities could reduce emissions by
at least 283,000 metric tons per year.”19
Methane emissions also can occur in localized “hot
spots.” A 2014 study by the National Aeronautics and
Space Administration (NASA) identified a 2,500-square
mile cloud of pollution in New Mexico and the Four
Corners region as the single largest concentration of
methane emissions in the country.20
More recently,
NASA revealed that this massive hot spot of methane
gas is largely the result of leaks in oil and gas systems.21
In addition to methane, other harmful pollutants
also are emitted by the oil and gas sector. These
include volatile organic compounds (VOCs), air toxics
such as benzene (a known carcinogen), polycyclic
aromatic hydrocarbons (PAHs), hydrogen sulfide, and
particulates, which can cause a range of health ailments
(e.g., asthma and some cancers), air quality problems
(e.g., smog and ground-level ozone), and other
environmental impacts.22
Reducing methane emissions
from oil and gas development also will help curb
release of these pollutants, especially in areas where
industrial infrastructure is more prevalent.
percent in the next ten years as the industry expands in
response to the increased use of new technologies that
open access to additional oil and gas resources.9, 10, 11
Origins in the Oil and
Gas Industry
The majority—nearly fifty-four percent—of releases in
the energy sector occurs in the natural gas portion of
the industry, with nearly twenty-one percent from oil
systems.12
The U.S. oil and natural gas supply chains
are typically separated into three segments: upstream
(exploration/extraction, supply, and production);
midstream (pipelines, transportation, and storage);
and downstream (distribution).13
Methane emissions
can occur at all stages of development: from extraction
and production through the distribution of a final
product to end users, such as industry, businesses, and
home owners. The figure14
on page 5 illustrates the
supply chains, including where methane emissions can
occur in each.
Operators release natural gas directly into the
atmosphere through venting (i.e., direct release) and/
or flaring (i.e., burning).15
Some natural gas can also be
lost due to leaks from oil and gas wells, storage tanks,
pipelines, and processing plants.16
Thus, methane is
emitted into the atmosphere during the production,
processing, storage, transmission, and distribution
of natural gas. Because natural gas is often found
alongside petroleum, the production, refinement,
transportation, and storage of oil are sources of
methane pollution as well.17
The production phase of oil and gas operations
comprises the largest source of methane emissions,
with 46 percent of the total. Natural gas transmission
Oil and gas wells. Photo: Richard Masoner.

W A S T E N O T — R E P O R T S U M M A R Y 3
Emissions Come from All Segments of Natural Gas and Oil Development
Total Emissions (2014 EPA GHG Inventory) = 7.7 Million Tons of Methane
Oil Well Pad
Emissions come from leaks,
pneumatic devices, storage
tanks, and from the flaring
of associated gas.
Oil to Market
Natural Gas Well Pad
Emissions come from
leaks, unloading liquids
from wells, pneumatic
devices, compressors,
storage tanks, and
dehydrators.
Gathering Compressor
Used to increase the pressure of the gas in the
gathering pipelines. Emissions can come from
leaks, pneumatic devices,and compressors.
Gas Processing Plant
Large plants used to clean and pressurize
gas. Emissions mainly come from compressor
venting and leaks.
Transmission Compressor
Compressor stations for maintaining
gas pressure along interstate pipelines.
Emissions can come from from leaks,
pneumatic devices, and compressors.
Storage
Gas is often stockpiled in underground storage
facilities or stored as a liquid. Emissions can
come from compressor venting and leaks.
City Gates
Gas is measured and decompressed
at the city gate before it is put into final
sales lines. Emissions can come from
leaks throughout the distribution system
including above ground and below
ground pipelines.
Gas to Consumers
Oil and natural gas production is responsible
for 46% of methane emissions.
Gas processing
is responsible for
11% of methane
emissions.
Gas distribution
is responsible for
16% of methane
emissions.
Gas transmission and
storage is responsible
for 27% of methane
emissions.
Commercial Residential Industrial
November2014/©CleanAirTaskForce/NonprofitDesign.com
Source: Clean Air Task Force.

River were killed when temperature increases and
reduced flow from declining snowmelt led to the
proliferation of a deadly parasite. Nearly 200 miles of
the river had to be closed to fishing and all other forms
of water recreation as a result, derailing tourist fishing
and boating plans at peak summer vacation time, with
significant cost to many local businesses.29
Additionally, oil and gas infrastructure and exploration,
production, and related activity can harm wildlife
directly and fragment habitat and wildlife corridors,
thereby hindering migration routes and limiting access
to resources—reducing some species’ ability to adapt to
a changing climate. Impacts of oil and gas development
can also include wildlife mortality and displacement,
and introduction of invasive species.30
ethane pollution is the second leading
greenhouse gas, fueling climate change
that poses one of the greatest threats to
wildlife and outdoor recreation. Changes to our climate
are having profound impacts on critical wildlife habitat,
causing habitat ranges to shift or be lost, increasing
incidence of pests and invasive species, decreasing
available food and water, and accelerating the rate
of species extinction.23, 24
Scientists have concluded
that climate change and other factors are causing an
exceptionally rapid loss of biodiversity, and some say
that a mass extinction event is underway.25
While
estimates vary, one in every six species on Earth could
become extinct if climate change were to continue
apace.26
Fortunately, averting dramatic loss is still
possible through concerted action.
Similarly, outdoor recreation is impacted by climate
change as hunting and fishing opportunities decline,
and as increased droughts, floods, wildfires, and other
climate change-fueled events impair and restrict our
ability to enjoy the outdoors and wildlife.
Big game like moose, mule deer, elk, and pronghorn are
also severely impacted by rising temperatures, drought,
and an increase in the spread of diseases due to climate
change. For example, the moose population in New
Hampshire has declined by 40 percent in the last
decade, largely due to a rapid rise in tick infestations
caused by climbing temperatures that fail to kill
parasite populations during winter.27
As our climate
continues to change, these impacts will only become
more pronounced, affecting wildlife, economic activity,
and outdoor traditions.
Even small temperature increases in lakes, rivers, and
streams can have dramatic impacts on game fish, such
as salmon and trout.28
In one recent troubling example
in Montana, thousands of whitefish in the Yellowstone
THREATS TO WILDLIFE AND
OUTDOOR RECREATION
M
Baby pronghorn. Photo: Jacob W. Frank.

Grand Teton National Park
In 2014, tourism in Wyoming created 31,510 jobs
and generated a total of $3.33 billion.37
Grand Teton
National Park is a $502-million annual economic engine
at the heart of the state’s tourism industry. Like many
parks in the northern part of the country, plant and
animal species in Grand Teton depend on cold winters
and higher elevations for survival. Small changes in
temperature and precipitation can have great effect,
especially with limited options for migration to higher
altitudes. Climate change is expected to degrade or
denude much of the forested ecosystems that support
the park.38
According to a research ecologist who co-
authored a report on climatic change in the park,
“What you’re effectively talking about is massive loss
of forest cover in a region that’s mostly forest-covered.
The effects would cascade to virtually every species
and every process.”39
Further, higher temperatures and corresponding
changes in the amount of snow and timing of snowmelt
will have far-reaching impacts throughout the Greater
Yellowstone Network, which includes Grand Teton
National Park and Yellowstone National Park. According
to long-term studies conducted in Greater Yellowstone,
the wetland habitat that amphibian species depend
on for breeding is severely impacted by changes in
temperature and precipitation. Six native amphibian
species occur in Greater Yellowstone: western tiger
salamanders, boreal toads, boreal chorus frogs,
northern leopard frogs, Columbia spotted frogs, and
a spadefoot species. Lower snowpack reduces the
amount of meltwater and wetland habitat, while rapid
snowmelt inundates wetlands to the point where
habitat is lost. Climate change has the potential to
alter temperature and precipitation patterns, placing
amphibian species in the park at risk.40, 41
Cuyahoga Valley National Park
The 33,000-acre Cuyahoga Valley National Park
in Ohio surrounds 22 miles of the Cuyahoga River.
Located south of Cleveland, this park holds some of
the largest forests in the state and is home to many
wildlife species, including those that are threatened and
When deterioration in habitat quality due to energy
development and climate change negatively affects
wildlife populations, hunters, anglers, and wildlife-
watchers may generate less revenue as a result,
affecting the tourism industry as a whole. In 2011, total
expenditures on wildlife watching, hunting, and fishing
in the U.S. amounted to $54.9 billion.31
Moreover, fees
and taxes paid by hunters and anglers support non-game
conservation programs run by state wildlife agencies, so
a decline in outdoor recreation means a decrease in the
funds to maintain treasured American lands.32
Our National Parks
While climate impacts on wildlife in the United
States are varied and widespread, they are especially
noticeable on our most cherished public lands—the
national parks. We illustrate here the ways in which
climate change (which is significantly exacerbated by
methane pollution) harms wildlife in national parks in
four states—Montana, Wyoming, Ohio, and Colorado.
These threats to wildlife and ecosystems put the parks’
economic value at risk as well.
Glacier National Park
More than 10 million tourists visit Montana each year,
supporting 38,200 jobs and bringing in $3.9 billion to
the economy. Montana ranks second in the nation for
most visits due to wildlife viewing. In Glacier National
Park, 2.2 million visitors in 2013 spent nearly $179
million in surrounding communities, supporting 2,824
jobs.33
This national park is one of the most visibly
threatened by climate change, as iconic glaciers are
melting rapidly.34
According to the National Park
Service, Glacier National Park contained more than 150
glaciers in 1910 but now features only 26, and may
lose all glaciers by as early as 2020.35
As a result of
this rapidly changing environment, many species are
in jeopardy. For example, bull trout—a popular game
fish—are severely threatened by climate change in
Montana. According to researchers with the U.S.
Forest Service, the species could lose 18-92 percent
of its suitable habitat in Montana’s portion of the
Columbia River basin due to warming waters, with
some populations facing higher risks than others.36

access to essential moisture for alpine plants and
animals. In addition, warmer temperatures are allowing
more mountain pine beetles to survive the winter and
damage the park’s forests.47
Very specialized species
like the American pika, which live only on high, rocky
mountains, are particularly sensitive to small changes
in their environments. When temperatures exceed
approximately 70 degrees Fahrenheit, American pikas
can die within hours if they cannot escape the heat.48
While the precise extent of climate-related impacts in
these and other areas is unclear, the significant economic
engines of tourism and outdoor recreation would be
diminished in a warmer world brought about in part by
methane pollution. Steps taken to limit the pollution that
causes these changes will not only benefit wildlife, but
will also preserve the value of important ecosystems for
human enjoyment and economic well-being.
endangered. On average, the park has about 2.5 million
visitors annually,42
and contributes $203 million to
Ohio’s economy.43
One of the most endangered species
in the park, the Indiana bat, is expected to lose most if
not all of its summer range—a range female bats use
to rear their young—which includes the state of Ohio.
Bats in northeastern states may be more sensitive than
other mammal species to the impacts of climate change
due to their reproductive cycles, hibernation patterns,
and migration timing. Bat populations in the region
have already suffered a dramatic decline due to white-
nosed syndrome, a fungal disease. Populations were
down 72 percent in 2011, and this loss is expected to
be compounded by the effects of climate change.44
Bats
are an important component of ecosystems as they eat
large quantities of insects, including crop pests than can
damage agricultural revenue.45
Rocky Mountain National Park
In 2014, more than 3.4 million visitors to Rocky
Mountain National Park in Colorado spent $217 million
and supported 3,382 jobs, which had a cumulative
benefit to the state’s economy of $329 million.46
Spring
snow now melts 2-3 weeks earlier on average each
year, leading to less water in summer and reduced
Compounding Concerns for Wildlife: Oil and Gas Infrastructure
Oil and gas development generally involve constructing well pads, access roads, pipelines, and other related
facilities and the removal of vegetation and topsoil.49
This can cause a loss of habitat in densely developed
areas.50
Wildlife also can be harmed through spills, chronic leaks, and crude oil releases if equipment is operated
improperly. These types of impacts can affect ecosystems and can lead to species’ population declines.51
In addition, wildlife can be threatened by habitat fragmentation, which can result in concentration of wildlife in
smaller areas that lack migration corridors. This can lead to competition for food, territory, and other resources.
The fragmentation caused by road construction produces some of the most deleterious impacts on wildlife and
ecosystems.52
These challenges exacerbate stresses on species already struggling in a rapidly-changing climate.
For example, in the American West, certain iconic species are in perilous decline, as migratory animals lose ground
to energy development. In Southeast Montana, Northeast Wyoming, and along the Colorado-Wyoming border,
mule deer and pronghorn are quite vulnerable to energy development and have seen population losses in terms
of both size and productivity over the last three decades.53
In certain areas of Montana, industrial activity and its
impacts also threaten grizzly bear populations. An interagency study found that grizzly bears are five times more
likely to die in an area with roads or trails.54
Mule deer. Photo: USFWS.

to the federal Bureau of Land Management.
56
Such
revenues could have gone to states, tribes, and federal
taxpayers to support construction and repair of bridges
and roads, education, or other local projects.
57
Nationally, one study estimated that the market value of
leaked gas in the supply chain is around $1 billion.
58
As
stated by the Center for Methane Emissions Solutions,
“[when] a percentage of your production is going up
into the air, you can’t sell it.”
59
Reducing Pollution is
Cost-Effective
Fortunately, research shows that methane emissions
can be limited significantly and in a cost-effective
manner. For example, one analysis finds that the oil and
gas sector can reduce methane pollution 40 percent
below projected 2018 levels using proven technologies
at a cost of less than one cent per thousand cubic
feet of produced natural gas.
60
Some of these costs
can be recouped through the sale of captured natural
gas. When accounting for the full recoverable value of
natural gas, savings to the U.S. economy and consumers
could total over $100 million per year.
61
The CEO for Southwestern Energy Company has stated,
“… there clearly are ways to reduce methane emissions
at low cost and sometimes even positive financial
payback to companies. At Southwestern Energy, for
example, we have already demonstrated that capturing
emissions through reduced emission completions can
be accomplished for the same cost as venting the gas
into the atmosphere.”
62
Wasted Gas and
Lost Revenues
hen methane leaks or is released
intentionally, it is a waste of a valuable
energy resource. The amount of
methane emitted each year nationally represents
enough natural gas to heat 6.5 million homes.
55
Capturing wasted methane would allow this fuel to
be sold and used for home heating, power generation,
or manufacturing.
Further, when extracted on federal or tribal lands,
increased revenue from royalties paid on recovered
methane would return financial resources to local
communities and their infrastructure. Between 2009
and 2014, oil and gas producers on public and Indian
lands wasted approximately 375 billion cubic feet of
natural gas. This wasted resource amounted to $23
million in lost royalty revenues and could have powered
5.1 million households for an entire year, according
ECONOMIC CONSIDERATIONS
W
American pika. Photo: Yathin.

Fortunately, EPA can reduce the oil and gas sector’s
emissions dramatically through commonsense
requirements for existing facilities. Regular leak
detection and repair can cut up to 1.8 million metric
tons of methane pollution per year. Replacing older
equipment can cut another 1.3 million metric tons.
And, capturing natural gas could reduce up to 500,000
metric tons annually. According to one analysis, “The[se]
abatement potentials ... are conservative estimates based
on government inventories. They don’t account for the
research indicating that actual emissions could be twice
the inventory estimates, or higher.66
he President’s Climate Action Plan: Strategy
to Reduce Methane Emissions sets a goal
of reducing methane emissions from the oil
and gas sector by 40 to 45 percent from 2012 levels
by 2025.
63
The strategy includes a combination of
regulatory and voluntary approaches, aiming to
expand participation in existing industry-led programs
and to complement them with new requirements.
While some progress has been made through voluntary
programs, it is clear that they are far from sufficient
to address the problem. Strong standards mandating
pollution reductions are needed both at the federal
and state levels.
According to one report, “[d]espite the overall growth
[in emissions], nearly 90% of the emissions in 2018
come from existing sources ([i.e.,] sources existing in
2011) . . . .”
64
Another analysis estimates that without
existing source standards, 75 percent of methane
emissions from today’s oil and gas infrastructure
will remain unregulated at the federal level after
Environmental Protection Agency’s methane standards
for new and modified sources go into effect.
65
10
Voluntary and Regulatory Efforts—
Status and Limitations
T
Without existing source standards,
75 percent of methane from
today’s oil and gas infrastructure
will remain unregulated at the
federal level.
Oil and gas fields. Photo: Jan Bucholtz.

equivalent of cutting 11 million metric tons of
carbon dioxide, or taking 2.4 million passenger cars
off the road. In addition, it will reduce 210,000 tons
of VOCs and 3,900 tons of air toxics in 2025.
69
The Environmental Protection Agency’s cost-effective
approach will cut this pollution using readily
available technologies.
In February 2016, the U.S. Department of the Interior’s
Bureau of Land Management (BLM) published a
proposed rule to “update its regulations to reduce the
waste of natural gas from flaring, venting, and leaks
from oil and gas production operations on public and
Indian lands.”
70
According to the BLM, the proposed
rule would produce net benefits of about $188 million
annually.
71
It would encourage the use of currently-
available technologies to minimize flaring at oil wells;
and, it would require owners/operators to replace
outdated equipment that vents large amounts of gas.
72
When finalized, the BLM rule and EPA’s methane
regulations will serve as key parts of a comprehensive
federal methane strategy.
Regulatory Efforts
U.S. Strategy
In 2012, EPA issued regulations (called New Source
Performance Standards (NSPS)) to reduce volatile
organic compound (VOC) emissions from new and
modified oil and gas sources.
67
EPA then issued a rule
in May 2016 amending the 2012 rule to add methane
pollution limits for these sources, as well as regular
methane leak inspection and repair requirements.
This rule also expanded the scope of the 2012
requirements by requiring VOC emissions reductions
from additional oil and gas activities and equipment
not previously covered.
68
The 2016 regulation will have net positive economic
benefits for natural gas producers by reducing leaks,
thereby saving a significant amount of gas that could
then be sold. Further, EPA’s estimates indicate that
this recent rule will result in net climate benefits of
$170 million in 2025 and that it will reduce more
than 462,000 metric tons of methane in 2025—the
11
Photo: Blake Thornberry.

Other processes when methane is lost, such as liquids
unloading (when the liquids built up in gas wells are
purged), also need to be better addressed. Montana
allows some venting for liquids unloading (with certain
time and volume limits),
77, 78
and Wyoming
79
and
Colorado
80
do not regulate this loss.
While venting and flaring regulations help reduce
waste, there is more that needs to be done. None of
the above states address the waste that accrues from
maintenance activities on oil and gas infrastructure. In
addition, out of the Interior West states, North Dakota
is the only state that requires drillers to submit plans
demonstrating exactly how they plan to transfer and
use the methane they will produce.
81
Further, accurate
monitoring and record-keeping are crucial components
of successful methane emissions reduction from the
oil and gas sector. Ohio does not require methane
wasted from smaller operations to be recorded, which
leads to an underestimate in the total amount of
methane emissions.
82
State Efforts
In the past several years, a number of states have
adopted oil and gas-related regulations, even as
natural gas production has continued to grow.
73
However, they are inconsistent in scope and ambition.
Some state methane regulations require oil wells to
capture methane for sale and use. Yet, these efforts
have limitations in states where regulations have been
finalized. A Colorado rule exempts wells that are
“not sufficiently proximate to sales lines”
74
and a
Wyoming rule only “encourages”
75
the use of methane
capture at the well.
76
12
The Colorado Model
Colorado has been a national leader in facilitating
more ecologically sustainable oil and gas
development. It is the first state to address
methane pollution by regulatory action. Its rule
requires that oil and gas companies perform
routine inspections for methane leaks and meet
timelines for fixing them, and install emissions
control devices on new wells and compressors,
storage tanks, and other equipment. As a result of
Colorado’s standard, leaking oil and gas sites have
decreased by 75 percent in the state, even as oil
and gas development has increased.83
Colorado’s rule has been supported by industry,
which has seen the benefits of reduced waste.
A recent study by the Center for Methane
Emissions Solutions found that representatives
from oil and gas companies overwhelmingly
agree that the benefits of Colorado’s regulation
outweigh the costs.84
However, despite Colorado’s success, and several
other state initiatives to limit methane pollution,
more stringent federal regulations are required
both to acknowledge the transboundary nature of
greenhouse gas pollution and its impacts, and to
maximize savings across the industry.
Northern leopard frog. Photo: Courtney Celley/USFWS.

of methane emissions have been eliminated through
the use of 150 cost-effective technologies and practices,
representing revenue savings equivalent to more than
$206 million in natural gas sales.
91
The figure on page 14 illustrates some of the top
emissions reduction opportunities for each stage in
the oil and gas supply chain. In 2014, 81 percent of
methane emissions reductions came from production,
using methods such as installing vapor recovery units
and converting to electric or solar pumps. Meanwhile,
16 percent of the emissions reductions came from
transmission.
92
Some examples of transmission-
related emissions reductions include installing electric
compressors and using turbines at compressor stations.
At the distribution level, inspection and maintenance
States need to take additional steps to regulate methane
emissions at existing facilities, including implementing
regular leak detection inspection requirements and
imposing strict venting and flaring restrictions.
89
Voluntary Programs
The Natural Gas STAR Program is a voluntary, public-
private program that has existed since 1993 to promote
efficient technologies and other best practices to
help reduce methane emissions from the natural gas
sector.
90
Natural Gas STAR has more than 100 partners
that operate in all aspects of the natural gas supply
chain, including production, gathering and processing,
transmission, and distribution. Since the Natural Gas
STAR Program began, more than 1.3 trillion cubic feet
Ohio: Challenges and Opportunities
While Ohio joined Colorado and Wyoming in 2014 by requiring operators to fix emissions from leaking equipment
identified during quarterly inspections,85
the state has suffered accidents and negative public health impacts from oil
and natural gas sector development. Explosions tied to leaking pipelines have resulted in numerous fatalities across
the country and in Ohio. In 2014, there were twelve oil and gas infrastructure accidents that left one person dead,
two injured and 1,000 evacuated from homes and businesses. In fact, 500 residents were directed to leave their
homes in the middle of the night in Crooksville, Ohio in February 2016. In addition to safety concerns, oil and gas
facilities in Ohio wasted enough methane to fuel more than 8,500 homes in 2014 alone.86
In April 2016, the administration of Ohio Governor Kasich announced that the state will issue permits for new and
modified equipment at compressor stations that pressurize gas.87
The new permits will require companies to use
infrared cameras to check the facilities for leaks on a quarterly basis and quickly fix leaks they find.
The EPA final rule aimed at reducing methane emissions from new and modified oil and gas sources provides
companies with methods by which to align the final standards with state-specific requirements that may exist. In
addition to protecting public health and the health of natural habitats, the state also stands to reap economic benefits
from these strong federal rules that will level the playing field for Ohio in relation to neighboring states without
adequate safeguards, thereby preventing Ohio oil and gas companies from being put at a competitive disadvantage.
Already in Ohio, fifteen companies specialize in fixing pollution leaks, and as a result, are boosting Ohio
communities with good-paying jobs. Regulating methane pollution will also significantly help Ohioans reduce
their risk of asthma. Rates of asthma in Ohio currently are higher than the national average, with more than
275,000 children in the state suffering with asthma every day.88
Regulating methane emissions makes sense in
Ohio on all levels.

Domestic Emissions Reductions by Stage in the Oil and Gas Supply Chain
96
of surface facilities and rehabilitating leaky pipes have
helped detect and reduce emissions, and together
accounted for more than 70 percent of the reductions
in this phase of operation in 2014.
93
Building on the Natural Gas STAR Program, EPA
launched the voluntary Natural Gas STAR Methane
Challenge Program earlier in 2016 with 41 partner
companies.
94
Through this program, EPA has
challenged companies to develop and implement best
management practices within five years.
95
Companies
can reduce emissions at any point throughout their
operations or supply chain (e.g., production, gathering
and boosting, transmission, storage, and more).
In the case of the Natural Gas STAR Program, the
bulk of emissions reductions come from production,
which is where most emissions occur in the supply
chain. In contrast, Methane Challenge Program
participants to-date are reducing methane emissions
primarily from the distribution phase, though this
segment comprises a relatively small portion of the
emissions that occur across the oil and gas supply
chain. Data are not yet available to measure the
extent of this program’s effectiveness. Nevertheless,
regulations still are needed to capture a greater
percentage of emissions. EPA has noted that such
voluntary efforts are, indeed, complementary to
regulatory requirements.

In summary, we recommend the following policies
to curb methane pollution from the oil and gas sector:
• Propose, finalize, and implement strong EPA rules
limiting methane pollution from existing sources in the
oil and gas industry.
• Successfully implement recent EPA rules limiting
methane pollution from new and modified oil and
gas sources.
• Finalize a proposed rule by the Bureau of Land
Management that would substantially curtail methane
waste from both existing and new sources of gas and oil
production on public and tribal lands.
• Continue to advance state efforts to reduce methane
pollution from oil and gas operations, such as the
strong standard in place in Colorado.
• Continue to support voluntary efforts that produce
significant results.
ildlife, their habitat, and local
economies reliant on tourism and
outdoor recreation have a vested
interest in reducing climate-changing methane
pollution. Current voluntary measures to reduce
methane pollution remain insufficient, given the
significant amount of oil and gas sector emissions
left unaddressed. Furthermore, methane pollution
is expected to increase without more action. In fact,
without additional regulation, EPA projects that
methane emissions from the oil and gas industry will
increase by 25 percent in the next 10 years.
97
The National Wildlife Federation therefore underscores
the urgent need for EPA to regulate existing sources in
the oil and gas industry to effectively reduce methane
emissions from this sector. NWF commends the EPA for
finalizing standards to curb methane emissions from
new and modified sources in the industry, and strongly
recommends that the agency propose and finalize a
rule as quickly as possible to regulate emissions from
existing facilities—i.e., those sources responsible for
the bulk of projected emissions.
CONCLUSION AND POLICY
RECOMMENDATIONS
W
Juvenile bull trout. Photo: USFWS.

1 Climate Central 2014. Determining Methane Leaks is Key to Climate Goals.
http://www.climatecentral.org/news/climate-goals-priority-is-methane-leaks-17854
2 U.S. EPA 2014. Overview of Greenhouse Gases: Methane Emissions.
https://www3.epa.gov/climatechange/ghgemissions/gases/ch4.html.
Emissions estimates are from the Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2014.
3 Ibid.
4 U.S. EPA 2014. Overview of Greenhouse Gases. https://www.epa.gov/ghgemissions/overview-greenhouse-gases. Emissions
estimates are from: Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2014.
5 U.S. Geological Survey (USGS) 2002. Natural Gas Production in the United States.
https://pubs.usgs.gov/fs/fs-0113-01/fs-0113-01.pdf
6 Clean Air Task Force 2014. Waste Not: Common Sense ways to Reduce Methane Pollution from the Oil and Gas Industry.
http://www.catf.us/resources/publications/files/WasteNot.pdf.
7 The Economist 2016. Methane leaks: A dirty little secret. http://www.economist.com/news/business/21702493-natural-gass-
reputation-cleaner-fuel-coal-and-oil-risks-being-sullied-methane.
8 U.S. EPA 2014. Methane Emissions.
9 U.S. EPA 2015. Fact Sheet, EPA’s Strategy for Reducing Methane and Ozone-Forming Pollution from the Oil and Natural Gas Industry.
http://www3.epa.gov/airquality/oilandgas/pdfs/20150114fs.pdf
10 Egan, M. 2016. Oil Milestone: Fracking fuels half of U.S. output. CNN Money.
http://money.cnn.com/2016/03/24/investing/fracking-shale-oil-boom/
11 Brown, S.P.A., and M.K. Yucel. 2013. The Shale Gas and Tight Oil Boom: U.S. States’ Economic Gains and Vulnerabilities. Council on
Foreign Relations. http://www.cfr.org/united-states/shale-gas-tight-oil-boom-us-states-economic-gains-vulnerabilities/p31568
12 U.S. EPA 2014. Table 3-1, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2014, Ch. 3: Energy.
https://www.epa.gov/sites/production/files/2016-04/documents/us-ghg-inventory-2016-chapter-3-energy.pdf.
13 API Energy 2013. Energy Infrastructure. http://www.energyinfrastructure.org/energy-101/jobs?gclid=CjwKEAjwiYG9BRCkgK-G4
5S323oSJABnykKAgdZt5DjZe8km3KmFNcT9xq7u7HXbpR7LpEAIUspNdhoCd9Tw_wcB.
14 Clean Air Task Force 2014.
15 U.S. Government Accountability Office 2016. Oil and Gas, Interior Could Do More to Account for and Manage Natural Gas Emissions,
page 6. http://democrats-naturalresources.house.gov/imo/media/doc/Interior%20Could%20Do%20More%20to%20Account%20
for%20and%20Manage%20Natural%20Gas%20Emissions.pdf.
16 U.S. Energy Information Administration (EIA) 2016. Natural Gas Explained, Natural Gas and the Environment.
http://www.eia.gov/energyexplained/?page=natural_gas_environment.
17 U.S. EPA 2014. Methane Emissions.
18 The percentages provided in this figure are based on EPA’s 2014 Greenhouse Gas Inventory, which consists of data through 2012,
and combine oil and gas data. Source: Clean Air Task Force 2014.
19 Clean Air Task Force 2014, p. 15.
20 NASA 2014. U.S. Methane ‘Hot Spot’ Bigger than Expected.
http://science.nasa.gov/science-news/science-at-nasa/2014/09oct_methanehotspot/
21 Alvarez, R. 2016. What the New NASA ‘Hot Spot’ Study Tells Us About Methane Leaks. Environmental Defense Fund.
http://blogs.edf.org/energyexchange/2016/08/15/what-the-new-nasa-hot-spot-study-tells-us-about-methane-leaks/
22 Office of Indian Energy and Economic Development 2002. Oil and Gas Production Phase Impacts.
http://teeic.indianaffairs.gov/er/oilgas/impact/prod/index.htm.
23 Intergovernmental Panel on Climate Change (IPCC) 2013. Summary for Policymakers. In: Climate Change 2013: The Physical
Science Basis. http://www.ipcc.ch/report/ar5/wg1/
24 Ramirez, P., and S.B. Mosley 2015. Oil and Gas Wells and Pipelines on U.S. Wildlife Refuges: Challenges for Managers. USFWS. PLOS
One 2015: 10(4). http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4410920/
25 Ceballos, G., et al. 2015. Accelerated modern human-induced species losses: Entering the sixth mass extinction. Science Advances
(1):5. http://advances.sciencemag.org/content/1/5/e1400253.full
ENDNOTES

26 Urban, M.C. 2015. Accelerating extinction risk from climate change. Science (348):6234.
http://science.sciencemag.org/content/348/6234/571.full
27 National Wildlife Federation (NWF) 2013. Nowhere to Run: Big Game Wildlife in a Warming World.
http://www.nwf.org/~/media/PDFs/Global-Warming/Reports/NowheretoRun-BigGameWildlife- LowResFinal_110613.ashx.
28 Eby, L., et al. 2014. Evidence of Climate Induced Range Contractions in Bull Trout Salvelinus confluentus in a Rocky Mountain
Watershed, U.S.A. PLOS One 9(6). http://www.fs.fed.us/rm/pubs_other/rmrs_2014_eby_l001.pdf.
29 Brown, M. 2016. More tests for Yellowstone, tributaries after fish kill. ABC News.
http://abcnews.go.com/US/wireStory/tests-set-yellowstone-tributaries-fish-kill-41579828. See also: Robbins, J. 2016. Tiny Invader,
Deadly to Fish, Shuts Down a River in Montana. New York Times 2016.
http://www.nytimes.com/2016/08/24/us/tiny-parasite-invader-deadly-to-fish-shuts-down-yellowstone-river-in-montana.html?_r=0
30 Ramirez and Mosley 2015.
31 U.S. Fish and Wildlife Service (USFWS) 2012. 2011 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation.
http://www.census.gov/prod/2012pubs/fhw11-nat.pdf
32 NWF 2015. Losing Ground: Wildlife and Energy Development in the Powder River Basin.
http://www.nwf.org/News-and-Magazines/Media-Center/Reports/Archive/2015/11-17-2015-Losing-Ground.aspx
33 National Park Service (NPS) 2014. Glacier Creates 179 Million in Economic Benefit.
https://www.nps.gov/glac/learn/news/glacier-creates-179-million-in-economic-benefit.htm
34 Wines, M. 2014. Climate Change Threatens to Strip the Identity of Glacier National Park. New York Times.
http://www.nytimes.com/2014/11/23/us/climate-change-threatens-to-strip-the-identity-of-glacier-national-park.html?_r=0
35 NPS. Ice Patch Archeology and Paleoecology at Glacier National Park. https://www.nps.gov/articles/glacicepatch.htm
36 Reiman, B. F. 2007. Anticipated Climate Warming Effects on Bull Trout Habitats and Populations Across the Interior Columbia
River Basin. Transactions of the American Fisheries Society 136:1552–1565.
http://www.fs.fed.us/rm/boise/publications/fisheries/rmrs_2007_riemanb001.pdf
37 NWF 2015. Losing Ground, page 11.
38 Thuermer, A. M. 2015. Report: Climate change likely to kill Yellowstone forests. WyoFile.
http://www.wyofile.com/report-climate-change-likely-to-kill-yellowstone-forests/
39 Ibid.
40 Ray, A., A. Sepulveda, B. Hossack, D. Patla, and K. Legg. 2014. Using monitoring data to map amphibian breeding hotspots and
describe wetland vulnerability in Yellowstone and Grand Teton National Parks. Park Science 31(1).
http://nature.nps.gov/ParkScience/Archive/PDF/Article_PDFs/ParkScience31(1)SpecialIssue2014_112-117,119_Ray_et_al_3810.pdf
41 NPS Intermountain Region Inventory & Monitoring Program. August 2013. Greater Yellowstone Network Resource Brief:
Amphibian and Wetland Monitoring. https://irma.nps.gov/DataStore/DownloadFile/480685
42 NPS 2013. Cuyahoga Valley National Park Climate Action Plan.
https://www.nps.gov/cuva/learn/management/upload/CVNP-Climate-Action-Plan.pdf
43 Bhatia, K. 2016. Cuyahoga Valley National Park Survey Shows $203 Million Economic Impact. WKSU.
http://wksu.org/post/cuyahoga-valley-national-park-survey-shows-203-million-economic-impact#stream/0
44 USFWS 2013. Climate Change Projected to Alter Indiana Bat Maternity Range. http://www.srs.fs.usda.gov/news/537
45 Indiana Department of Natural Resources. July 28, 2016. Indiana Bats. http://www.in.gov/dnr/fishwild/3371.htm
46 NPS 2015. Rocky Mountain National Park Will Increase Entrance and Camping Fees Beginning in October.
https://www.nps.gov/romo/learn/news/pr_park_entrance_and_camping_fees_beginning_october_1.htm
47 NPS. Rocky Mountain National Park: Climate Change. https://www.nps.gov/romo/learn/nature/climatechange.htm
48 NPS. Rocky Mountain National Park: Pika. https://www.nps.gov/romo/learn/nature/pikas.htm
49 Office of Indian Energy and Economic Development 2002. Oil and Gas Production Phase Impacts.
http://teeic.indianaffairs.gov/er/oilgas/impact/prod/index.htm.
50 NWF 2015. Losing Ground, pages 8-9.
52 Rowland M. M., M. J. Wisdom, B. K. Johnson, and M. A. Penninger. 2005. Effects of Roads on Elk: Implications for Management in
Forested Ecosystems. http://www.fs.fed.us/pnw/lagrande/starkey_na/PDFs_Preprints/ms-04_Rowland.pdf
54 Geid, E. 2003. Oil, gas, and the grizzly. Earth island Journal.
http://www.earthisland.org/journal/index.php/eij/article/oil_gas_and_the_grizzly/
55 Clean Air Task Force 2014.

56 Bureau of Land Management (BLM) 2016. Fact Sheet on Methane and Waste Reduction Rule. http://www.blm.gov/style/medialib/
blm/wo/Communications_Directorate/public_affairs/news_release_attachments.Par.74451.File.dat/VF_Fact_Sheet.pdf
57 Wheeler, A. 2016. The Future of Methane in Colorado. Conservation Colorado.
http://conservationco.org/2016/07/future-methane-colorado/
58 Hausman, C. and L. Muehlenbachs 2016. Price Regulation and Environmental Externalities, Evidence from Methane Leaks.
Resources for the Future. http://www.rff.org/files/document/file/RFF-DP-16-23.pdf
59 Truchot, J. 2016. Jonah energy cuts costs by stopping methane leaks. Wyoming Business Report.
http://wyomingbusinessreport.com/jonah-energy-cuts-costs-by-stopping-methane-leaks/
60 Environmental Defense Fund (EDF) 2014. Cost-effective methane emissions reductions from U.S. oil and gas.
https://www.edf.org/media/cost-effective-methane-emissions-reductions-us-oil-and-gas
61 EDF 2014. ICF Methane Cost Curve Report. https://www.edf.org/energy/icf-methane-cost-curve-report.
62 EDF 2014. Cost-effective methane emissions.
63 U.S. EPA 2016. EPA’s Actions to Reduce Methane Emissions from the Oil and Natural Gas Industry: Final Rules and Draft Information
Collection Request. https://www3.epa.gov/airquality/oilandgas/may2016/nsps-overview-fs.pdf
64 ICF International 2014. Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas
Industries, pages 3-4. https://www.edf.org/sites/default/files/methane_cost_curve_report.pdf
65 Cassady, A. 2016. The Who’s Who of Methane Pollution in the Onshore Oil and Gas Production Sector. Center for American
Progress. https://cdn.americanprogress.org/wp-content/uploads/2016/06/20070044/MethanePollution-report.pdf.
66 Clean Air Task Force 2014, p. 3.
67 U.S. EPA 2016. EPA’s Actions to Reduce Methane Emissions.
68 Ibid.
69 Ibid.
70 BLM 2016. Fact Sheet on Methane and Waste Reduction Rule.
71 Alexander, R. 2016. BLM proposed royalty rule on wasted natural gas would benefit taxpayers. The Hill.
http://thehill.com/blogs/congress-blog/energy-environment/288160-blm-proposed-royalty-rule-on-wasted-natural-gas-would.
72 BLM 2016. Proposed Methane and Waste Prevention Rule.
http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/methane_and_waste.html
73 Pirog, R. and M. Ratner 2012. Natural Gas in the U.S. Economy: Opportunities for Growth. Congressional Research Service, R42814.
https://www.fas.org/sgp/crs/misc/R42814.pdf
74 Colorado Department of Natural Resources Oil and Gas Conservation Commission, 2 CCR 404-1: 805(b)(3)(A).
https://www.sos.state.co.us/CCR/GenerateRulePdf.do?ruleVersionId=6658&fileName=2CCR404-1
75 Wyoming Oil and Gas Conservation Commission, Operational Rules Drilling Rules, Chapter 3, Section 39 (a).
http://soswy.state.wy.us/Rules/RULES/10099.pdf
76 Western Environmental Law Center, Western Organization of Resource Councils 2016.
77 Montana Department of Oil and Gas, Conservation Rule 36.22.1219.
http://www.mtrules.org/gateway/ShowRuleFile.asp?RID=12051
78 Montana Department of Oil and Gas, Conservation Rule 36.22.1221.
http://www.mtrules.org/gateway/ShowRuleFile.asp?RID=1205 3
79 Wyoming Oil and Gas Conservation Commission, Chapter 3, Section 39 (b)(ii). http://soswy.state.wy.us/Rules/RULES/10099.pdf
80 Colorado Department of Natural Resources Oil and Gas Conservation Commission, 2 CCR 404-1: 912(b).
https://www.sos.state.co.us/CCR/GenerateRulePdf.do?ruleVersionId=6658&fileName=2CCR404-1
81 Western Environmental Law Center, Western Organization of Resource Councils 2016.
82 EDF. Reducing Ohio’s Methane Pollution Problem.
https://www.edf.org/sites/default/files/content/methane_fact_sheet_ohio_final_for_1115.pdf
83 Wheeler, A. 2016.
84 Graham, E. 2016. Study: Energy industry supports methane rules in Colorado. The Durango Herald.
http://www.durangoherald.com/article/20160415/NEWS01/160419787/
85 Williams, A. 2016. Ohio Gov. Kasich Moves to Reduce Environmental Impact of Natural Gas Industry. EDF.
https://protect-us.mimecast.com/s/8JQZBds97b5FV?domain=blogs.edf.org
86 EDF. Ohio’s Methane Pollution Problem: Reducing oil and gas methane emissions benefits Ohio communities.
https://www.edf.org/sites/default/files/content/methane_fact_sheet_ohio_final_for_1115.pdf

87 Ohio Environmental Protection Agency. April 7, 2016. Ohio EPA Requests Comments on Drafts of General Permits for Compressor
Stations. https://protect-us.mimecast.com/s/Md6XB0TKGAXCl?domain=epa.ohio.gov
88 American Lung Association. 2016. Report Card: Ohio. In State of the Air 2016.
http://www.lung.org/our-initiatives/healthy-air/sota/city-rankings/states/ohio/
89 EDF. Wyoming State Fact Sheet. https://www.edf.org/sites/default/files/content/methane_fact_sheet_wyomingfinal.pdf
90 For those who are familiar with the Energy STAR label that can be found on many computers, refrigerators, dishwashers, and other
household and business products, the Natural Gas STAR program is modeled after the Energy STAR public-private program that also
has existed since the 1990s. The Energy STAR label is awarded to products that meet a level of energy efficiency that far exceeds the
minimum industry standards or thresholds to provide public recognition in this regard. It indicates a “best-in-class” product in terms
of energy efficiency and was designed to encourage and incent companies to strive to achieve greater efficiency levels. Similarly,
Natural Gas STAR was created to encourage gas companies to adopt efficient technologies as well as to reduce emissions voluntarily in
a cost-effective manner, and to receive recognition for doing so through this Program. See: U.S. EPA 2013. Natural Gas STAR Program.
https://www.epa.gov/natural-gas-star-program/natural-gas-star-program#introduction
91 Ibid.
92 Ibid.
93 Ibid.
94 U.S. EPA. Natural Gas STAR Methane Challenge Program. https://www3.epa.gov/gasstar/methanechallenge/
95 Ibid.
96 Ibid.
97 U.S. EPA 2015. Fact Sheet, EPA’S Strategy for Reducing Methane.

23Oil and Gas Methane Pollution: An Invisible Threat to Wildlife and Economic Opportunity for Communities
Pronghorn. Photo: USFWS.

24 Oil and Gas Methane Pollution: An Invisible Threat to Wildlife and Economic Opportunity for Communities
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Oil and Gas Methane Pollution Report

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