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Power Generation for Generations to come

Take Action to Reinstate the Methane Rule


Power Generation for Generations to Come has prepared three arguments expressed in sample public comments on why the U.S. Bureau of Land Management (BLM) proposal should be rejected and the original methane rule maintained. Each argument is based on a myth that the BLM has spun in defense of its deregulatory proposal.  The three sample comments, one to explode each myth, are provided for you to personalize and/or submit. This public comment period will end on April 23, 2018.


Personalize and/or send one of the sample comments,
below it’s corresponding Myth and Background,
to the Bureau of Land Management.

The link above will take you to the Federal Register site for the Rescission Rule.
Click the green button to the right below the Rule title that says “Submit a Formal Comment.”




BLM Myth #1.   Only domestic effects of domestic activities count.


President Trump’s Executive Order (EO) 13783 attempts to remove from consideration effects of deregulated fossil fuel extraction activities on global climate outcomes. It begs us to imagine that only a small portion of all U.S.-generated pollution affects the United States, and other countries’ smog, not at all. But earth’s atmosphere is unrelentingly global.  Each country’s climate impacts are roughly proportional to total worldwide emissions.  In the end, what we dish out, we will eat.

BLM Myth #2.  Climate impacts are imprecise and unforeseeable.


The phrase “reasonably foreseeable” means a lot in the National Environmental Protection Act. Plans like BLM’s proposal have been litigated on just how it may be used. Phrases like “the BLM notes that the actual effects of such [greenhouse gas] emissions on global climate change cannot be reliably assessed and thus are sufficiently uncertain as to be not reasonably foreseeable” wiggle and wriggle in legal limbo throughout the Draft Environmental Assessment of BLM’s proposed rule.

BLM Myth #3.  Making Science Great Again eliminates pesky facts


The BLM’s background information plays fast and loose with justifications for ignoring scientifically based conclusions. Even its adoption of a Bush era financial impact standard ignores its advice.

Sample comment to explode myth #1

The estimate of forgone climate benefits from the proposal (see section 3.3 of Regulatory Impact Analysis) is flawed.  The promulgation of this domestic harm-only standard implies its legitimate application by every nation around the globe.  Climate harms produced in each land are proportional to the sum of atmospheric pollutants emitted by all nations.  The choice to measure only harms directly caused from one nation’s pollutants against that same nation’s climate is a foolish and fallacious notion.  It is like a person saying, “this closed room has enough air for me to breathe for 100 years” and ignoring the fact that the other 999 people in the room must also breathe.  Earth’s atmosphere forever will resist being divided into domestic and global components. Even if an environmental assessment ignores the oversized contributions to climate change imposed globally by baseline domestic habits in the United States, BLM’s analysis of domestic social costs of its proposal must consider the reciprocal right of other nations to pollute on the same terms that BLM deems acceptable for this nation to pollute.  The outcome is that the sum total of U.S. emissions should be considered equal to emissions that impact this country domestically.


Sample comment to explode myth #2

The BLM’s repeated assertion in the Draft Environmental Assessment that the effects of greenhouse gas emissions on global climate change and associated harms cannot be reliably assessed and thus are sufficiently uncertain as to be “not reasonably foreseeable” is an abuse of logic, of the English language and of judicial precedent.  The fact that the exact shape that an automobile will have after an imminent head-on collision with a semi-truck is unclear does not mean that the most significant effects of the impending collision are sufficiently uncertain as to be not reasonably foreseeable.  The trajectory of the increasing concentration of greenhouse gases in earth’s atmosphere and the delay of several decades in most of the major resulting effects, such as sea level rise, global mean temperature increase, mass extinctions, displacement of species and other catastrophic harms, is sufficiently certain to disallow a grim linguistic game of feigned ignorance for short-term vested interests.


Sample comment to explode myth #3

The BLM’s background information explains that by Executive Order 13783, President Trump disbanded a federal interagency body tasked with assessing the social cost of greenhouse gases and threw away its researched conclusions. BLM then explains that it chose “interim values…. In accordance with E.O. 13783, they are adjusted to reflect discount rates of 3 percent and 7 percent, and to present domestic rather than global impacts of climate change, consistent with OMB Circular A-4.” This language is misleading.  Circular A-4, a Bush era OMB standard, does not include the word “domestic.” And it recommends, among other ignored counsel, that “[i]f your rule will have important intergenerational benefits or costs you might consider a further sensitivity analysis using a lower but positive discount rate in addition to calculating net benefits using discount rates of 3 and 7 percent.”  The higher rates have the effect of saying that future generations have a value that is very, very close to zero. This valuation of life on earth works well for purposes that are likely to be destructive of future generations’ viability.  But pursuers of life, liberty and happiness are not in that camp, and we will not abide rules that usurp our inalienable rights.


Copy a sample comment, above, paste, personalize and send it
to the Bureau of Land Management.