Comment Log Display

The Liberty Hill Foundation wishes to offer brief comments on the
proposed Oil and Natural Gas Production Processing, and Storage
(the “Oil & Gas rule”) regulation.  We appreciate efforts of the
California Air Resources Board (CARB) in developing the regulation,
and urge the strengthening of measures to prevent practices leaving
communities unprotected. 

Our foundation staff does not possess the technical expertise to
make detailed and specific comments.  However, we are acutely aware
of the significant health impacts that specific communities in Los
Angeles have suffered due to their proximity to active oil and gas
drilling operations.  For the last twenty years, Liberty Hill has
been a significant funder of grassroots, environmental justice
organizations in the Los Angeles region.

Liberty Hill issued a report in September 2015, “DRILLING DOWN: The
Community Consequences of Expanded Oil Development in Los Angeles”,
documenting five examples of neighborhoods severely impacted by
health ailments and disruption to their quality of life from noise,
vibration and other air quality impacts.  It is very clear that the
pollutants and chemicals associated with oil and gas production are
harmful to human health, in addition to the strong climate/GHG
impacts of methane.  Further, we are keenly aware that the industry
has been insufficiently regulated and that much of the
infrastructure—as demonstrated by the Aliso Canyon disaster—is in a
state of significant disrepair.  And, the close proximity of some
of the facilities in densely populated urban areas like Los
Angeles—some within just a few dozen feet of homes and schools—is
of great cause for concern.

We encourage the CARB to carefully review the detailed, technical
letter submitted by Julia May, Senior Scientist with Communities
for a Better Environment which calls for tighter leak standards
consistent with best practice in oil refinery standards,
accelerated implementation and strengthening of deadlines,
exemption allowances, monitoring and enforcement requirements.   We
also encourage careful review of the letter submitted by
Environmental Defense Fund which also calls for accelerated
implementation, as well as the removal of the “step down” provision
which relaxes the inspection schedule.

Thank you for the opportunity to comment.

Sincerely,
 
Michele Prichard
Director, Common Agenda