Sharon provided the below comment live to the EPA during its June 15, 2021 methane public listening session to provide input on the rule it will publish this September to cut oil and gas production’s methane pollution.
I’m Sharon Wilson with Earthworks speaking to you from Dallas.
Today I join the calls for the EPA to fully use the powers provided by the Clean Air Act to cut oil and gas methane pollution 65% by 2025. It’s the least that you can do and it’s not nearly enough.
Our climate emergency is headed toward a climate catastrophe.
Last month, the International Energy Agency said to avoid climate catastrophe, we cannot regulate new oil and gas extraction, we must stop new oil and gas extraction.
I first presented optical gas imaging evidence to the EPA ten years ago, at the AIr Division in Research Triangle Park. Two months later, I met with the current White House Climate Advisor Gina McCarthy in DC.
In 2014, I became a certified optical gas imaging thermographer. Since then, I have traveled throughout the U.S. and the UK and have been interviewed and featured in hundreds of articles detailing harms of pollution from this industry.
I have participated in at least 5 EPA oil and gas pollution listening sessions. And here I am again.
What’s changed in 10 years? Oil and gas pollution is magnitudes worse pushing the globe to the precipice of climate catastrophe. And this agency has not addressed the problem.
I want to share lessons I’ve learned from over a decade in the field–specifically in Texas.
First: Texas will not regulate this industry. I’ve made well over 200 complaints with video evidence of pollution and the TCEQ has provided more cover for the industry than enforcement.
Second: Texas leaders are ideologically defiant and have vowed to fight back against any attempts to regulate oil and gas. The EPA must rescind Texas’s implementation of the Clean Air Act if there is any hope for methane rules to be successful.
Third–and this is very important–the industry’s solutions to methane emissions do not reliably prevent emissions.
They cannot keep flares lit. Even when the flare has auto-relight, I find them unlit and blasting methane. In 2017, 14% of the sites I visited had unlit flares. By the first quarter of 2020, that number was 34%. The problem is not just mechanical failures. Sometimes flares are intentionally left unlit.
Vapor Recovery Systems malfunction frequently. They are dependent on reliable electricity and or proper flare operation. Without those there’s no vapor recovery. But we find vapor recovery malfunctions for many other reasons.
Workers open tank hatches to take measurements and samples. This process called “thieving” allows intense pollution from tanks to escape for about 45 minutes each time it occurs, which may be a dozen times a day. At least nineteen men have died while thieving. Nearby neighbors and the climate have suffered. This process defeats the purpose of vapor recovery.
American Petroleum Institute recommends Standard 21 to prevent opening tank hatches. The industry only follows Standard 21 where it’s mandated. A Federally mandated Standard would protect our climate and nearby neighborhoods and save workers’ lives.
Pressure releases are required, are permitted, and are baked into the design of oil and gas equipment. Even if these releases are reduced, the continued expansion of oil and gas guarantees methane levels will continue to rise.
Oil and gas has never been adequately regulated. Since 2005 when the fracking boom started, the industry has expanded everywhere and there are well over 250,000 wells just in Texas. Adequate regulation, if that’s even possible, will require an army.
We need solutions that rise to meet the emergency created by oil and gas.