EPA has posted a massive proposed rule making targeting the oil and natural gas industry, calling it a “climate review”.

The full title is “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review”

The URL for commenting is here:


EPA has included a lot of tricky stuff in how the proposal is made. First, this is what is called a “holiday rule making” which EPA is famous for. The comment period is just 60 days long and it spans the Thanksgiving, Christmas and New Year holidays.

Second, most major proposals consist of just a few documents. Typically just the proposal itself plus a technical support document or two. In this case there are a whopping 184 different documents, with no time to read them all.

Also while the webpage says that as of this writing about 16,000 comments have been received only 30 have been posted. However it may well be that the others are the junk duplicate green emails that often plague EPA commenting.

A serious early comment from the American Petroleum Institute speaks to the complexity of the proposal. API says this:

“The proposal includes substantial changes from current regulations and includes multiple areas where EPA is requesting comments. We note the need for additional time to review and respond to the proposed rules. Considerable effort will be required to analyze and understand rule implications, and to develop constructive comments. Further, EPA has explicitly solicited feedback on over 200 specific items, all of which will require time to analyze, collect any necessary data, and develop thoughtful responses. A minimum 30-day extension to the comment period will be necessary to respond to the proposed rules.”

API also says:

“With respect to rule implementation, we urge EPA to carefully consider the availability and cost of equipment, labor and other required resources needed to comply with the proposed standards. These aspects are especially critical in setting workable implementation timelines, given the hundreds of thousands of existing sources that may require retrofit, and current well-documented supply chain shortages.”

Why is EPA hammering the oil and natural gas industry, which will cost all of us dearly when these costs hit consumers? Here is their goofy rationale:

“This proposed rulemaking takes a significant step forward in mitigating climate-destabilizing pollution and protecting human health by reducing GHG and VOC emissions from the Oil and Natural Gas Industry, specifically the Crude Oil and Natural Gas source category. The Oil and Natural Gas Industry is the United States’ largest industrial emitter of methane, a highly potent GHG. Human activity-related emissions of methane are responsible for about one third of the warming due to well-mixed GHGs and constitute the second most important warming agent arising from human activity after carbon dioxide (a well-mixed gas is one with an atmospheric lifetime longer than a year or two, which allows the gas to be mixed around the world, meaning that the location of emission of the gas has little importance in terms of its impacts). According to the Intergovernmental Panel on Climate Change (IPCC), strong, rapid, and sustained methane reductions are critical to reducing near-term disruption of the climate system and are a vital complement to reductions in other GHGs that are needed to limit the long-term extent of climate change and its destructive impacts.”

Note the nonsensical alarmist rhetoric: “climate-destabilizing pollution” and “disruption of the climate system” and “destructive impacts”. I earlier wrote about this methane pseudo-problem.

See my https://www.cfact.org/2021/11/04/cop-26-methane-madness/.

Recent research by Happer and van Wijngaarden finds that increasing methane will have negligible impact on global temperatures, so not on climate either. Methane is harmless.

See https://co2coalition.org/wp-content/uploads/2021/08/Methane-and-Climate.pdf

In short EPA is proposing to hammer our basic energy system with no scientific justification. As API explains: “Our members produce, process, and distribute most of the nation’s energy. The industry supports more than 10 million U.S. jobs and nearly 8% of the U.S. economy.”

This is truly methane madness.


  • David Wojick, Ph.D. is an independent analyst working at the intersection of science, technology and policy. For origins see http://www.stemed.info/engineer_tackles_confusion.html For over 100 prior articles for CFACT see http://www.cfact.org/author/david-wojick-ph-d/ Available for confidential research and consulting.