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The report finds that 238 US counties in 21 states face cancer risks exceeding the EPA's 1-in-a-million threshold due to oil and gas emissions, affecting over 9 million people. Key pollutants identified include benzene, formaldehyde, and ethylbenzene, with the highest risks concentrated in states with significant infrastructure like Texas, Louisiana, Oklahoma, North Dakota, Pennsylvania, and Colorado. The analysis highlights that NATA likely underestimates total health impacts by excluding particulate matter, ozone, and water contamination. To mitigate these risks, the report recommends implementing leak detection and repair (LDAR) programs, replacing high-emitting pneumatic equipment, and installing vapor recovery units on storage tanks.

The Clean Air Task Force evaluates the EPA's first-ever methane standards for new and modified oil and gas sources. While praising the removal of exemptions for low-producing wells and the implementation of fixed inspection frequencies, the author argues the rule is inadequate because it ignores existing sources, which account for 75% of the sector's methane emissions. To meet the White House's goal of a 40-45% reduction in methane pollution by 2025, the author asserts that the EPA must now regulate existing sources to reduce emissions by approximately 75 million metric tons of CO2 equivalent.

The document outlines technical recommendations for the California Air Resources Board (ARB) on monitoring, reporting, and verification (MRV) and accounting for CO2 sequestration. It emphasizes the priority of subsurface plume tracking over surface monitoring, argues that only anthropogenic CO2 should be credited, and suggests pragmatic 'haircut' approaches to credit reductions in the event of atmospheric leakage. For EOR applications, it clarifies that recycled CO2 should not require mass balance accounting and stresses the critical importance of wellbore integrity in brownfields.

The testimony identifies significant regulatory barriers to advanced nuclear energy in the United States, specifically the NRC's reliance on light water reactor (LWR) standards and a high-risk, front-loaded investment profile for licensing. To address these, the Nuclear Innovation Alliance (NIA) recommends a staged licensing process utilizing licensing project plans (LPP), topical reports, and a 'statement of licensing feasibility' to provide early feedback to developers. The document advocates for S.2795 to provide dedicated funding for a technology-inclusive, risk-informed, and performance-based regulatory framework, while suggesting a shift in the NRC's budget structure from a fee-based model to one with more consistent public funding for new regulation development.

The Clean Air Task Force asserts that the EPA's Methane Challenge Program, which relies on voluntary industry commitments, cannot achieve the U.S. target of a 40-45% reduction in oil and gas methane emissions by 2025. While 41 companies joined as founding members, the program lacks participation from oil and gas exploration and production companies, which are responsible for 73% of the industry's methane emissions. Although 37 Local Distribution Companies representing nearly 60% of natural gas utility customers are participating, the author maintains that voluntary measures are no substitute for strong, nation-wide regulations of existing pollution sources.

The document is a formal request to the U.S. House Committee on Ways and Means to permanently extend and increase the value of the Section 45Q Tax Credit for Carbon Dioxide Sequestration. The authors argue that the credit is essential for incentivizing carbon capture utilization and storage (CCUS) at industrial facilities and power plants, and that current uncertainty regarding its expiration deters private investment. They highlight that CCUS is critical for meeting global mid-century greenhouse gas emission goals and for expanding domestic oil production through enhanced oil recovery (EOR).

The Obama Administration set a goal to reduce methane emissions from the oil and gas sector by 40-45% from 2012 levels by 2025. While the EPA proposed standards for new and modified sources, it has failed to address existing sources, which a 2014 ICF International study predicts will represent 90% of the sector's total methane emissions in 2018. Analysis by CATF and the Rhodium Group indicates that voluntary industry programs are insufficient to bridge the 'methane emissions gap', as even 100% participation would leave a gap of 54 million metric tons of CO2e. The author asserts that nationwide standards on existing oil and gas equipment would reduce emissions by 77 million metric tons of CO2e, sufficient to meet the Administration's goal.

The report identifies a 'methane emission gap' between the Obama Administration's goal to reduce oil and gas methane pollution by 40–45% from 2012 levels by 2025 and the actual impact of its proposed regulations. It finds that proposed standards primarily target new and modified sources, while existing sources are projected to represent 90% of the sector's total methane emissions in 2018. To close the gap of at least 75 million metric tons CO2e, the report recommends requiring leak detection and repair, non-emitting pneumatic technologies, and the capture of gas from oil wells for existing sources.

The Clean Air Task Force views the EPA's proposed methane standards for new and modified oil and gas sources as a positive first step but argues they are insufficient to meet national greenhouse gas reduction targets. While praising the direct regulation of methane under the Clean Air Act and the implementation of leak detection and repair (LDAR) requirements, CATF recommends mandating controls for omitted equipment like liquids unloading operations and increasing LDAR inspection frequency. Crucially, the document highlights that the proposal fails to address existing sources, which are projected to account for 90 percent of methane emissions by 2018.

The report identifies and assesses nine technologies to reduce the flaring of associated gas in US tight oil fields, concluding that Natural Gas Liquid (NGL) recovery, Compressed Natural Gas (CNG) trucking, and Gas-to-Power (for local loads) are the most mature and scalable options. It highlights that flaring in the Bakken and Eagle Ford basins reached approximately 125 billion cubic feet per year by 2013. The analysis emphasizes that while technical solutions exist, robust regulations are necessary to eliminate routine flaring. A case study on Alaska's Shublik formation suggests that while the region has high potential, its remoteness and harsh climate necessitate early infrastructure planning to avoid future flaring.

The Clean Air Task Force supports the EPA's first direct regulation of methane in the oil and gas sector but argues that the proposal is insufficient. It recommends expanding the rule to cover liquids unloading, pneumatic controllers, well site compressors, and storage vessels. It further contends that the proposed variable frequency for leak detection and repair (LDAR) is inadequate, advocating instead for a fixed quarterly minimum. Finally, it urges the EPA to use section 111(d) to regulate existing sources, noting that 90 percent of 2018 emissions are expected to come from sources existing in 2011.

The Arctic is warming at almost twice the global average rate, a phenomenon known as Arctic amplification. While long-term climate stability requires reducing carbon dioxide, the author argues that targeting short-lived climate pollutants (SLCPs) like black carbon (BC) and methane can provide immediate mitigation benefits. The paper specifically focuses on the shipping and oil and gas sectors, which are expected to grow as sea ice retreats. It recommends a ban on heavy fuel oil (HFO) for shipping to reduce BC and marine risks, and the creation of a best-practices dialogue via the Arctic Economic Council to limit methane releases and flaring in oil production. The author emphasizes that coordinated infrastructure planning is essential to make these cleaner practices viable in the harsh Arctic environment.

The Clean Air Task Force acknowledges the USEPA's 2015 proposal to reduce methane emissions from the oil and gas industry as a significant first step, noting it introduces the first greenhouse gas standards for the sector. However, the authors argue that the proposed rules only reduce 2012 emissions by approximately 7.5% and will not be sufficient to meet the White House goal of a 40-45% reduction by 2025. They emphasize that because existing sites are predicted to represent 90% of the sector's total methane emissions in 2018, the EPA must issue emissions guidelines for existing sources under the Clean Air Act to achieve the necessary reductions.

The Clean Air Task Force criticizes the EPA's reliance on voluntary programs to reduce methane emissions from existing oil and gas infrastructure, arguing that such measures lack the enforceability and participation rates necessary to achieve significant climate goals compared to mandatory regulations under the Clean Air Act.

The author argues that the Supreme Court's ruling in Michigan v. EPA did not vacate the Mercury and Air Toxics Standards (MATS) rule, but rather remanded the EPA's determination that regulating coal and oil-fired power plants was "appropriate and necessary" for reconsideration of costs. The document asserts that MATS emissions limits remain in place, potentially saving 11,000 lives per year, and that the decision does not affect other industries' air toxics standards, National Ambient Air Quality Standards, or the Clean Power Plan. While the ruling suggests that cost is relevant to regulatory actions involving ambiguous statutory language, the author notes that the EPA already possesses empirical cost of compliance data and a 2012 Regulatory Impact Analysis showing benefits outweighing costs by a 9:1 ratio.

The report documents a significant decline in power plant-related health impacts and emissions in the U.S. and the RGGI region between 2004 and 2012, attributing these gains to stringent emission controls, the transition from coal to natural gas, and renewable energy policies.

The Clean Air Task Force (CATF) asserts that allowing interstate trading between states with separate, unmerged emission rate targets creates a perverse economic incentive to operate higher-emitting power plants in states with more lenient targets. This 'leakage' problem would displace lower-emitting generation, leading to higher overall system emissions and increased operating costs. CATF provides a quantitative example showing that relaxing the merger requirement could result in 20 percent more emissions and nearly 50 percent higher dispatch costs. The document further argues that this risk is widespread, noting that 26 states have target emission rates below the 1000 lbs./MWh new source performance standard for natural gas combined cycle (NGCC) units. Finally, it contends that limiting interstate trading to renewable energy credits (RECs) would not solve the problem, as renewable resources in states with higher targets would generate disproportionately more credits, allowing for greater continued use of fossil resources in more stringent states.

The document argues that biomass combustion should not be part of the Clean Power Plan's 'best system of emission reduction' because it emits more CO2 per megawatt-hour than coal and relies on speculative, delayed carbon offsets. The authors contend that the EPA lacks a rational scientific framework for biomass carbon accounting and that 'sustainability' standards are an inadequate proxy for carbon dynamics.

The document argues that flaring of associated gas in the Little Missouri National Grassland (LMNG) is unnecessary because CNG trucking is a profitable alternative for a majority of flaring wells. In January 2015, approximately 30% of gas produced within the LMNG was flared. Analysis shows that 61% of wells flaring gas from the Federal mineral estate in and around the LMNG could economically use CNG trucking, which could have captured 83% of the gas flared from those specific wells. If all wells within the LMNG boundaries are considered, 89% of flared gas could be trucked. The author contends that oil producers flare for convenience to prioritize oil production and urges the Bureau of Land Management (BLM) and state regulators to phase out flaring.

The Clean Air Task Force reports that over 60 organizations have urged the EPA to implement comprehensive methane standards for new and modified oil and gas equipment. The requests include mandatory leak detection and repair across the entire sector, extending green completions to oil wells with significant gas production, reducing emissions from liquids unloading and pneumatic equipment, and covering the full supply chain including transmission and storage.