This testimony was provided by Shannon Smith, FracTracker Manager of Communications & Development, at the July 23rd hearing on the control of methane & VOC emissions from oil and natural gas sources hosted by the Pennsylvania Department of Environmental Protection (DEP).

My name is Shannon Smith and I’m a resident of Wilkinsburg, Pennsylvania. I am the Manager of Communications and Development at the nonprofit organization FracTracker Alliance. FracTracker studies and maps issues related to unconventional oil and gas development, and we have been a top source of information on these topics since 2010. Last year alone, FracTracker’s website received over 260,000 users. FracTracker, the project, was originally developed to investigate health concerns and data gaps surrounding Western Pennsylvania fracking.

I would like to address the proposed rule to reduce emissions of methane and other harmful air pollution, such as smog-forming volatile organic compounds, which I will refer to as VOCs, from existing oil and gas operations. I thank the DEP for the opportunity to address this important issue.

The proposed rule will protect Pennsylvanians from methane and harmful VOCs from oil and gas sources, but to a limited extent. The proposed rule does not adequately protect our air, climate, nor public health, because it includes loopholes that would leave over half of all potential cuts to methane and VOC pollution from the industry unchecked.

Emissions of the potent greenhouse gas methane and VOC pollution harm communities by contributing to the climate crisis, endangering households and workers through explosions and fires, and causing serious health impairments. Poor air quality also contributes to the economic drain of Pennsylvania’s communities due to increased health care costs, lower property values, a declining tax base, and difficulty in attracting and retaining businesses.

Oil and gas related air pollution has known human health impacts including impairment of the nervous system, reproductive and developmental problems, cancer, leukemia, depression, and genetic impacts like low birth weight.

One indirect impact especially important during the COVID-19 pandemic in 2020, is the increased incidence and severity of respiratory viral infections in populations living in areas with poor air quality, as indicated by a number of studies.

Given the available data, FracTracker Alliance estimates that there are 106,224 oil and gas wells in Pennsylvania. Out of the 12,574 drilled unconventional wells, there have been 15,164 cited violations. Undoubtedly the number of violations would be higher with stricter monitoring.

There is a need for more stringent environmental regulations and enforcement, and efforts to do so should be applauded only if they adequately respond to the scientific evidence regarding risks to public health. These measures are only successful if there is long-term predictability that will ultimately drive investments in clean energy technologies. Emission rollbacks undermine decades of efforts to shift industries towards cleaner practices. So, I urge the DEP to close the loophole in the proposed rulemaking that exempts low-producing wells from the rule’s leak inspection requirements. Low-producing wells are responsible for more than half of the methane pollution from oil and gas sources in Pennsylvania, and all wells, regardless of production, require routine inspections.

I also ask that the Department eliminate the provision that allows operators to reduce the frequency of inspections based on the results of previous inspections. Research does not show that the quantity of leaking components from oil and gas sources indicates or predicts the frequency or quantity of future leaks.

In fact, large and uncontrolled leaks are random and can only be detected with frequent and regular inspections. Short-term peaks of air pollution due to oil and gas activities are common and can cause health impairments in a matter of minutes, especially in sensitive populations such as people with asthma, children, and the elderly. I urge the Department to close loopholes that would exempt certain wells from leak detection and repair requirements, and ensure that this proposal includes requirements for all emission sources covered in DEP’s already adopted standards for new oil and gas sources.

Furthermore, conventional operators should have to report their emissions, and the Department should require air monitoring technologies that have the capacity to detect peaks rather than simply averages. We need adequate data in order to properly enforce regulations and meet Pennsylvania’s climate goals of decreasing greenhouse gas emissions by 80% by 2050.

Pine Creek compressor station FLIR camera footage by Earthworks (May 2019).