Tell the Environment Department you want nation-leading methane rules that will help fight climate change and protect community health in the oil fields.

To the Members of the Environmental Improvement Board:  

I am writing to support Governor Michelle Lujan Grisham's call for nation-leading methane rules. Methane is a powerful greenhouse gas and the rules regulating it must be as stringent as possible.

In August, the International Panel on Climate Change (IPCC) released their latest Assessment Report. The report showed there is very little time to mitigate the worst impacts of rising global temperature. One key finding of the report was that rapidly reducing methane emissions could have a dramatic effect on limiting global temperature increase.

The 2020 New Mexico Climate Strategy: Progress and Recommendations report states that "Our current and proposed climate strategies will make a significant dent in our greenhouse gas emissions profile by 2030—but reaching our targets will require renewed ambition and additional action." (emphasis added)

Ozone precursors and other volatile organic compounds (VOCs) pollute the air that hardworking New Mexican families must breathe, causing asthma and other health problems, and worsening visibility, which lowers the incentive for developing outdoor recreation opportunities. Regulating leaks of ozone precursors will also limit methane emissions and formation in the atmosphere.

I support the proposed improvements to NMED's proposed ozone rule put forward in a joint proposal by CVNM and several other groups represented at the EIB hearings by the Western Environmental Law Center and by the Environmental Law Clinic at the University of New Mexico Law School. Specifically, I support these four significant changes:

• Ensure the oil and gas industry addresses leaking equipment. A significant portion of air pollution from the oil and gas industry is generated from old, faulty, or damaged equipment that leaks toxins into the air. We need to make sure that leaks are identified and fixed as quickly as possible. The rules must require more frequent leak detection and repair (LDAR) inspections at well sites within 1,000 feet of an occupied place (e.g. home, school, commercial center); this will help protect frontline communities


• Upgrade equipment to zero-emission technology. The oil and gas industry uses pneumatic controllers that regulate temperature and air pressure to keep the oil and gas system operating smoothly. The pneumatic technology used by much of the industry releases pollution into the air. New Mexico should accelerate the transition to zero emission devices as soon as possible (by 2027)


• Require storage tanks to be operated in ways that eliminate leaks. Operators of new storage tanks should install equipment that allows the tank to be automatically gauged, and samples withdrawn, without opening hatches (often called "thief hatches"). Substantial emissions escape from open or improperly closed thief hatches


• Address pollution when oil and gas wells are readied for production. After a well is drilled, it is typically lined and flushed to clear sand and drilling fluids, a process called "completion." The state should require emissions from flowback during completion or recompletion of a well to be controlled or combusted so that it doesn't vent into the air.

Strong ozone precursor rules will help improve air quality for workers and in communities near oil and gas fields. This is also an environmental justice issue because a significant portion of the state's oil and gas infrastructure is located near communities of color and/or low-income families. In many of these communities, the negative health impacts of poor air quality are also compounded by the effects of poverty.

I ask you to heed the international and state calls for aggressive action on greenhouse gas emissions and the Governor's pledge to put New Mexico at the forefront of greenhouse gas emission regulation with nation-leading rules.

Sincerely,
[YOUR NAME]