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Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA) proposed addition of natural gas processing plants to the Toxic Release Inventory (TRI). Please accept these comments on behalf of Earthworks, a national nonprofit organization committed to protecting communities and the environment from the impacts of mining and energy development while seeking sustainable solutions. For more than 25 years, we have fulfilled our mission by working with communities and grassroots groups to reform government policies, improve corporate practices, influence investment decisions and encourage responsible materials sourcing and consumption.

Earthworks supports the addition of natural gas processing (NGP) facilities, NAICS 211112 (North American Industry Classification System), to the TRI. The proposed rule is a necessary acknowledgement by EPA of a new reality: rapid growth in the number and capacity of NGP facilities and the negative environmental and health risks posed by these facilities. We therefore respectfully urge EPA to expeditiously finalize this proposed rule. However, for the reasons stated below, we believe that EPA underestimates the number of facilities that should report and we also urge inclusion of compression, gas gathering, and other midstream NAICS 211111 facilities as well, since (as discussed below) these can also release TRI-listed chemicals.

Earthworks has previously supported the TRI and EPA’s discretionary authority to add or delete industry sectors from TRI’s scope. Indeed, the last time EPA added an industry to the TRI, metal mining and six others, the decision was in part based on an Earthworks (then Mineral Policy Center) petition.3 In the subsequent 20 years, the metal mining industry has perennially topped TRI’s list as the nation’s largest toxic polluter.

We therefore appreciate that EPA partially granted the Environmental Integrity Project (EIP) petition, joined by Earthworks and sixteen other environmental advocacy organizations in 2015. EPA’s partial grant of that petition reveals the agency’s commitment to the purposes TRI serves. EPA’s decision also reflects the credibility and seriousness of the petitioners’ request, since the last time Earthworks and other environmental organizations requested EPA expand TRI’s scope, it was for the nation’s top toxic polluter. Now, we strongly believe that inclusion of NGP facilities in the TRI is equally warranted and urgently needed.

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