Comment Log Display

July 18, 2016

California Air Resources Board
1001 “I” St. 
Sacramento, CA, 95814 
Via Electronic Submittal: 
http://www.arb.ca.gov/lispub/comm/bcsubform.php?listname=oilandgas2016&comm_period=A


Re: Letter of Support and Suggested Improvements for the Revised
Draft Regulation for Greenhouse Gas Emission Standards for Crude
Oil and Natural Gas Facilities


The undersigned organizations would like to submit this letter in
support of the proposed rule to regulate greenhouse gas emissions
from oil and gas facilities in California. 

We commend California Air Resources Board (“CARB”)”) staff for
drafting a proposal that directly regulates methane and associated
emissions from a diverse suite of new and existing oil and gas
sources. Many of the provisions contained in the draft represent
models for the nation, including the quarterly baseline inspection
requirement for facilities, the continuous ambient air quality
monitoring requirement for natural gas storage facilities, and the
prioritization of natural gas capture over combustion requirements
for a suite of equipment.  Nevertheless, there remain opportunities
to further enhance the public health and welfare benefits of the
rule, and to showcase California as the foremost leader in tackling
serious clean air and environmental issues.

As a growing body of evidence demonstrates, there are significant
negative public health and environmental impacts associated with
pollution from oil and gas - and communities living nearby are the
ones most affected. Studies show that along with the release of
strong climate pollutants like methane, oil and gas production
releases harmful co-pollutants like volatile organic compounds that
contribute to ozone formation that impact lung health, and toxic
chemicals like benzene, which is a known human carcinogen. The
communities most impacted by oil and gas pollution are often
low-income communities and communities of color that are already
disproportionately vulnerable to socio-economic and environmental
hazards. Residents of the most impacted communities throughout
California, many of which live less than 30 feet away from
production facilities, have experienced firsthand the harmful
effects of oil and gas pollution. Reported symptoms from residents
living near oil and gas operations have included onset of asthma
and other respiratory problems, nausea, dizziness, loss of smell,
and frequent migraines. Additionally, science shows that our most
vulnerable and defenseless populations - children, pregnant women,
and the elderly - are most susceptible to experiencing negative
health impacts from oil and gas pollution.

In order to ensure that the proposed regulation results in maximum
reductions in emissions that harm community health, we support CARB
in its efforts to strengthen the leak detection and repair
requirements applicable to facilities with the potential to leak or
inadvertently vent harmful pollutants. Specifically, by removing
the step down provision from the proposed draft, the rule is
greatly strengthened. By allowing operators to move to relaxed
annual inspection standards if leaks are not detected in the first
five quarters, operators are dis-incentivized to properly detect,
report, and repair leaks. Additionally, due to the century-old
infrastructure that exists in most of the state, leaks may happen
at any time, and strict quarterly inspections are critical for
catching leaks when they are still small and manageable, and before
they turn into another Aliso Canyon-scale catastrophe. For these
reasons, we believe that in order for the rule to be effective in
protecting the health of our families, the step down provision must
be removed.

Additionally, we are concerned that the timeframe for implementing
the rule has slipped by approximately one year, and believe that
the implementation date should be reviewed.  While we understand
the need to ensure adequate time for Air District staff and
industry to prepare for administration and compliance with the
rule, we urge CARB to implement the rule expeditiously with no
further delays, so that communities can begin experiencing the
critical clean air protections afforded by the rule’s many strong
provisions. 

Thank you for taking seriously the concerns of our communities.

Sincerely,

 
Irene Burga, JD
Oil and Gas, Environment Justice Fellow
Environmental Defense Fund



Madeline Stano, JD
Staff Attorney 
Center on Race, Poverty & the Environment 

Vinai Decena RN, PHN
Northern California Program Coordinator
Alliance of Nurses for Healthy Environments

Bonnie Holmes-Gen
Senior Director, Air Quality and Climate Change
American Lung Association in California

 
Scott Takahashi, PharmD
Chair
Asthma Coalition of Los Angeles County

Taylor Thomas
Research and Policy Analyst
East Yard Communities for Environmental Justice

Gisele Fong, PhD
Executive Director
EndOil

Bill Magavern
Policy Director
Coalition for Clean Air