Comments on this important Clean Air Act rulemaking to revise EPA’s New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the oil and gas industry

A coalition of environmental organizations argues that the EPA's proposed rules for the oil and gas industry are insufficient. They demand the direct regulation of methane, the inclusion of existing sources, the elimination of exemptions for certain wells, and the regulation of hydrogen sulfide and particulate matter. The coalition also calls for more stringent toxic air pollutant limits and a more comprehensive health risk assessment for vulnerable populations.

• The EPA's proposed rules fail to directly regulate methane, despite the oil and gas industry being the "single largest contributor to United States anthropogenic methane emissions," accounting for over 40% of total domestic methane emissions.
• The proposed New Source Performance Standards do not mandate controls for existing sources, such as compressors and pneumatic devices, which the coalition argues will allow "outdated devices" to continue polluting.
• The coalition identifies several problematic exemptions in the proposed rules, including a blanket exemption for "wildcat" and "delineation" wells, as well as the exclusion of oil wells that may produce substantial natural gas.
• The EPA has neglected to regulate hydrogen sulfide, a highly toxic gas found in 14 major areas across 20 states, and particulate matter (PM10 and PM2.5) generated during all phases of drilling projects.
• Regarding the National Emission Standards for Hazardous Air Pollutants, the coalition argues that the EPA's risk review ignores critical pollutants such as the carcinogen 1,3 butadiene and the neurotoxin mercury.
• The coalition contends that the EPA's "ample margin of safety" analysis for public health is deficient because it focuses "almost exclusively on cost considerations" and fails to adequately account for the vulnerability of children and overburdened communities.
• The document highlights severe ozone pollution in specific regions linked to oil and gas development, noting that in Wyoming’s Upper Green River Basin, ozone levels exceeded those of Los Angeles on some days.

APA

Earthjustice (2011). Comments on this important Clean Air Act rulemaking to revise EPA’s New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the oil and gas industry. https://earthjustice.org/wp-content/uploads/nspsshortcomments.pdf

Chicago

Earthjustice. Comments on this important Clean Air Act rulemaking to revise EPA’s New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the oil and gas industry. 2011. https://earthjustice.org/wp-content/uploads/nspsshortcomments.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Comments on this important Clean Air Act rulemaking to revise EPA’s New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the oil and gas industry |date=30 November 2011 |url=https://earthjustice.org/wp-content/uploads/nspsshortcomments.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2011comments, author = {{Earthjustice}}, title = {{Comments on this important Clean Air Act rulemaking to revise EPA’s New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the oil and gas industry}}, publisher = {Earthjustice}, year = {2011}, month = nov, url = {https://earthjustice.org/wp-content/uploads/nspsshortcomments.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }