By: Kindra Weid, Michigan volunteer, Moms Clean Air Force
Date: January 10, 2023
About: Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2021-0317
To: Environmental Protection Agency
Thank you for this opportunity to comment on EPA’s supplemental proposal to reduce methane and other harmful pollution from oil and gas operations. My name is Kindra Weid, and I am a volunteer with Moms Clean Air Force and a critical care RN advocating on behalf of the Alliance of Nurses for Healthy Environments and the Michigan Clinicians for Climate Action. I reside and practice as a nurse in southeastern Michigan.
I appreciate that the draft rule has been noticeably improved upon but still strongly urge the US EPA to increase safety standards for US oil and gas operations.
Methane pollution from the oil and gas sector is not only accelerating the pace of climate change, it is extremely harmful to the health of children, families and communities across the country. Methane has more than 80 times the warming power of carbon dioxide over the first 20 years after it reaches the atmosphere, and even though CO2 has a longer-lasting effect, methane sets the pace for warming in the near term at a time when it is critical for immediate action.
We are in a climate emergency and we cannot afford to let this potent greenhouse gas continue to be under-regulated. Every day that passes without increased protections is a missed opportunity to reduce climate and air pollution from the oil and gas industry and safeguard the health and well-being of thousands of people.
The impacts of climate change are present throughout Michigan. We see the physical and mental health impacts of extreme heat, storms and heavy precipitation events; the increased spread of vector-borne illnesses; prolonged pollen and allergy seasons; and the respiratory and cardiovascular impacts of poor air quality. These are just to name a few. Many suffer in silence and in unquantifiable ways. When a severe storm causes days-long power outages, we don’t quantify spoiled food & medications, days and nights without essential medical equipment; missed appointments, work and school; and the mental toll of all of these combined stressors. These events can result in hospitalization and that is when I interact with patients in the ICU for an acute exacerbation of their chronic condition.
Analyses show that in the United States more than 17.3 million people, including 3.9 million children under 18, reside within a half mile health threat radius of active oil and gas production operations. Toxic pollutants released alongside methane, such as benzene, can worsen asthma and other respiratory diseases, increase the risk of heart attacks and cardiovascular diseases, increase the risk of cancer, cause immune system damage, and even developmental problems in children. Methane also oxidizes to form ground-level ozone, which has known negative health impacts of its own.
Communities that are often situated nearest to oil and gas production industries are often the same communities that are impacted first and worst by the rapidly worsening effects of climate change. Our communities deserve swift, regulatory action now. I urge you to act with the intensity that you would as if these emissions were directly harming your own children, family, or community- because they are.
To ensure that the strongest possible methane safeguards are finalized, I encourage EPA to include the following components in the final rule:
- Ensure that operators at wells capture associated gas and limit its flaring to instances in which it is necessary for safety or maintenance reasons;
- Strengthen the standards to address emissions from storage tanks by making them applicable to more tanks; and
- Provide 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 oil and gas leaks, by ensuring that approved monitoring technologies and data are accessible to all.
I urge EPA to finalize strong, comprehensive rules to cut methane pollution from the oil and gas sector as quickly as possible. We have the health and climate data to conclude that swift action is warranted. Thank you for this action and thank you for your time.