Tell the Oil Conservation Division that you want nation-leading methane rules that will help fight climate change and protect community health in the oil fields.
New Mexico's oil and gas industry has a massive methane problem. That's because methane gas is released from oil and gas infrastructure when it is leaked, vented or flared throughout the production process.
Methane is a super pollutant that is an even more dangerous greenhouse gas than carbon dioxide—in terms of both climate change and the quality of the air we breathe. Methane escapes with carcinogens like benzene and other toxic air pollutants that contribute to smog formation. That means when methane is leaked, vented and flared into our air, it can spike asthma attacks and cancer rates.
Early in her tenure, Governor Michelle Lujan Grisham issued an executive order directing her administration to take action on climate change. As part of that order, she called for developing nation-leading rules to reduce methane waste and leakage from oil and gas production in New Mexico.
The rule-making is divided between the Energy, Minerals and Natural Resources Department's Oil Conservation Division (OCD) and the New Mexico Environment Department (NMED). OCD is developing rules to regulate the waste of methane through venting and flaring, while NMED is developing rules regulating leaks in oil and gas production infrastructure.
Initial rules developed by OCD and NMED were released for public comment in October. While a first step, they currently have significant loopholes and gaps that need to be addressed to ensure they are as strong as possible. A hearing on the rules regulating venting and flaring has been set with the Oil Conservation Commission (OCC) on January 5.
Can we count on you to strengthen our impact at the hearing? Sign the petition today to tell the Oil Conservation Division that you want nation-leading methane rules that will help fight climate change and protect public health.
To the Members of the Oil Conservation Commission:
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.
The 2020 New Mexico Climate Strategy: Progress and Recommendations report revealed that "the oil and gas sector generated 60 million metric tons of greenhouse gas emissions in 2018, nearly four times more than previously estimated based on national data" and that more than half the state's greenhouse gas emissions come from the oil and gas sector with the rest spread among six other sectors.
Critically, the Climate Strategy report released in October 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."
On Nov. 10, NM Treasurer Tim Eichenberg and a group of 40 investors, managing some $102 billion worth of assets in the state, sent a letter to the Governor calling for exemptions and loopholes to be removed from the proposed regulations.
The current version of the proposed OCD rule is only a modest improvement over the draft rule it circulated for public comment in July. The rule does not prohibit routine flaring from new oil and gas wells and does not include a 90% base level gas capture requirement that companies must meet by the end of 2021 to receive approval for new oil and gas well permits. It also relies too heavily on OCD's admittedly limited enforcement resources to ensure meaningful consequences for oil and gas companies that do not comply with the rules.
I support the following improvements to the OCD draft rule:
- While there is improved natural gas management planning for proposed new oil and gas wells, the proposed rule allows a company that is not in compliance with the 98% gas capture requirement to receive approval for new oil and gas drilling. Operators should be required to clean up their existing wells before they get permits for new wells.
- Third-party verification, which is at the discretion of the OCD in the draft rule, should be required of all operators.
- The proposed rule does not prohibit routine flaring. Routine flaring of associated gas should not be tolerated in New Mexico as an acceptable business practice and the proposed rule, by not banning it, has missed an opportunity.
- The proposed rule does not require operators to achieve a base 90% gas capture requirement by the end of 2021 in order to get new drilling permits. Seven of the top 25 oil producers in New Mexico flared more than 20% of their produced gas in 2019. The vast majority of operators are already achieving a capture percentage of 90% or greater, so there is no excuse for OCD to allow an operator to capture less than 90%.
- The draft rule does not require oil and gas companies to prepare natural gas management plans to show how they will minimize venting and flaring at the point well spacing decisions are made.
- The draft rule has a weak incentive structure for Advanced Leak And Repair Monitoring (ALARM) but otherwise does not specifically cover methane leaks, only methane that is vented and flared. This is insufficient to mitigate serious flaws with the New Mexico Environment Department's counterpart ozone pollution rule, specifically unacceptable exemptions for low-producing stripper wells and for sites below a 15-ton-per-year pollution threshold.
Strong methane rules will help improve air quality in communities near oil 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. Capturing almost all the methane currently vented and flared will increase revenue for both private companies and the state government, and installing, monitoring and maintaining the equipment will create jobs.
I ask you to heed the data, the investor community, the oil field communities, and the Governor and put New Mexico at the forefront with a nation-leading rule.
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