Miguel Escoto to EPA: Cut oil & gas methane pollution to protect communities & climate

Miguel provided the below comment live to the EPA during its June 15, 2021 methane public listening session to provide input on the rule it will publish this September to cut oil and gas production’s methane pollution.


My name is Miguel Escoto. I’m Earthworks’ West Texas Field Advocate based in El Paso, TX. This gives me a special window as to why the EPA needs to enact the strongest methane rules possible to protect climate and communities. This includes at a minimum a 65% methane reduction by 2025. Over the past year, I have visited oil and gas operations with an optical gas imaging camera that makes visible the normally invisible methane and associated toxic air pollution that an EPA rule would cover. Our evidence is striking. Methane is being pumped into the atmosphere, virtually unchecked by the Texas State Government during an unprecedented decade of climate emergency.

West TX is home to the Permian Basin: the largest oil and gas producing region in the country. Studies show that the Permian emitted at least 275 billion cubic feet of methane last year— enough gas to serve nearly 5 million homes for a year. Even worse, if the status quo is left unchecked, the Permian is forecast to increase its oil and gas production levels. 

The Permian is ground zero for the methane rule under discussion today. So allow me to share three main insights of this region based on my experience on-the-ground

  1. Oil and gas corporations are all talk and no action when it comes to methane reductions. No matter how big or small a company, no matter its promises about clean/responsible operations, it doesn’t change what we see on the ground when we visit: pollution. Even oil and gas behemoths. We’ve seen Shell blast tank emissions, XTO/Exxon venting unlit flares, and BP with dirty, black carbon malfunctioning flares. This gets us to a fundamental principle of methane policy: Oil and gas will not improve unless they are forced to act. EPA, you are that regulatory authority 
  2. Second insight: The two Texas environmental agencies the TCEQ  are failed systems. We have evidence that both of the agencies tasked with regulating oil and gas in Texas and in the Permian are captured by industry or otherwise committed to allow industry to pollute unchecked. Operators enjoy dozens of loopholes that skirt EPA guidelines; unpermitted sites are allowed to pollute for months without repercussion; pollution complaints from the public are chronically ignored. EPA, you need to step up, because Texas won’t regulate. 
  3. Number three: Methane policy is directly related to people’s health, especially frontline communities and climate refugees. My border hometown of El Paso in West Texas has seen thousands of migrants cross to the United States fleeing violence, poverty and climate displacement brought by climate change. The World Bank calculates that over 140 million people, particularly in the Global South and regions like Latin America,  will be displaced from their communities because of the effects of climate change: increased sea levels, desertification, and flooding. Additionally, within the US, more than 12.5 million Americans live close to an active oil and gas site. Forcing industry to reduce methane emissions will save lives. 

In conclusion, given the time we have to avert climate catastrophe, even the strongest rule you issue won’t be enough. We need new laws that will shut down new oil and gas extraction. At the very minimum, this 65% reduction in methane emissions will protect health and planet immediately: it means a 2.3 million metric ton VOC reduction in 2025 and a GHG emissions reduction that is equivalent to the pollution from roughly 175 coal fired power plants. EPA, your decision is simple: You can either decide to protect industry profits or protect human lives. Thank you.