On December 3, 2015,
the American Council for Capital Formation (ACCF) released a report
entitled “Technical Comments on the Social Cost of Methane as Used in the
Regulatory Impact Analysis for the Proposed Emissions Standards for new and
Modified Sources in the Oil and Natural Gas Sector.” The report analyzed the
climate benefits of EPA’s proposed actions to reduce methane emissions.
In August 2015, EPA published
a series of proposed regulatory actions to reduce methane and volatile organic
compound (VOC) emissions from the oil and natural industry, which are part of the
U.S. efforts to halt climate change. Those proposed regulatory actions would
amend the 2012 New Source Performance Standards (NSPS) for the Oil and Natural
Gas Industry by setting new standards for methane and VOC emissions from new
and modified oil and gas sources.
Along with the proposed
actions, EPA issued a Regulatory
Impact Analysis (RIA) providing estimations of the
potential impacts of the rulemaking. The RIA’s results estimate monetized
climate benefits around $460 million to $550 million in 2025 using the social cost
of methane method (SC-CH4).
According to the ACCF report,
“EPA’s estimates of the benefits are: 1) highly uncertain and very likely
overstated; and 2) lack the appropriate peer review that is necessary for use
in supporting regulatory policy.” The center contended that EPA did not
properly estimate the climate benefits and that “the SC-CH4 estimates could be
90% to 94% lower than the EPA’s SC-CH4” based on ACCF’s own calculations. ACCF
also argued that the absence of peer review seriously challenge the
“reliability” of the RIA’s climate benefits estimate. Therefore, the report
concluded that “EPA’s SC-CH4 estimates are too premature and are inappropriate
for use in making major national policy decisions.”
Written by Chloe Marie - Research Fellow
12/10/2015
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