Comment Log Display

To Whom It May Concerned: 

Attached, please find the signatures of 3,974 EDF Activists from
across California who have submitted electronic comments in favor
of your proposed regulation for greenhouse gas emission standards
for crude oil and naturalgas facilities. 

The comment they each submitted reads: 

"I'm writing today to support your proposed rules limiting methane
pollution from California's oil and gas industry, and to ask you to
strengthen them before finalization. 

Several provisions represent some of the strongest standards in the
nation, and I am pleased that the regulations: 

* Covers both new and existing sources,
* Uses better science, evaluating methane's impact based on its
20-year impact rather than 100-year value,
* Requires comprehensive quarterly inspections of equipment that is
designed to vent (like  pneumatic controllers) and components that
can leak
* And includes key provisions moving California away from venting
and flaring wasted gas, a strategy that limits both climate
pollution and smog-forming gases that harm human health. 

But there are also several key improvements I would like to see.
Please update the final rule to improve elements of leak detection
and repair by eliminating provisions that currently allow for a
reduction in inspection frequency. California communities also
deserve a faster implementation timetable, meaning inspection
requirements should start next year and not be delayed until 2018.
Finally, your agency needs to look at all the benefits of reducing
toxic air chemicals as part of its regulatory analysis, because
only a full evaluation will show how cheap and effective these
rules are and resist the oil and gas industry pushback. 

In strengthening and finalizing these critical rules, the
California Air Resources Board will ensure that the Golden State
remains a leader in clean energy and climate action."

Please let me know if you have any questions or concerns about this
submission. 

Thank you for your consideration,

Heather Shelby
Activism & Engagement Manager
Environmental Defense Fund
(202) 572 3242
hshelby@edf.org