Tell the Department of Environmental Protection: PA Needs Strong Methane Protections

To the Department of Environmental Protection:

The Department of Environmental Protection's (DEP) state plan to implement the Environmental Protection Agency's (EPA) methane rule is an important step forward in protecting Pennsylvanians from oil and gas pollution. It is critical that these protections are in place regardless of changes to the EPA rule at the federal level.

Please guarantee the state plan to implement the EPA methane rule is strong and rooted in the DEP's own authority to regulate methane pollution. Doing so will ensure Pennsylvanians can reap the public health, economic, and environmental benefits of the EPA methane rule. The rule, finalized in March of 2024, would drastically reduce air pollution from oil and gas infrastructure, creating jobs in the methane mitigation industry and improving air quality and public health. Pennsylvania must make sure its state plan will provide the same level of, if not more, protection as the EPA rule and can continue to be enforced even if the federal rule is rolled back. 

Oil and gas infrastructure is known to be highly polluting, emitting significant amounts of pollutants including methane – a potent climate-warming greenhouse gas – and volatile organic compounds. To reduce this pollution, the EPA rule will require monitoring for leaks from wells regardless of size, use of zero-emission process controller devices, elimination of routine flaring at large wells, and creation of a Super Emitter Program. This is a huge step forward in protecting health and the environment, but Pennsylvania can do more. Please ensure the state plan addresses the concerns of Pennsylvania residents living near gas operations by doing the following: 

- Require quarterly instrument-based leak monitoring at all well sites that are not considered complex;

- Include separators – which separate gaseous and liquid components of oil and gas well streams – in the definition of complex well sites, and hold them to monthly instrument-based inspections;

- Ensure quick repair timelines for detected leaks to reduce immediate harms to public health, safety, and the environment;  

- Supplement EPA's Super Emitter Program by engaging with and connecting impacted residents with necessary methane monitoring and health resources and expertise to better protect public health; 

- Create protective standards against flaring of associated gas for wells of all sizes that requires thorough proof that other options are infeasible before flaring is allowed; 

- Submit the state plan proposal as soon as possible, before the 2-year deadline of March 8, 2026. 

I thank the DEP for working on critical protections for Pennsylvania residents from oil and gas pollution. Please make sure the methane rule state plan is rooted in DEP's own authority to regulate methane, so the rule can be tailored to Pennsylvania's needs and will still exist and be enforceable even if the federal EPA rule goes away. A strong state plan can maximize protections to realize and surpass the health and environmental benefits of the EPA methane rule, demonstrating strong Pennsylvania climate and public health leadership.

Thank you.