Docket ID Number EPA-HQ-OAR-2010-0505
Oil and Natural Gas Sector: Emission Standards for New and Modified Sources
(Submitted December 4 2015)

The Coastal Bend Regional Group of the Sierra Club includes the Eagle Ford Shale play area and thus these proposed changes have a direct impact on me and on our other members.  The facts carefully explained in the November 2, 2015 Comments from Cyrus Rood, Lone Star Chapter of the Sierra Club need not be repeated here, but do warrant careful consideration.

A.  The three main points regarding the gas itself:
1) a valuable resource is being wasted, with the actual amount of methane emissions even higher than the estimates provided by the Texas Railroad Commission.
2) methane is a climate-disrupting gas, adding significantly to climate change.
3) methane has very negative health impacts of immediate importance.
B.  Texas is unlikely to deal with methane emissions on its own.
C.  The need for a strong standard
1) a good first step in addressing methane pollution from the oil and gas industry, as detailed in the Clean Air Task Force, Sierra Club and NRDC joint report, Waste Not, cited in the November 2 Comments.
2) current problems with leak detection and storage tanks
3) capturing gas and routing it to process needs to be the practice to follow in place of venting and flaring
4) recognizing the role that flaring takes in ozone formation, and thus in our economy and human health.

The Coastal Bend Regional Group would like to add that the EPA rules provide certainly for industry, a benefit to industry - and to jobs!  One thing that industry often reports is that they are happy to follow the standards, as long as all involved know the standards; the implementation of objective rules that have a uniform standard will thus benefit industry.

Methane releases, escapes, and flarings within the Coastal Bend Group Sierra Club's​ geographic area reached a new high with the development of the EFS for natural gas and oil production. Not only were exploration, drilling and production sites allowed to belch and flare natural gas for weeks and months on end, but a unbelievable increase in the number of diesel engines, from tractor trailer rigs, to oilfield generators, other oil field equipment, and smaller trucks and cars on the road put an added burden on the hydrocarbons discharged into the air in our region. Add to this the cumulative effects with refineries, and major amounts of traffic on the road what with Texas population growing disproportionately fast compared to the rest of the USA, and we are looking at a catastrophic synergism - where the total polluting effect is disastrously greater than the sum of its individual parts.

The cumulative effect on Texas of Eagle Ford Shale oil and gas plays include, impact and are impacted by these factors about the Coastal Bend area:
1) We have multiple refineries
2) We are part of the fastest growing state
3) We have the 6th largest port in the USA
4 We have a tremendous number of roadways taking drivers (automobiles, farm vehicles, tanker trucks, etc) to diverse and often very distant locations.
5) We have tank farms springing up all over the Eagle Ford Share area and pipelines in planning, under construction and in use.

As noted in the November 2 comment, these proposed rule change will put the state agencies in an unbiased position where the political pressures of permit deadlines and lease agreement time constraints will not dominate over objective rules that benefit the environment, a benefit not to be overlooked.

We are appreciative of the EPA proposed rule changes and look forward to their implementation.

Lois Huff, Chair, Sierra Club Coastal Bend Group