350CO Testimony at EPA hearing Regarding Proposal to Reduce Climate- and Health-Harming Pollution from the Oil and Gas Industry 


Hi, my name is Micah Parkin, Executive Director of 350 Colorado. We’re a nonprofit organization working to solve the climate crisis and to transition to a sustainable future. Thank you for this opportunity to speak today on behalf of our 20,000 members statewide. 

First, I want to express support for EPA’s efforts to reduce pollution from oil and gas development across our nation, especially potent heat-trapping methane emissions. According to researchers from Cornell University, there has been a worrying increase in methane emissions globally over the past decade, which has been traced back to the shale oil and gas industry in North America since fracking began in earnest around 2008.   

For far too long, the fossil fuel industry has been allowed to dump toxic and climate-warming waste into our skies and atmosphere for free and largely unregulated, allowing disproportionately impacted communities and society at large to pay the many costs to their health and safety as their environment has been deteriorated and the global climate has been destabilized. In Colorado, this has resulted in F-grade air quality, severe nonattainment for ozone – with 40-50% of the ozone precursors coming from oil and gas production. We’re experiencing record breaking wildfires and temperatures, floods, drought, pine beetle destruction of our forests, and serious impacts to our economy, especially agriculture and winter sports industries. The longer we allow this pollution to be emitted and accumulate in our atmosphere, the worse these impacts become.

Nations around the globe, including the US, have signed onto global climate agreements that strive to keep global temperature rise below 1.5C to prevent the most devastating impacts of climate destabilization, and the International Panel on Climate Change has made it clear that society must transition rapidly off the burning of fossil fuels, largely within the next decade, to have a meaningful chance of limiting global temperature rise to 1.5C. In fact, for even a 66% chance of staying below a 1.5C temp rise, the IPCC’s 2018 report said we must achieve net neutral GHG emissions around the year 2037. We are in a state of global climate emergency, and the decisions and actions of our leaders and regulators at every level should reflect that reality. It is critical they act responsibly and with the courage that this crisis demands.

We must take all the responsible steps to stop these upstream methane leaks that the EPA is proposing and much more. Please ensure that the direct regulations are as strong as possible – require non-emitting pneumatic controllers, ensure low-producing wells are subject to regulations, require frequent leak detection and repair This should be accompanied by third-party on-site monitoring at every site, with the data available to the local communities online, in real time, as well as frequent aerial monitoring surveys, rather than relying on industry self-reporting of pollution. The industry has proven in Colorado and beyond that it is not capable or motivated to properly self-regulate and report, and we all pay the price, especially fenceline communities, which are all too often low income and communities of color. 

While the EPA’s proposed regulations to reduce GHG emissions from the oil and gas industry are an essential step to reduce the harm the industry is doing, the truth is that until we also begin phasing out permitting the production of these fossil fuels, it is like trying to plug holes in a dike that a flood is overtopping. Those fossil fuels will flow and be burned somewhere, emitting enormous quantities of pollution that is overheating our only planet and destroying lives, ecosystems and many entire species. 

A recent global ‘production gap’ analysis performed by the Stockholme Institute and the United Nations Environment program found that globally, countries plan on producing 120% more fossil fuels by 2030 than can be burned if we are to limit warming to 1.5 degrees Celsius. Limiting warming to 1.5C will require ‘supply side’ limits on fossil fuel production through a managed decline in permitting, in addition to enacting ‘demand side’ policies to reduce fossil fuel consumption and facilitate the transition to renewables. Restricting fossil fuel production by limiting permitting is an effective, administratively straightforward policy approach to improve air quality and address the climate crisis.

The right thing to do at this point in history to be responsible to our children and future generations is for our nation’s leaders to set a moonshot goal of transitioning from fossil fuel production and consumption to renewable energy within the decade, with a WWII-style effort to retool systems and infrastructure toward that goal, instating the incentives and policies necessary to make it happen. 

We urge you to use your positions of power and responsibility to tackle and resolve this crisis – stop the leaks, then stop the flood and the destruction that will follow by stemming the flow. Put the wheels in motion to phase out permitting of fossil fuel production in the rapid timeline that science and social justice demands. Thank you.