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Testimony delivered for public comment hearing on proposed rules to reduce oil and gas methane by the U.S. Environmental Protection Agency, 10 January, 2023.

I’m Sharon Wilson with Earthworks speaking to you from Dallas.

I have endlessly submitted comments to the EPA on oil and gas pollution. First at the Air Division in Research Triangle Park in 2010. Two months later, I met with Gina McCarthy in DC. And here I am again.

What’s changed in 12 years? Oil and gas pollution is magnitudes worse pushing the globe to the precipice of climate catastrophe. And this agency has failed to address the problem.

I became an optical gas imaging thermographer in 2014. 

Your Super Emitter Response Program has two flaws. First, communities suffer from ongoing emissions that might not reach the super emitter threshold. Their complaints must be considered. Second, quantification requires industry inputs, you are limiting participation to only those the industry is willing to work with. My evidence is credible evidence and should be allowed and even sought out. 

People are in prison based on video evidence from a cell phone. EPA must accept credible evidence of pollution documented by community monitoring. Why should a polluting industry be allowed higher consideration? 

Some lessons learned from over a decade in the field–specifically in Texas.

First: Texas will not regulate this industry. I’ve submitted about 400 complaints with video evidence of pollution and the TCEQ provides 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–I have documented that the industry’s solutions to methane emissions do not reliably prevent emissions. 

Vapor Recovery Systems malfunction frequently. They are dependent on proper sizing, reliable electricity, persistent maintenance, and in some cases proper flare operation. Without those there is no vapor recovery. 

They cannot keep flares lit. Even when the flare has auto-relight, sensors and special monitoring equipment, I find them unlit and blasting methane. 

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. 

Equipment start up, shut down, maintenance and malfunction emergencies all require releases. 

Oil and gas has never been adequately regulated. Today there are 350 active rigs in the Permian Basin and 71 in the Eagle Ford Shale. Adequate regulation, if that’s even possible, will require a dedicated army. 

We need solutions that rise to meet the emergency created by oil and gas.