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The document argues that the Renewable Fuel Standard (RFS) has failed to meet its goals of producing clean renewable fuels and protecting consumers, instead primarily incentivizing corn ethanol. It highlights negative impacts including increased greenhouse gas emissions from land conversion, water pollution in the Mississippi River Basin and Gulf of Mexico, and increased food prices and land displacement in developing countries and the United States.

The Clean Air Task Force asserts that as the U.S. assumes the chairmanship of the Arctic Council, it must lead by example in reducing short-lived climate pollutants. While the Council adopted the Framework on Black Carbon and Methane Emissions, the author argues that U.S. domestic regulations for Arctic offshore oil and gas, managed by the Bureau of Ocean Energy Management (BOEM), are severely outdated. The document calls for BOEM to align its rules with EPA standards, eliminate 'emission exemption levels', include support vessel emissions, and ban the routine venting and flaring of natural gas in the Arctic.

The document evaluates technical and commercial viability for several associated gas utilization technologies in US tight oil fields. It identifies gas gathering, CNG trucking, NGL recovery, gas-to-power, and Mini-GTL MT as technologies that pass initial screening, while gas reinjection, Mini-LNG, Mini-GTL FT, and ammonia production are rejected due to scale, maturity, or economic constraints. The report provides detailed technical specifications, cost models, and case studies for these options, specifically focusing on the Bakken region of North Dakota.

The Clean Air Task Force (CATF) asserts that the Renewable Fuels Standard (RFS) has failed its primary goal of reducing greenhouse gas emissions, instead promoting corn ethanol production that increases emissions and raises food prices. The document highlights that corn ethanol produced between 2010 and 2015 failed to meet the 20% GHG reduction mandate and that the RFS has failed to stimulate the production of advanced cellulosic biofuels.

The document argues that most global decarbonization scenarios require energy intensity improvements that far exceed historical rates, while noting that policy makers have limited influence over the mechanisms driving these trends.

The Clean Air Task Force (CATF) supports the readoption of California's Low Carbon Fuel Standard (LCFS) through 2020 but argues against reducing the indirect land use change (ILUC) emissions score for corn ethanol. CATF contends that current modeling, specifically the CA GTAP-BIO model, underestimates emissions by ignoring water scarcity, failing to differentiate between commercial and non-commercial forests, and using flawed yield price elasticity assumptions. The document also highlights the negative impact of corn ethanol on global food security and proposes liquid ammonia as a scalable, low-carbon fuel alternative for the post-2020 period.

The Clean Air Task Force supports the re-adoption of California's Low Carbon Fuel Standard (LCFS) through 2020 but opposes reducing the carbon intensity value for corn ethanol. The organization argues that the current modeling used to justify a lower indirect land use change (ILUC) score is based on subjective decisions, specifically the assumption that biofuel expansion leads to a reduction in food consumption that provides a climate benefit. CATF contends that if food consumption declines were limited, corn ethanol's ILUC emissions would increase substantially, and that relying on corn ethanol would hinder the development of more effective compliance options.

The authors contend that the Clean Power Plan's design and current industry trends allow for significant power sector emission cuts while maintaining reliability. They highlight that existing natural gas and transmission infrastructure, combined with the flexibility of the rule, are sufficient to manage the transition. To further mitigate potential reliability risks, the document advocates for the EPA to establish a mechanism for interstate allowance trading between states in different regions, which would allow states facing local constraints to purchase allowances from those with surplus capacity.

The report identifies the U.S. oil and gas industry as the largest industrial source of methane and argues that the EPA should issue nationwide standards under the Clean Air Act to target the sector's top emitting sources. The authors propose three primary categories of intervention: regular leak detection and repair (LDAR) programs, the replacement of outdated compressors and pneumatic equipment, and the capture of gas from oil and gas wells. These measures are estimated to reduce annual methane emissions by 3.2 to 3.7 million metric tons, a reduction of 42% to 48% of the sector's total. The report emphasizes that direct methane standards would be significantly more effective than regulating volatile organic compounds (VOCs) or relying on voluntary programs. The estimated cost of these measures is low, ranging from $8 to $18 per metric ton of carbon dioxide equivalent, and would represent less than 1% of the industry's sales revenue.

Dr. Ashley Finan of the Clean Air Task Force testifies that while nuclear power is essential for addressing climate change, the US needs a new commercialization model for advanced reactors. She proposes a DOE-supervised test bed facility to reduce costs and risks for private prototypes and a staged licensing process at the NRC, similar to FDA drug trials, to provide clearer signals to investors.

The document highlights the link between oil and gas emissions and ground-level ozone, asserting that methane regulations provide significant co-benefits by reducing VOCs more effectively than direct VOC regulations or previous EPA programs. It notes a high overlap between oil and gas production areas and regions exceeding proposed ozone standards, particularly west of the Mississippi River.

The author defends the EPA's use of the Clean Air Act to mandate deep carbon pollution reductions in the power industry, rejecting claims by certain members of Congress that federal subsidies for clean coal projects prohibit those technologies from being used to set performance standards. The author asserts that the EPA relies on a global array of projects to demonstrate that carbon capture and sequestration is a viable 'best system of emissions control'.

The document details the technical basis for calculating methane emissions and abatement costs across the U.S. oil and gas value chain, focusing on leaks, pneumatic devices, compressor seals, oil wells, and liquids unloading.

The author refutes the argument that the EPA cannot regulate greenhouse gases from existing power plants because those plants are already required to control air toxics. The author asserts that section 111(d) of the Clean Air Act specifically allows for the regulation of "gap" pollutants—those that are neither National Ambient Air Quality Standards (NAAQS) nor Hazardous Air Pollutants (HAPS)—and that the Senate's version of the 1990 amendments, which is the controlling law, confirms this authority.

The report advocates for the EPA to establish direct methane standards for the oil and gas industry, which it identifies as the largest industrial source of methane in the U.S. It proposes three primary control measures: regular leak detection and repair (LDAR) programs, upgrading older compressors and pneumatic equipment, and capturing gas from wells. The authors argue these measures are low-cost, commercially available, and would reduce methane emissions by 3.2 to 3.7 million metric tons per year, while also significantly lowering volatile organic compounds (VOCs) and toxic air pollutants.

The Clean Air Task Force asserts that the U.S. must regulate domestic methane and black carbon emissions from oil and gas activities to lead the Arctic Council effectively. It calls for the EPA to cut methane emissions by 50% in five years, for the BLM to implement a 'waste' rule prohibiting unnecessary flaring on Federal lands, and for BOEM to overhaul outdated air regulations in the Alaskan Arctic.

The document examines Gevo's GIFT platform, which converts corn sugars into isobutanol for use as a fuel additive or chemical feedstock. It highlights that achieving 'advanced biofuel' certification from the US EPA is critical for the technology's commercial success, as the product would otherwise be only marginally better than ethanol in terms of carbon impact. The report notes significant financial instability at Gevo, including a risk of insolvency and potential delisting from the NASDAQ. Economically, retrofitting an ethanol refinery with GIFT and a combined heat and power (CHP) system would increase capital requirements by approximately 60%. Additional risks include past process contamination at a Minnesota plant, ongoing patent litigation with Butamax, and the emergence of potentially cheaper ethanol-to-butanol conversion technologies.

The Clean Air Task Force asserts that while efforts have been made to reduce methane from oil and gas production, local gas distribution systems—particularly aboveground equipment like city gates and metering stations—have been neglected. Citing EPA data, the author notes that emissions from these large stations are larger than those from outdated underground pipes and can be fixed cheaply. The document emphasizes that reducing methane is critical for slowing the rate of warming in the coming decades, complementing the primary priority of reducing CO2 from power plants.

The document analyzes natural gas flaring in the Bakken formation of North Dakota, noting that in 2013, 32% of all produced gas was flared. It disputes the claim that slow federal permitting for pipelines is the primary driver of flaring, providing data that 72% of 2013 flaring occurred on private or state-owned land and 57% of statewide flaring came from wells already connected to gathering pipelines. The author argues that flaring is instead caused by insufficient infrastructure capacity, lack of front-end planning, and investment gaps, and opposes HR 4293, which would allow the Secretary of Interior to bypass the National Environmental Policy Act (NEPA) process for pipeline and compressor station permits on federal lands.

The Clean Air Task Force supports the EPA's proposed rule for existing fossil power plants, stating that the emissions reductions can be achieved at minimal cost primarily by shifting generation from high-emitting coal plants to underutilized natural gas plants. The organization notes that these regulations, alongside other EPA standards, will benefit public health by reducing premature deaths and asthma attacks.