Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review

A coalition of environmental justice organizations argues that the EPA's proposed regulations for the oil and gas sector must be strengthened to protect Black, Latine, tribal, and low-income communities. The commenters detail how these groups suffer disproportionate health risks from air and water pollution, economic burdens from orphaned wells and property devaluation, and heightened climate vulnerability. They recommend specific policy enhancements, including stricter leak detection and repair (LDAR) requirements, the elimination of routine flaring, and more robust community monitoring and well-closure mandates.

• Oil and gas infrastructure disproportionately impacts marginalized populations; of the nearly 18 million people in the U.S. living within one mile of an active well, 3.3 million are Latine, 3 million live below the poverty line, 1.8 million are Black, and 500,000 are Native American.
• Flaring practices create severe respiratory health risks, particularly for communities of color. In North Dakota, a 1 percent increase in flared natural gas is linked to a 0.73 percent increase in respiratory-related hospitalizations, with the Fort Berthold Reservation experiencing nearly 20% of all state flaring from 2012 to 2020.
• The presence of unplugged orphaned wells causes significant economic harm to local property values. In southwest Pennsylvania, properties near unplugged wells have a market value approximately 12% lower than those near plugged wells.
• Oil and gas development is linked to increased violence and sex trafficking of Indigenous women, specifically in 'hotspots' where hydraulic fracking facilities are present, such as on the Fort Berthold Reservation.
• Marginalized communities face higher climate vulnerability; for example, with 2°C of warming, Black populations are 41% more likely, and low-income populations are 11% more likely, to live in areas with the highest projected increases in extreme-temperature related deaths.
• The commenters recommend that the EPA strengthen the Supplemental Proposal by replacing broad technical infeasibility exceptions for flaring with narrow exemptions, requiring bimonthly optical gas imaging (OGI) at compressor stations, and shortening the timeline for states and tribes to submit Implementation Plans from 18 to 15 months.

APA

Earthjustice (2023). Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review. https://earthjustice.org/wp-content/uploads/joint_environmental_justice_comments-epa_oil_and_gas_climate_rev.pdf

Chicago

Earthjustice. Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review. 2023. https://earthjustice.org/wp-content/uploads/joint_environmental_justice_comments-epa_oil_and_gas_climate_rev.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review |date=13 February 2023 |url=https://earthjustice.org/wp-content/uploads/joint_environmental_justice_comments-epa_oil_and_gas_climate_rev.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2023standards, author = {{Earthjustice}}, title = {{Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review}}, publisher = {Earthjustice}, year = {2023}, month = feb, url = {https://earthjustice.org/wp-content/uploads/joint_environmental_justice_comments-epa_oil_and_gas_climate_rev.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }