Comment Log Display

Monday, July 18, 2016

Subject: Please quickly finalize strong methane safeguards --
Notice of Public Hearing to consider the Proposed Regulation for
Greenhouse Gas Emission Standards for Crude Oil and Natural Gas
Facilities.

Dear California Air Resources Board Chair Nichols and fellow board
members,

I'm writing to thank the Air Resources Board for developing
critically important rules to address methane pollution from the
oil and gas industry in California, and to urge the agency to
quickly finalize these safeguards.

"Then I say the Earth belongs to each generation during its course,
fully and in its own right, no generation can contract debts
greater than may be paid during the course of its own existence."
-- Thomas Jefferson

Full implementation of these new protections would make California
a national leader in reining in out-of-control methane pollution
from the oil and gas industry. The comprehensive scope of these
rules--including addressing both new and existing sources, both
onshore and offshore infrastructure, and setting monitoring
standards for natural gas storage sites like Aliso Canyon--avoid
many of the loopholes and weaknesses of other state and federal
standards.

"It is our task in our time and in our generation, to hand down
undiminished to those who come after us, as was handed down to us
by those who went before, the natural wealth and beauty which is
ours."
-- John F. Kennedy

However, in addition to ensuring that these rules aren't weakened
in any way, I urge the Air Resources Board to strengthen a few
provisions, including:

* Require operators to regularly find and fix leaks, and remove the
provision allowing operators to "step-down" from quarterly to
annual inspections depending on whether they find leaks;

* Do not exempt sources of methane such as low-bleed pneumatics;

* Ensure that agency cost estimates take into account the value of
reducing pollution from oil and gas industry in California
communities, including reducing exposure to toxics.

"Our duty to the whole, including to the unborn generations, bids
us to restrain an unprincipled present-day minority from wasting
the heritage of these unborn generations. The movement for the
conservation of wildlife and the larger movement for the
conservation of all our natural resources are essentially
democratic in spirit, purpose and method."
-- Theodore Roosevelt

The massive, nearly four-month-long methane leak in Porter Ranch
was a wakeup call that the lax regulation of existing oil and gas
facilities is an immediate threat to our health and our climate.
That's why I support these new safeguards and urge the Air
Resources Board to implement the strongest rules possible without
delay.

"A thing is right when it tends to preserve the integrity,
stability, and beauty of the biotic community. It is wrong when it
tends otherwise."
-- Aldo Leopold

Thank you for your consideration of my comments. Please do NOT add
my name to your mailing list. I will learn about future
developments on this issue from other sources.

Sincerely,
Christopher Lish
San Rafael, CA