Remarks of Lucas Minich for the Clean Air Task Force on Oil and Natural Gas Sector; Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, 82 Fed. Reg. 27,645 (June 16, 2017)

The Clean Air Task Force opposes the EPA's proposed stays on emission standards for new, reconstructed, and modified oil and gas sources, asserting that the agency lacks the legal authority under the Clean Air Act and the Administrative Procedure Act to postpone compliance dates for an already-effective rule. The organization highlights that staying leak detection and repair requirements would eliminate over half of the rule's methane reductions and nearly 90 percent of its toxic air emissions benefits, disproportionately impacting the health of children and vulnerable populations living near facilities.

• The EPA lacks the legal authority to implement the proposed stays under the Clean Air Act or the Administrative Procedure Act. The D.C. Circuit ruled that a 90-day stay is only permissible if an objection of "central relevance" was "impracticable" to raise during public comment, which was not the case here. Furthermore, Administrative Procedure Act section 705 cannot be used to postpone a rule that has already passed its effective date, which for this rule was June 2016.
• The proposed stays would significantly undermine the environmental and health benefits of the emission standards, particularly regarding leak detection and repair. These specific provisions are estimated to provide more than 50 percent of the methane reductions and almost 90 percent of the benefits related to toxic air emissions.
• The suspension of these requirements poses a disproportionate health risk to children and vulnerable individuals residing near new or modified oil and gas facilities due to increased emissions of climate pollution, air toxics, and smog precursors.

APA

Minich, L. (2017). Remarks of Lucas Minich for the Clean Air Task Force on Oil and Natural Gas Sector; Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, 82 Fed. Reg. 27,645 (June 16, 2017). Clean Air Task Force. https://cdn.catf.us/wp-content/uploads/2017/07/21094346/CATF_Testimony_LucasMinich.pdf

Chicago

Minich, Lucas. Remarks of Lucas Minich for the Clean Air Task Force on Oil and Natural Gas Sector; Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, 82 Fed. Reg. 27,645 (June 16, 2017). Clean Air Task Force, 2017. https://cdn.catf.us/wp-content/uploads/2017/07/21094346/CATF_Testimony_LucasMinich.pdf.

Wikipedia

{{cite press release |last1=Minich |first1=Lucas |title=Remarks of Lucas Minich for the Clean Air Task Force on Oil and Natural Gas Sector; Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, 82 Fed. Reg. 27,645 (June 16, 2017) |publisher=Clean Air Task Force |date=10 July 2017 |url=https://cdn.catf.us/wp-content/uploads/2017/07/21094346/CATF_Testimony_LucasMinich.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{minich2017remarks, author = {Minich, Lucas}, title = {{Remarks of Lucas Minich for the Clean Air Task Force on Oil and Natural Gas Sector; Emission Standards for New, Reconstructed, and Modified Sources: Stay of Certain Requirements, 82 Fed. Reg. 27,645 (June 16, 2017)}}, publisher = {Clean Air Task Force}, year = {2017}, month = jul, url = {https://cdn.catf.us/wp-content/uploads/2017/07/21094346/CATF_Testimony_LucasMinich.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }