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Jack 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.


My name is Jack McDonald. I am 19 years old, and I live in Dallas Texas. 

When I was younger my family lived on the Barnett Shale. Our town had 50 wells drilled with plans to go to over 100. Our house was just a mile from gas wells that released emissions into the air and regularly had spills. There were plans for fracking within 1000 feet of homes and near my school. A cul-de-sac in the neighborhood across the street had several cases of rare childhood cancers. The health department determined breast cancer rates were elevated. My family moved. We were fortunate; many people do not have the means to move.

I first told this story at an EPA listening session on rolling back methane regulations in October of 2019. Unfortunately, despite near unanimous protesting from those who commented at the session, those methane rollbacks did happen.

When I last testified I was a senior in high school. I took a gap year in between my senior year of high school and college, during that time I have had the privilege of becoming the Texas Field Analyst for Earthworks. In that role, I have begun to understand the full extent to which Texas has sold its soul to oil and gas. 

I have watched this Texas Legislative session as the chairmen of the *environmental regulations* committee proposed a bill that would prevent state agencies from enforcing federal environmental regulation. I have seen bills that aim to regulate flaring die without even a committee hearing, even bills just to study the impact of methane died. I learned that in the Texas Legislature Climate Change is a dirty word, that even some environmental groups are afraid to say in hearings. Bill after bill was filed to protect the interests of fossil fuels even to the detriment of the people. When 151 people died earlier this year during the winter storm, it seems that fossil fuels lobbyists saw an opportunity. They used the storm to pass laws like HB 17 which prevents local governments from regulating where their local utility sources its power. Even the few Democrats willing to say the word climate change supported that bill despite the representative who filed saying in a hearing that it was designed to target the climate plans of cities like Dallas and Austin.

I was also able to visit the Permian Basin with Sharon Wilson who does optical gas imaging for Earthworks. I had seen OGI footage before, but being out among those wells was a totally different experience. I saw tanks where no one had bothered to close the hatches. Flares that no one had bothered to light. I visited neighborhoods where the smell of gas was overpowering. I knew from work I had done as a Field Analyst that many of the things we saw were against state regulation, but clearly those regulations were not working. Even now after submitting numerous complaints on the sites that we saw nothing has changed. 

I worked on research understanding the extent to which Texas has failed to regulate its oil and gas producers. Through that research I learned that oil and gas operators were failing to get permits for flaring more than 75% of the time. That report which Earthworks published earlier this year elicited a response from the Railroad Commission. The best they could do to explain why 75% of flares were not being permitted by the RRC was to say that those must be emergencies.  Texas doesn’t regulate methane. When a site has a release of methane they don’t even have to report a volume for it. The closest thing to methane regulation is those flaring permits and even those it seems like the state can’t be bothered to actually enforce.

I’ve only been working in this field full time for about nine months. But I understand the pollution that Texas oil and gas communities live with, and the dread with which the rest of the world looks at Texas and our outsized contribution to the climate crisis. If Texas is left to its own devices it will bring the rest of the world hurtling towards climate catastrophe. Texas is an environmental rogue state, and we need the EPA’s help to stop it. .

Federal regulation is a necessity. We need the strongest methane regulation that the EPA can achieve under the Clean Air Act. I understand a plan has been laid out for a 65% reduction, and Texas communities need every percentage point.  Moreover, Texas regulators are not equipped, nor inclined, to regulate the oil and gas industry. They’d rather let oil and gas do what they want, regardless of the consequences. Texas needs to be stripped of its ability to enforce the Clean Air Act — Texas, and the planet – need EPA to intervene.

I’m only 19. I’m going to college next year. My generation needs time to be prepared to fully address the climate crisis. Time to learn, grow, innovate, and contribute. We’ll gladly seize the reins when the time comes, but you’ve got to give us the breathing room to do so.