By: Elizabeth Hauptman, Michigan state coordinator, Moms Clean Air Force
Date: January 10, 2023
About: Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2021-0317
To: Environmental Protection Agency
I’m Elizabeth Hauptman. I live in Livingston County with my family, and I’m the state coordinator with Moms Clean Air Force Michigan. We have 30,000 members here in Michigan and 1.4 million nationally fighting for clean air and climate action for the sake of our children’s health and future.
I’d like to start by thanking EPA for closing a loophole in the leak detection and repair (LDAR) standards by requiring routine inspections using gas imaging cameras at all wells, including low-producing wells, which are responsible for half of all methane emissions nationwide. My family appreciates the new program to address large leaks of methane more quickly through third-party monitoring, and EPA’s requirement that abandoned wells are subject to inspections until closure. I’m glad that oil and gas companies will have to submit a closure plan and that EPA will conduct a post-closure survey of these wells to ensure they are not leaking.
However, more work needs to be done to protect the health and future of our children. Parents want the strongest possible methane safeguards to be finalized by EPA to address climate change and protect public health. EPA needs to include limiting flaring only to instances where it is necessary for safety or maintenance reasons, strengthening the standards to address emissions from storage tanks by making the standards applicable to more tanks. In addition to providing a clear pathway for communities and individuals to participate and engage in the Super-Emitter Response Program, which is designed to quickly address very large leaks from the oil and gas industry by ensuring that approved monitoring technologies and data are accessible to all.
Methane, which is the primary ingredient in natural gas, is a powerful greenhouse gas that is contributing to the climate crisis. Michiganders are experiencing climate change today with more flooding, coastal erosion, warming of the Great Lakes, and extreme weather. Climate change is causing our lakes to warm faster than our oceans and is impacting the fish populations. Michigan summers are getting longer and hotter, and during our warmer winters, we see more rain and less snow, our lake only freezes for weeks, not months. We cannot skate, sled, or ice fish because it’s too warm. These changes affect commerce and recreation for all Michiganders.
These hotter temperatures can cause an increase in ground-level ozone pollution or smog. Smog is a lung irritant that triggers asthma attacks. My son, Oscar, has asthma, so I understand how vital clean air is for life. He is one of 166,000 children in Michigan who suffer from asthma. Michigan has some of the worst asthma rates in the country according to the American Lung Association. In the summertime, parents like me need to check our weather apps to see if it’s safe for our children to play outside. We have far too often rushed home after a soccer game on a hot summer day to use his nebulizer.
Children are more impacted by air pollution for many reasons. They breathe more rapidly than adults, spend more time outdoors, and are more physically active than adults, thus exposing their still-developing lungs to more air pollution. That’s why I depend on EPA to do their job and protect children from air pollution and climate change. Moms and dads want climate action, and we want EPA to make protective regulations that would limit potent greenhouse gas emissions from oil and gas operations. We need to cut methane pollution to help clean up our air, protect children’s health, and stabilize our climate. Thank you.