May 4, 2020
Dear Chairman Christian and Commissioners Craddick and Sitton,
The first 15 words of the mission of the Texas Railroad Commission are: “Our mission is to serve Texas by our stewardship of natural resources and the environment…” Historically, the greatest success to this end was the Texas Railroad Commission’s elimination of flaring in the 20th century. Today, this critical part of the agency’s mission is unrecognizable.
Thousands of people listened to the April 14 hearing about limiting production. Excessive flaring came up time and again, speaker after speaker, on all sides of this pro-rationing issue, by industry and other interested parties. Texas residents in more than 1,000 comments urged the Railroad Commission to address this pollution. One oil and gas industry insider said that “flaring is the biggest black eye on our industry.”
Yet, last week, the Commission rubber-stamped more flaring permits and seven more are on your agenda on May 5th. The option to do the right thing comes before you at your May 5th hearing. We encourage you to reaffirm Texas’ earlier historical precedent by taking strong action this week to limit production, especially focused on the bad practice of flaring over limits. We also urge you to reject the flaring waivers that are on the agenda.
The only measure you have announced to address flaring so far is a Blue-Ribbon Committee. Not one environmental organization was included in this Committee to develop approaches to flaring. That speaks volumes about how serious this agency is about examining the full range of concerns and solutions.
Commissioners, your predecessors stopped this wasteful practice. History is repeating itself in West Texas. Do not fail to use your power wisely. Please follow their example and fulfill your responsibility to protect our natural resources. By doing so, you can protect the health and lives of many Texans.
Climate change, caused in large part by fossil fuel emissions[i], is wreaking havoc and causing tragedies for Texans as extreme weather events increase in frequency. Science shows that the planet’s warming is an undeniable contributor to extreme weather including ultra-strong hurricanes, tornados, rain bombs, floods. In addition, we experience drought and fires from extreme evaporation during increased and growing numbers of over 100-degree days. Many areas of Texas are looking at possible 100-degree days in the first week of May – a full month earlier than usual.
The science demonstrates that West Texas is playing an outsized role in disrupting the climate. New research from satellite data has found that the Permian emits methane at twice the rate of any other oil and gas fields in the nation.[ii]
The losses from climate change impacts in other parts of the country and the world are incalculable – from the 2019 floods of the Mississippi to fires in California, the Amazon, and Australia. It is now impossible to ignore and we must take steps for our own resiliency in Texas.
In addition to climate impacts, flaring results in toxic air pollution including formaldehyde, benzene, and pollutants that contribute to increased smog, which worsens heart and lung diseases and other health conditions. These pre-existing conditions make people more vulnerable to early death, including from pandemics like Covid-19.
Finally, the direct economic impacts are clear, flaring waste costs our state in lost revenue now and in the future.
We respectfully ask the Railroad Commission to uphold its mission and conserve our state’s resources in the ground rather than allowing drillers to generate waste through flaring and venting. The costs for our climate, our health and the state’s financial resources are too high to continue on our current wasteful and reckless path.
Again, we ask you, Commissioners, take strong action this week and in the future to limit production, especially focused on the bad practice of flaring and to establish a process for changing your policy and rules related to flaring, venting and gas capture over limits. We also urge you to reject all flaring waivers on this week’s agenda.
Isabel Araiza, Ph.D., Founding Member, For the Greater Good – Corpus Christi
Ranjana Bhandari, Chair, Liveable Arlington
Gene Collins, Environmental Justice Chair, National Association for the Advancement of
Colored People (NAACP), Texas
Tricia Cortez, Executive Director, Rio Grande International Study Center
David Foster, State Director, Clean Water Action
Juan Macias, Tribal Chair, Carrizo/Comecrudo Tribe of Texas
Luke Metzger, Executive Director, Environment Texas
James Newsom, Executive Director, Big Bend Conservation Alliance
Frankie Orona, Executive Director, Society of Native Nations
Virginia Palacios, Climate and Clean Air Program Consultant, Green Latinos
Juan Parras, Founder & Executive Director, Texas Environmental Justice Advocacy Services
Cyrus Reed, Interim Director, The Lone Star Chapter of the Sierra Club
Robin Schneider, Executive Director, Texas Campaign for the Environment
Adrian Shelley, Texas Office Director, Public Citizen
Sharon Wilson, Senior Field Advocate and Thermographer, Earthworks
Bill Berg, Associate Director, Save RGV (Rio Grande Valley)
[i] Curbing anthropogenic methane emissions, including those from the oil/gas sector, is considered an effective strategy to slow the rate of near-term climate warming. D. Shindell, J. C. I. Kuylenstierna, E. Vignati, R. van Dingenen, M. Amann, Z. Klimont, S. C. Anenberg, N. Muller, G. Janssens-Maenhout, F. Raes, J. Schwartz, G. Faluvegi, L. Pozzoli, K. Kupiainen, L. Höglund-Isaksson, L. Emberson, D. Streets, V. Ramanathan, K. Hicks, N. T. K. Oanh, G. Milly, M. Williams, V. Demkine, D. Fowler, Simultaneously mitigating near-term climate change and improving human health and food security. Science 335, 183–189 (2012).
[ii] Based on satellite measurements from May 2018 to March 2019, Permian methane emissions from oil and natural gas production are estimated to be 2.7 ± 0.5 Tg a−1, representing the largest methane flux ever reported from a U.S. oil/gas-producing region and are more than two times higher than bottom-up inventory-based estimates. Yuzhong Zhang, Ritesh Gautam,, Sudhanshu Pandey, Mark Omara, Joannes D. Maasakkers, Pankaj Sadavarte, David Lyon, Hannah Nesser, Melissa P. Sulprizio, Daniel J. Varon, Ruixiong Zhang, Sander Houweling, Daniel Zavala-Araiza, Ramon A. Alvarez, Alba Lorente, Steven P. Hamburg, Ilse Aben and Daniel J. Jacob, “Quantifying methane emissions from the largest oil-producing basin in the United States from space”, Science Advances 22 Apr 2020: Vol. 6, no. 17, eaaz5120 DOI: 10.1126/ sciadv.aaz5120, https://advances.sciencemag.org/content/6/17/eaaz5120