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Thank you for the opportunity to submit comments on the New Mexico Methane Advisory Panel draft technical report (issued in December 2019). The report’s issuance is an important step on the path toward the state’s goal of curbing climate pollution, including from the oil and gas industry.

Our comments are informed by the governor’s mandate to NMED and EMNRD: “…jointly develop a statewide, enforceable regulatory framework to secure reductions in oil and gas sector methane emissions and to prevent waste from new and existing sources and enact such rules as soon as practicable.”

In 2014, Earthworks started the Community Empowerment Project (CEP) because oil and gas pollution puts people and the climate at risk. CEP focuses on the use of optical gas imaging (OGI) to make visible otherwise invisible pollution caused by intentional releases, equipment failures, and operator errors in oil and gas fields. CEP’s primary goals are to support frontline communities; shine a spotlight on the need for regulators, legislators, and companies to reduce pollution; and promote the improvement of oil and gas policies and regulations.

One of our strategies is to file complaints with regulatory agencies nationwide in order to drive industry and government accountability for fixing pollution problems. We have been heartened to see the New Mexico Environment Department (NMED) recently begin to use Earthworks’ OGI and complaints as valid third-party evidence on which to base oil and gas investigations.

Such efforts are particularly critical now because methane pollution is 86 times more damaging to our climate than carbon dioxide over a 20-year time frame—which is only twice as long as the time that scientists say we have to avoid the most catastrophic effects of climate change.

Oil and gas operations also release volatile organic compounds (VOCs) that cause a range of health problems, including benzene, a known carcinogen, and nitrogen oxide, which contributes to the formation of ozone. This directly threatens the nearly 140,000 New Mexico residents who live within a half-mile radius of active oil and gas facilities.

The following comments focus on several sections of the report and Earthworks’ documentation of oil and gas pollution through OGI and Quantitative Optical Gas Imaging (QOGI), as well as our experience with methane control regulations in other states.

In addition, our comments are supported by input from James (Tim) Doty, President of TCHD Consulting LLC, with whom Earthworks has consulted on technical matters related to oil and gas air pollution and OGI. Mr. Doty is a former air scientist with the Texas Commission on Environmental Quality (TCEQ). He oversaw the agency’s Mobile Monitoring Team’s OGI program for ten years and served as its OGI Program Coordinator and certification instructor for another three years until his retirement from state service.

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