U.S. ENVIRONMENTAL PROTECTION AGENCY
                          Zoom Virtual Public Hearing

Public Hearing for the Proposed Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems (88 FR 50282, August 1, 2023)

1:00-5:00 PM
Monday, August 21[st], 2023

List of EPA Panelists:
Julius Banks, Hearing Chair (Groups 1-3)
Mark DeFigueiredo, Hearing Chair (Groups 4-7)
Michael Hanaan
David Lyon
Vasco Roma

Transcription details:
Date:					21-Aug-2023
Input Sound Files:			13284 SubpartPublicHearing ENG_sml.mp4
Transcription Results:
Speaker:
Transcription:
Julius Banks
00:00:01
Good afternoon.  Welcome, everyone.  Thank you for joining the greenhouse gas reporting rule revisions and confidentiality determinations for petroleum and natural gas systems. This is a virtual public hearing.  We will get started here momentarily, so please stay on and we'll be back in just a few seconds.
Julius Banks
00:00:23
Good afternoon, all.
My name is Julius Banks, I'm the chief of the Greenhouse Gas Reporting Branch in EPA's Office of Atmospheric Protection, Climate Change Division, and I will be chairing the session of today's public hearing.  First off, welcome and thank you for joining us virtually.  Before beginning, we'd like to run through a few administrative items.  I'll be turning it over shortly to Kellie Dubay.  She is with ERG, who is helping support today's mission.  Or session.
Kellie Dubay
00:00:56
Thank you.  Hi.  As Julius and our interpreter said, my name is Kellie Dubay.  I'm with ERG.  We are a contractor supporting EPA in this effort.  Before we get started today, I just want to review a few housekeeping items with everyone.  When you logged on you should have seen the statement that stated this hearing is being recorded.  So I just want to make sure everyone is aware.  Closed captions are available for today's presentation.  To turn those on or adjust the setting of the captions, you just have to navigate to the closed caption icon on the bottom of your control panel just right of center.  So you can also select your preferred language by clicking on the interpretation icon at the bottom of your screen.  If you do select the Spanish channel, please click the globe icon and select "mute original audio."

Kellie Dubay
00:01:53

English speakers must also select English.  Our interpreters will also go over this information momentarily.  A reminder that attendees have been muted and your videos are turned off to preserve video and audio quality for today.  Audio is available for this presentation through your computer's mic and speakers, or by telephone.  If during the hearing today you experience any technical difficulties with your computer microphone, you can use your phone by clicking the upward arrow by the mute and unmute buttons in the zoom control panel that's across the bottom of your screen.  After you click the upward arrow, you can choose "switch to phone audio," and then follow the instructions.  And if you experience any other technical difficulties, you can always reach out to my ERG colleagues today by emailing us at<EMAIL_ADDRESS>or if you need to, you can message us in the chat box by directing any questions or technical difficulties that you might have.  Gabby, my colleague, is listed as "Attendee Support."
So any technical issues, find attendee support in the chat box and Gabby will be able to help you out.  We will do our best to troubleshoot issues with you.  So I am now going to pause and give our Spanish interpreter Michele a chance to speak and give any Spanish speakers an opportunity to look at the slides and select the Spanish room.
Kellie Dubay
00:03:29
Thank you, Michele.  So everyone can go ahead and select their appropriate language channel for English speakers, we do need you to please select the English channel.
Kellie Dubay
00:03:42
So we will review the process for speakers to share their comments momentarily.  So everyone go ahead and select your language channel, and I think we'll go ahead and put Michele in the interpretation room, and then we'll continue with the hearing.
Julius Banks
00:04:00
Thank you.
Kellie Dubay
00:04:01
Back to you, Julius.
Julius Banks
00:04:03
Thank you.  As I mentioned, I'm Julius  Banks serving as the EPA hearing chair.  Please note by registering for this event you are agreeing to abide by the ground rules of the virtual event.  That includes rules of behavior.  EPA is committed to an environment of mutual respect and safety.
Julius Banks
00:04:21
The agency will not tolerate harassment, discrimination, intimidation, inappropriate language and images or sustained disruption of the public hearing.  EPA expects all participants including the panelists registered speakers and attendees to conduct themselves in a respectful, professional and civil manner.  We will monitor and moderate this virtual event to ensure that these common standards of decency are upheld.
So again, good afternoon.  Thank you all once again for taking time out of your day to share your comments and participate in today's hearings.  The purpose of today's hearing is to receive comments from interested parties on EPA's proposed rule, Greenhouse Gas Reporting rule:  Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems or Subpart W.  This proposal, which EPA announced on July 6th, 2023, would amend reporting requirements for petroleum and natural gas systems under EPA's Greenhouse Gas Reporting Program.  The proposed revisions would improve the accuracy of reported emissions of greenhouse gases, including methane, from applicable petroleum and natural gas facilities consistent with the Methane Emissions Reduction Program under the Inflation Reduction Act.  We are conducting this hearing under section 307(d) of the Clean Air Act to provide interested parties an opportunity for oral presentation in addition to written submissions on the proposed rulemaking.  A written transcript of this hearing will be made available electronically on EPA's website, and at regulations.gov website under the docket for this rulemaking, which is docket number EPA-HQ-OAR-2023-0234.  The official record of this hearing will be kept open for more than 30 days after the date of the hearing to provide an opportunity to submit rebuttal and supplemental testimony.  You may submit this additional testimony to the same docket for this action by using one of the methods described in the Federal Register notice announcing the proposal.  We ask that each person limit their verbal testimony to 4 minutes, given the number of testifiers for today, we'll need to hold speakers to that time limit.  Our contractor, ERG, will be facilitating the lineup of speakers and helping to keep testimony to 4 minutes.  We'd appreciate all of your cooperation in allowing us to give everyone an opportunity to speak today.  When you are finished with your comments, members of this panel may ask clarifying questions.
This hearing is not intended to be a decision of the proposed rulemaking.  While we might ask questions for request additional data or supporting materials, we will not respond to comments in this forum.  Instead, we'll provide a written response to comments as part of the process of finalizing this proposed rulemaking.  Remember, you can continue to submit your comments on this proposed rule through October 2nd of 2023.  EPA considers all comments, whether submitted to the docket or given orally, equally.  Please refer to the docket number on the screen when you submit your comments.  The details on where to submit written comments can be found in the Federal Register Notice announcing the proposal as well as on our website.  We encourage you to also submit a written copy of the testimony that you provide today.  We will also produce a written transcript of today's hearing.  And we will add that transcript to the public docket for this rulemaking.  I would like to ask that the other EPA panelists turn on cameras and introduce themselves.
Michael Hannan
00:08:24
Hi.  My name is Michael Hannan.  I'm an Environmental Engineer in the Office of Atmospheric Protections, Climate Change Division.
Vasco Roma
00:08:34
Hi.  My name is Vasco Roma.  I'm an Environmental Protection Specialist, also in the Climate Change Division.
David Lyon
00:08:43
David Lyon, I'm a Special Adviser for implementation in the Climate Change Division.
Mark DeFigueiredo 00:08:48
And Mark DeFigueiredo, I'm team leader in EPA's Climate Change Division.
Julius Banks
00:08:55
Thank you all.  There will be a short recess later in the public hearing, and during that time, my colleague, Mark DeFigueiredo, will assume the role of the EPA hearing chair, and David Lyon will join as an EPA panelist.  They will re-introduce themselves again after the recess.  Before we begin, I'm pleased to introduce Sharyn Lie, Director of Climate Change Division in EPA's Office of Atmospheric Protection.  She will provide some opening remarks.  Sharyn?
Sharyn Lie
00:09:34

Thank you, Julius.  Welcome, everyone.  My name is Sharyn Lie, and I am the Director of the Climate Change Division in the Office of Atmospheric Protection.  I want to thank you for taking the time to comment on the proposed rule to revise the reporting requirements to petroleum and natural gas systems, otherwise known as Subpart W, under EPA's greenhouse gas reporting program.  In August of 2022, Congress passed and President Biden signed the Inflation Reduction Act into law, which amended the Clean Air Act to add section 136 to reduce methane emissions from oil and gas systems.  Consistent with the Methane Emission Reduction Program under the Inflation Reduction Act, the proposed revisions in this proposal would improve the accuracy of reported emissions of greenhouse gases, including methane, which as many of you know is one of the primary drivers of this climate crisis, from applicable petroleum and natural gas facilities. EPA's proposed amendments to the Subpart W of the Greenhouse Gas Reporting Program would address gaps in the total methane emissions reported by facilities by adding several new covered sources such as other large release events which would capture abnormal methane emission events not fully accounted for using existing methods.
Proposed revisions would also leverage advancements in technology including the use of new technology such as remote sensing for identifying or quantifying emissions from other large release events.  The amendments would also collect data at a more granular level to improve verification and transparency of the data collected.  The data that would be collected through this action would provide an important data resource for communities and the public to understand greenhouse gas emissions.  Again, thank you for your time, and I will now turn it back over to the hearing chair, Julius Banks.
Julius Banks
00:11:19
Thank you, Sharyn.  That concludes our background remarks.  It's now time to begin the public comment portion of this hearing.  So we will now have Kellie Dubay, the facilitator from ERG, review the public comment process with everyone.
Kellie Dubay
00:11:36
Great.  Thank you, Julius.  All right.  So we just want to go over speaker order first.  Most of you should know this who have already been preregistered, our preregistered speakers have been assigned to a group number and a general time slot.  These groupings will appear on the screen as we proceed, so everyone participating will know the speaker order for each of the groups.  If a registered speaker is not available at the time that they're called on by the hearing chair, the hearing chair will move to the next person on the list.  If a registered speaker who was not present when called to speak subsequently joins the hearing, we will fit them in at the end of the group, if possible, if we have time that allows and hopefully we will, and then if a speaker doesn't show up, we may have additional time, and in that case, we will go ahead and include anybody who may have requested an opportunity to speak, but didn't get assigned a preregistered time slot.  If anyone who is participating as an observer today would like the opportunity to speak and didn't preregister, you can always email us at<EMAIL_ADDRESS>any time throughout the hearing.  We will be checking that email frequently, and that will give us an opportunity to add you to the list and call your name after we go through the list of registered speakers.  If we have space at the end of a group, or towards the end of the hearing.  And as Julius mentioned, we will be taking a short recess after the group 3 speakers to change the hearing chair and just give everyone a break.  Okay.  So now let's go over speaker process.  For those of you that preregistered to speak today or may request time, the EPA hearing chair will call your name when it's time for you to share your comments based on the list of registered speakers that have been received.  When the chair calls your name, what will happen is my colleague, Gabby, will promote you to a panelist on zoom.  There will be an invitation that you'll see, and you'll need to accept that invitation to be a panelist when it pops up on your screen.  This is going to give you the ability to unmute yourself using your own unmute button in the bottom left of your menu bar.  And turning on your camera will be optional.  For those of you who may be preregistered and are participating via phone, when the EPA hearing chair calls your name, please press star 9 and that will raise a digital hand for us to let us know that you're here.  And at that time, you can press star 6 to unmute and to speak.  Everybody who provides testimony today will have 4 minutes to provide comments.  There will be a little timer that pops up at the bottom of your screen and everyone will be able to follow along with that timer.  If you are testifying by phone, however, I will have to give you a verbal alert when you have a minute remaining.  And to be fair, we're going to really enforce that 4-minute limit.  So when you have about 30 seconds left, try to wrap up if possible.  We are going to ask that you please remember to speak slowly, even slower than I'm speaking now, and clearly for our interpreters. You met Michele, she has a colleague working with her, and we have a closed captioner today who is also providing the closed captions.  So those are real people working for us today to make sure that we have accessibility, and so we just need everyone to be really aware of speaking slowly and clearly.  The interpreters and the closed captioner may send the team a message to ask the commenter to slow down.  Unfortunately, if I receive one of those messages, I may have to just sort of pop in and remind you to slow down, so I apologize in advance if that happens.  When it's your turn to speak, please start by providing your name and if you would like also your affiliation.  And as the hearing chair previously mentioned, I will let you know when your 4 minutes is up and we will ask you to end your comments and we'll move on to the next speaker.  So hopefully that's clear to everyone.  We'll get into a pattern shortly as a group, and with that, we're going to go ahead and put the slide up for speaker group 1, and Julius, I just wanted to let you know that all of our speakers in speaker group 1 are present today, so we should be able to move through this group.
Julius Banks
00:16:33
Thank you, Kellie.  All right, we will get started with the comment portion of the hearing.  So first up is Lindsey Koehling.  Lindsey, are you ready?
Kellie Dubay
00:16:50
It may take a moment, Julius, for them to be able to unmute.
Julius Banks
00:16:57
I just received a message that she did not intend to speak, although she is indicated.  So I guess we can go to the second speaker, and that speaker is Monica Prabhu, if Monica is available.
Monica Prabhu
00:17:23
Thank you.  I think that I'm on now.  So I originally wanted to add my thoughts and comments in my role as the Commercialization Officer at Prabhu Energy Labs.  However, I'd also like to expand that to being a private citizen and someone that's been following along with the process.  I appreciate very much the EPA's work on this matter, and I want to acknowledge that although the public comment period is open until October, as of right now, the number of public comments that have been lodged in writing are very few.  As far as I can tell, they're nearly all from the oil and gas industry, except for Project Canary.  And I'd like to echo Project Canary's written remarks and ask for an extension to the public comment period because this is an extremely important, highly technical, complex proposal that has policy implications that are far-reaching.  As a nontechnical person myself, I think I misunderstood exactly what those policy implications may be and the science behind the empirical inventories are just a very complex topic.  So I want to acknowledge the work that the EPA is doing and thank you for that, and also to echo Project Canary's request for an extension.  A number of groups I would like to see comments from have not lodged them yet, so I'll be watching for that, including the Environmental Defense Fund, the Clean Air Task Force, IGSD among them.  If you have not received comments from these groups, I hope that the EPA can reach out to them and receive comments, as well as state air and environmental regulators from California, Colorado, New Mexico and others.  I'd like to see their comments, and hopefully between now and October, we will see that.  A question that I have that I'd like to see addressed is the issue of GWP 100 continue being the factor for which all greenhouse gases are being computed, including short-lived climate pollutants such as methane, and I would like to see a very clear layman's explanation as to why GWP 100, as in the 100-year impact, is being -- continuing to be used despite the new information that we have about the importance in the next 10 years if not 20 years.  So I know it's complicated and I'd like to see better explanation as to why that continues to be the inventory factor, and I will end my time here and just thank you all again for the work that you're doing.  Really appreciate it.
Julius Banks
00:20:47
Thank you, Monica.  Really quickly, it's not uncommon for us to receive a large number of comments late towards the end of the comment period, so that's almost to be expected.  Your request for comment extension, feel free to contact us in writing if you choose to do so with that request.  And there is a separate rulemaking that you may be unaware of that addresses the 100-year GWP.  That rulemaking is being issued under Greenhouse Gas Reporting Program technical amendments.  Information about that rulemaking is available on our website.  Any of the panelists have questions or comments for Monica?  All right, thank you, Monica.  Moving on to the third commenter, third speaker, Asa Carre-Burritt, and apologies if I'm mispronouncing your name.  Asa, are you available?
Asa Carre-Burritt
00:22:13
Yeah, here I am.  Thank you.  So first I wanted to thank the organizers of this hearing for the opportunity to provide testimony for the proposed rulemaking.  My name is Asa Carre-Burritt, and I'm the Director of Policy and External Affairs at Bridger Photonics.  Our company serves the oil and gas industry by providing actionable data for methane emissions based on laser-based remote sensing measurements taken from airplanes and helicopters.  The subject rulemaking has the potential to significantly impact the oil and gas industry's approach to methane emissions management.  Therefore, we urge the EPA to make sure that the final rule incentivizes operators to find emission and does not penalize operators for detecting and reporting emissions.  The EPA is proposing many amendments to incorporate additional empirical data in emissions reporting for the purpose of improving accuracy. Bridger is in support of providing operators with the option to use empirical data for emissions reporting.  In this statement, we would like to draw the EPA's attention to our specific concerns with reporting for the proposed other large release events source category.  Reporting for this category is based on the best available information, notably this includes information from OGI surveys or advanced methane sensing technology that may be deployed to achieve regulatory compliance under OOOOb.  Relying on operator funded LDAR programs as a key element for reporting under this source category gives rise to several issues.  For example, reporting could be inconsistent depending on the technology that is deployed because in practical application, methane sensing technologies can have significantly different coverage of emissions.  Because Subpart W reporting will be tied to the waste methane emissions charge, if provisions are finalized in their current form, there's now clear disincentive for comprehensively characterizing emissions using the best available technology.  The improved detection of emissions would be penalized with the potential for additional charges.  This is a major issue considering the potential importance of this source category.  In addition, we are not aware of a clear methodology to make sure operators have collected enough information to ensure accurate reporting of large release events.  Instead of relying on operator-funded LDAR programs and the Super Emitter Response Program to determine the presence of many of the emissions subject to the other large release event reporting, we encourage the EPA to finalize rules that leverage an optimally systematic approach to assessing total emissions.  This can be achieved by considering basin wide measurement.  Empirical measurement across production basins can be used to develop basin specific emission factors for equipment.  This approach provides a reliable back stop for emissions reporting and a level playing field for operators.  The technology is already available to characterize basin emissions at the equipment scale with defined uncertainty.  In addition to implementing a more systematic approach to evaluating total emissions, we also urge the EPA to provide operators with a pathway to demonstrate improved performance relative to basin norms.  This can be accomplished through measurement protocols executed at the operator scale such as those that may be developed based on the Veritas protocol.  With that I want to thank you and I'd be happy to take clarifying questions.
Julius Banks
00:26:06
EPA panelists, any questions for Asa?  All right.  Thank you very much, Asa.  Let's move to the fourth speaker, Edwin LaMair.  Edwin LaMair, are you available?
Edwin LaMair
00:26:37
I am on.  Thank you, Julius, and thank you, EPA.  My name is Edwin LaMair.  I am an attorney at Environmental Defense Fund.  Thank you for the opportunity to provide input on EPA's proposed updates to Subpart W of the GHGRP under the Methane Emission Reduction Program.  Avoiding the most catastrophic consequences of global warming requires limiting the world's temperature rise to 1.5 degrees Celsius.  Doing so requires dramatically cutting greenhouse gas emissions.  The GHGRP and Subpart W is a fundamental underpinning of U.S. climate policy.  Understanding the sources of emissions is critical for informing approaches to mitigation.  And ensuring the accuracy of information reported through the GHGRP is necessary for achieving the Biden administration's commitment to reducing domestic greenhouse gas emissions by 50 to 52% over 2005 levels by 2030.  EDF strongly supports updates to Subpart W and we urge EPA to strengthen key provisions.  In adopting the Methane Emission Program, Congress recognized the importance that accurate and empirically based methane reporting would have effectuating the methane waste emissions charge.  That is because the waste charge is only assessed on methane emissions reported to EPA through Subpart W.  If that reporting is not accurate and does not capture all of the emissions actually occurring, then the waste charge will not be as effective in incentivizing reductions as Congress intended.  There are three components of the directive to update Subpart W included in Clean Air Act section 136(h).  The first is that reporting be based on empirical data, the second is that reported emissions accurately reflect the total methane emissions from reporting facilities, and the third is that owners and operators of reporting facilities be allowed to submit data in a manner to be prescribed by EPA.  EPA's proposed updates to Subpart W include important improvements to enhance the accuracy of reported emissions.  These include the reporting of large release events and new emission factors based on recent measurement studies.  We strongly support these updates, and we urge EPA to further strengthen reporting requirements in the final rule by more comprehensively incorporating measurement data, including from aerial observations, accounting for intermittent emissions through statistical methods, and providing clear guardrails for operator measurement and self-reporting.  Specifically, we hope to see EPA integrate top-down basin-level data into the reporting program.  This data can provide a full picture of total emissions in a region or basin, allowing for comparison of reported emissions to ensure accuracy with basin-level totals.  Second, we hope to see EPA ensure robust statistical analysis and methods are finalized that account for intermittent emissions that may be missed during observations or one-time measurements.  Third, EPA should clearly define guardrails and require independent verification of any self-reported measurements from companies to ensure that companies are accurately representing their operations and not selectively choosing unrepresentative sites.  Auditing and reporting emissions will also be important for ensuring accuracy after emissions have been reported to EPA.  Thank you for the opportunity to provide input on this important program, and for moving forward to implement the Methane Emission Reduction Program, a key pillar of the Inflation Reduction Act.
Julius Banks
00:30:44
Thank you, Edwin.  Good to see you and apologies for mispronouncing your name.
Edwin LaMair
00:30:49
No problem.
Julius Banks
00:30:50
EPA panelists, any questions or comments for Edwin?  Very good.  Thank you again.  All right.  Our fifth speaker, Don Schreiber.
Don Schreiber
00:31:34
Yes, thank you very much for the opportunity to be here.  Hello again.  My name is Don Schreiber from the Devil Springs Ranch.  I'm in the other famous basin in New Mexico, the San Juan basin in the northwest corner of our state.  We're home to 30,000 gas and oil wells, major gas processing facilities, compressor plants and stations, thousands of points where methane can and does occur in emissions.  And we have the infamous methane hot spot over our heads to prove it.  We're surrounded by 122 gas wells on and near our ranch. Thirty-three of those are within a mile of our home and 10 of them you can see from our front yard.  So I've offered my comments to you in the past many times over the years, and every time I'm telling you about what I'd seen daily here on the Devil Springs Ranch for the last 23 years and still see today.  When I comment, I'm speaking on behalf of front-line families like mine who most often suffer the effects of methane pollution that finds its way on to our doorsteps and into the faces of those of us most vulnerable to methane pollution, like the elderly.  My wife and I are in our mid-70s.  Like the very young, we have 10 grandchildren.  And like those already suffering from pre-existing health conditions.  You have already heard and will hear again comments regarding potential positive results for the Greenhouse Gas Reporting Rule and the Methane Emissions Reduction Program that's the subject of today's hearing.  GHGRP and MERP are full of opportunities to make a direct impact on front-line communities like ourselves and to help prevent further methane pollution that is so devastating to our climate.  But for those of us who live with the impacts of oil and gas every day, it is our obligation to speak out about operators who do not always follow the rules, no matter how well intended or written they are.  Unfortunately, for us here in the San Juan basin, the dominant operator is Hilcorp Energy of Houston, Texas who, according to analysis of your 2021 methane emission data, is the largest methane polluter in the United States, despite the fact that they are only 13th in overall methane production.  GHGRP and MERP are only going to be as good as the self-reported company data is.  And EPA must be vigilant that companies will report in the interest of methane reductions, not in their own self-interest.  When New Mexico was writing its own methane waste and emission rules, New Mexico Oil Conservation Director Adrian Sandoval said some companies live within the exceptions, not the rules.  After so many years of state and federal efforts to reduce methane pollution, we cannot let the opportunities that GHGRP and MERP present be lost because of oil and gas operators that seek to profit at the expense of front-line communities and at the expense of a climate changing so dramatically for the worse.  Thank you very much.
Julius Banks
00:35:24
Thank you, Mr. Schreiber.  Any comments, questions from EPA panelists?  All right, thank you again, sir.  Let's move to Morgan King.
Morgan King
00:36:10
 Thank you for the opportunity to comment.  My name is Morgan King.  And I am the Climate Campaign Coordinator at the West Virginia Rivers Coalition.  I was born and raised in Charleston, West Virginia and after living away I found my way back home to advocate for a livable future for West Virginians.  No one should have to worry if air they breathe is safe or if climate disaster will take their home or business.  As the climate emergency worsens, it is more important than ever to rapidly reduce greenhouse gases to avoid the worst impacts of our warming world.  The West Virginia Rivers Coalition supports the EPA in proposing updates to Subpart W of the Greenhouse Gas Reporting Program.  Including improvements to enhance the accuracy of reported emissions from the oil and gas industry.  Cutting methane emissions and other greenhouse gas emissions within the oil and gas sector is the quickest and most impactful way to limit global warming, given how potent methane is as a greenhouse gas.  Appalachians and West Virginians are among the most at risk due to the many active and abandoned oil and gas wells in the region.  Over half of West Virginians live within half of a mile of an active gas and mile well. Also, there are approximately 6500 abandoned and orphaned oil and gas wells in our state leaking methane.  As a region, Appalachia has over 180,000 low producing oil and gas wells responsible for half of all well site methane pollution in the country, and the region, with the highest concentration of these sites.  My own county, Kanawha County, has over 3,000 of these types of wells in my home state, which is the highest number of wells in a single county in the state.  Needless to say, pollution from the oil and gas industry is a problem in West Virginia.  West Virginians have dealt with the brunt of pollution and cumulative impacts for too long from extractive industries.  Given the high concentration of oil and gas operations in West Virginia, there is an increased health impact here.  The volatile organic compounds released alongside methane during operations worsen respiratory disease, increase the risk of cancer and cardiovascular disease.  West Virginia ranked first in the nation in the prevalence of heart attack and coronary heart disease and has the second highest cancer mortality rate.  With an overall aging population, this puts our West Virginians at an even greater risk from these pollutants.  We support the following proposed changes in Subpart W by EPA on large release events, updated emission factors, and equipment malfunctions.  We support the proposal to require reporting of other large release events because these emission events are not currently reflected in Subpart W reporting and some are extremely large.  Because most operators calculate their emissions using EPA's default assumptions for pollution from different types of equipment, it's critical that these emission factors accurately reflect real pollution.  We support EPA moving toward major equipment-based emissions factors that use recent real-world data adjusted for infrequent large emitters.  These improved emission factors will better capture intermittent emissions and provide more accurate reporting for simplifying calculations.  And finally, we support EPA's proposal for multiple changes that would require operators to report higher emissions when they discover malfunctioning equipment.  West Virginia Rivers would like to suggest a few recommendations including more comprehensively incorporating measurement data, accounting for intermittent emissions with statistical methods, and providing clear guardrails for operator measurements and self-reporting.  We urge EPA to finalize other improvements it's proposed to enhance the accuracy of emissions including requirements to report large release events and new emission factors based on recent measurement studies.  Thank you for your time.
Julius Banks
00:40:21
Thank you, Morgan.  Any questions or comments from EPA for Morgan?  All right.  Our last speaker in group 1, Alice Lu.
Alice Lu
00:40:58
Hi, everyone.  I'm Alice Lu, the Policy Coordinator for Clean Air Council, a non-profit working across Pennsylvania to improve air and water quality.  I thank the EPA for updating the Greenhouse Gas Reporting Program for the oil and gas sector, and for holding this hearing.  The United States oil and gas industry produce what is equal to 312 million tons of carbon dioxide in 2021.  That's equivalent to driving 70 million gas-powered cars for an entire year.  Methane, a potent greenhouse gas, is a major pollutant emitted by this industry and is often released alongside other toxic and carcinogenic air pollutants. Reducing emissions would tackle the climate crisis and protect the health of Americans.  While the proposed update has several notable improvements, the rule can still be strengthened, so first , the reporting and methane emissions charge thresholds of 25,000 metric tons of CO2 equivalent should be reduced to 10,000 metric tons of CO2 equivalent as originally proposed in draft legislation.  This would promote accountability and accuracy without being prohibitively strict, so in Pennsylvania, for example, lowering the threshold would only increase the number of reporting facilities from 53 to 57 by 2021 reports.  But this would account for an additional 100,000 metric tons of CO2 equivalent.  The EPA should also require continuous optical gas imaging or OGI for all affected facilities with required reporting of data from OGI inspections necessitated by EPA's forthcoming methane rule.  Stationary OGI is a very simple process of surveying the facility with a specialized infrared camera that shows gas leaks on a screen.  This would allow for more frequent and accurate data that could help catch super emitter incidents more quickly.  The EPA should also lower the super emitter event reporting thresholds.  There are two proposed limits currently, a total of 250 metric tons of CO2 equivalent or an instantaneous methane emission size of 100 kilograms an hour.  However, a methane leak of 100 kilograms an hour would exceed the total threshold within a week without regular checks in place.  The instantaneous methane emission size must, therefore, be reduced to 14 kilograms an hour.  A leak of this size instead would take about a month for it to exceed the total emissions limit, allowing for more time to find and fix leaks.  When these super emitter events do occur the EPA should require operators to repair the leak as quickly as possible, within five days, report monthly emissions going forward, submit a compliance plan to prevent future incidents and test after the leak to show it's been addressed. Monies from the Methane Emissions Reduction Program should be allocated towards validating and implementing fence line air monitors to track methane emissions at affected facilities or any that experience a super emitter event, especially when they're located in environmental justice communities.  The EPA must also utilize top-down approaches such as aerial monitoring to detect and quantify super emitter events.  These events generally lack empirical emissions factors so they're difficult to calculate and aerial monitoring can instead measure emissions when they do occur.  And finally, data from all facilities including those affected under the proposed revisions to onshore oil and gas production, gathering and boosting industries should remain publicly available and accessible.  Ensuring that the proposed update effectively accounts for total greenhouse gas emissions will be crucial for tackling the climate crisis and protecting human health.  Thank you all today for considering these comments.
Julius Banks
00:44:56
Thank you, Alice.  Any comments for Alice from the EPA panelists?  Thank you again.  I'm giving the time check.  We are 8 minutes to the hour.  I'm going to suggest that we move on to our group 2 commenters.  All right.  We will start with Lisa Beal.  Go right ahead, Lisa.
Lisa Beal
00:45:50
Great.  Thank you so much.  Hi, my name is Lisa Beal and I'm an Environmental Projects Adviser with BHE GT&S which is an interstate natural gas transmission storage company, headquartered in Richmond, Virginia.  We have operations in 10 states.  GTS is a standalone subsidiary of Berkshire Hathaway Energy.  We operate around 5,400 miles of transmission pipeline in the eastern U.S., and 756 billion cubic feet of total natural gas storage.  We also operate the Cove Point LNG import-export facility in Lusby, Maryland which has daily send out capacity of about 1.8 billion cubic feet.  Today I'm actually speaking on behalf of the Interstate Natural Gas Association of America in my capacity there as the co-chair of INGAA's Greenhouse Gas Task Force. INGAA has a long history of offering hopefully thoughtful and constructive written comment on the Subpart W program and we plan to do the same for this proposal.  But for now, I'd like to offer just a few of our initial thoughts.  I think first consistent with the Inflation Reduction Act mandate, IGNAA supports the development of amendments to the GHGRP Sub-W that incorporate more empirical data. INGAA generally believes operator should have the option to use measured data or other methods in Subpart W.  This proposal adds those options or adds options to use measured data which we fully support.  As an example, to estimate exhaust emissions, exhaust methane emissions from natural gas combustion, operators can use emission factors, company test data, or vendor data.  INGAA also supports adding that flexibility to include measurement options at the operator's discretion.  However, in some cases, the rule is also too limiting or measurement requirements are unnecessarily burdensome and I'll give you a couple examples of those.  Crank case vent emissions reporting is added or is proposed to be added for compressor stations in underground storage facilities.  That estimate requires the use of an emissions factor and does not include an option to use measured data.  It's unclear to us why that proposal or why this proposal would limit the use of measured data when it certainly can be collected.  Another is pneumatic device emissions which are relatively insignificant for the T&S segment, but the proposal adds ongoing annual measurement of the pneumatic device vent rates, typically for all pneumatics located at T&S facilities.
Lisa Beal
00:48:33
The empirical evidence currently available which is pretty extensive clearly shows the minor contribution of these emissions to the overall transmission and storage sector emissions.  As such, we believe the rule should include less frequent measurement or a simplified pathway for developing improved emission factors for transmission and storage pneumatics based on the amount of measured data.  The proposed updates to leak survey leak emission factors for transmission and storage is based on data from upstream operations, without detailing why the existing transmission and storage data was inadequate.  And the ability to develop company-specific emission factors based on measured data really should be streamlined and simplified.  The proposed threshold for large release events, we believe, is too low.  Since the 250 metric tons of CO2e emissions don't really constitute what has been called a super emitter.  The proposal refers to large release events as super emitters, but really the two are not the same.  A super emitter is a term of art that's been used to describe releases such as the Aliso Canyon event which was magnitudes higher than the proposed threshold for large release event.
Kellie Dubay
00:50:01
Lisa, this is Kellie.  I just want to let you know your time is up if you want to just make a concluding statement to EPA.
Lisa Beal
00:50:10
Sure.  Thank you so much.  I apologize for going over.  I just wanted to say that we are developing our comments and written comments on this and I would just like to echo a few of the other speakers who have already said that additional 60 days extension time would be very helpful because this is a very important and impactful regulation.  So thank you very much and I appreciate your time and apologize for going over.
Julius Banks
00:50:38
That's fine, Lisa.  Thank you very much.  Any comments or questions from our EPA panelists for Lisa?  All right, Ms. Beal, thank you once again.  As I had stated earlier, feel free to provide any written requests that you may have for an extension to the comment period.  All right.  Moving to the second speaker, Jessica Moerman.
Jessica Moerman
00:51:14
Good afternoon, and thank you for this opportunity to give comment.  My name is Dr. Jessica Moerman, President and CEO of the Evangelical Environmental Network.  I'm a climate scientist, a pastor, and a mother of two young boys who bring joy and light into my life.  I speak to you today from my capacity and experience in all three of these roles.  First, I want to thank you on behalf of my children for taking methane pollution seriously.  Medical research shows that children are among the most at risk for developing life-threatening conditions from exposure to fossil fuel pollution, and that fossil fuel combustion is a leading environmental threat to children's health.  Many studies link living in proximity to natural gas development and methane production to birth defects, including to the brain, spine, and spinal cord, and to lower birth weight.  As an evangelical pastor, I take seriously what the bible says in Proverbs 13:22, that it's our duty to leave a good inheritance to future generations.  Birth defects and severe health complications are no inheritance to leave to our children.  The good news is, is because of methane's significantly stronger warming punch and shorter lifespan in the atmosphere, reducing methane emissions is the fastest way to slow global warming while defending the health of all God's children.  However, with inadequate monitoring and reporting of methane emissions and leaks, we face what former defense secretary Donald Rumsfeld referred to as a "known unknown."  We know that leaks are out there, but we don't know where and how much.  At EEN, we support the proposed changes to Subpart W for accounting for the reporting of large release events; the move towards major equipment-based emission factors that use real world data and adjusted for infrequent large emitters; and multiple changes that would require operators to report higher emissions when they discover malfunctioning equipment.  However, there are many ways that the rule can and must be strengthened to eliminate these deadly dangerous and wasteful "known unknowns."  Specifically, EPA should integrate top-down basin-level measurement data which provides a full picture of total emissions in a region or basin, strengthening the overall accuracy of reported emissions.  Studies based on observed measured emissions at the regional level show that current emission inventories are underestimating methane pollution.  EPA should also ensure robust statistical analyses and methods that are finalized to account for intermittent emission events, which may be missed by individual one-time measurements or not detected during observations.  EPA should define guardrails and require independent verification of self-reported measurements from companies to ensure any company-reported data accurately represents emissions and is not limited to unrepresentative sites or equipment that typically have lower emissions.  Now unfortunately, and respectfully, as a mom I've found that the honor system does not always work and industry self-reporting at times may be as accurate as my 8-year-old son self-reporting how many cookies he ate while I wasn't looking.  The technology and innovations required for robust and full methane monitoring is available and at hand.  I urge the EPA to help the industry be better stewards of our precious natural resources and the good neighbors to nearby communities and the world by incorporating these improvements in monitoring.  I thank you for your work, I thank you for this rule and the opportunity to provide comment.  Thank you.
Julius Banks
00:55:07
Thank you.  EPA panelists, any questions or comments for Dr. Moerman?  Thank you again.  I believe our third speaker, Antoinette Reyes, is joining us by phone.  Antoinette, if that's the case, you can hit star 9 on your phone to let us know when you are ready.  We'll give her a couple seconds to see if this goes through for her.
Kellie Dubay
00:55:59
I didn't see a hand go up, Julius, if you want to continue.
Julius Banks
00:56:07
All right.  Well, we'll continue to the fourth speaker then.  Luke Metzger.
Luke Metzger
00:56:27
Oh, hello.  I'm the Executive Director of Environment Texas, we're a non-profit advocate for clean air and water, parks and wildlife, and a livable climate with about 30,000 members and supporters here in Texas.  To avoid the worst impacts of global warming, we must drastically cut climate pollution, but we can only do that with the best data on where the pollution is coming from and how much.  So these changes to Subpart W are critical to preserving a livable climate.  Texas is ground zero for global warming.  We're both the top polluter and home to some of its worst impacts; according to an analysis by the Texas Tribune, in the last decade here in Texas, there were 1,000 more days of record-breaking heat than a normal decade, and that's had deadly consequences.  Last year, at least 300 people died of heat-related causes.  Scientists have estimated that the persistent dangerous heat that we're experiencing was made at least five times more likely by climate change.  So, cutting pollution and accurately measuring that pollution will save lives.  Industry is the largest source of climate pollution in Texas with petroleum and natural gas systems making up about one fifth of reported industrial emissions.  But the studies show, of course, that current emissions inventories are underestimating the methane pollution and the oil and gas companies know it.  A report last year from the House Committee on Science, Space, and Technology found that the company's own internal data show that their methane emissions in the Permian Basin are likely significantly higher than official data.  In particular, large release events which can make up most of total methane emissions are not currently reflected in Subpart W reporting.  A 2021 survey of the -- aerial survey of the Permian conducted by Carbon Mapper found 533 methane super emitters.  According to the Associated Press, one of those was the Mako compressor station which was observed releasing as much methane as the climate equivalent to burning seven tanker trucks full of gasoline every day, but the total reported emissions to the EPA in 2020 by the company that operates Mako from all of its boosting and gathering operations combined were just 1/12th of what Carbon Mapper documented billowing from that Mako site alone.  So we strongly support EPA's proposed reporting updates, including requiring reporting of other large release events, updated emissions factors to accurately reflect real pollution, and changes that would require operators to report higher emissions when they discover malfunctioning equipment.  We also urge the EPA to strengthen the final rule, including by integrating top-down basin-level measurement data such as from continuous air monitoring, reducing the current reporting limit in methane emissions threshold of 25,000 metric tons of CO2 equivalent to 10,000 metric tons, requiring continuous optical gas imaging for all affected facilities, and requiring operators that have a super emitter event to repair the leak as soon as possible.  Thank you so much for the opportunity to speak.
Julius Banks
00:59:57
Great.  Thank you.  Any questions or comments from EPA for Luke?  Thank you again.  Let's move on to the fifth speaker, Laurie Anderson.
Laurie Anderson
01:00:38
Hi.  My name is Laurie Anderson, and I'm a Field Organizer for Moms Clean Air Force.  I live in Broomfield, Colorado.  Thank you for this opportunity to share with you today.  At Moms Clean Air Force, our mission is to protect children from air pollution and climate change.  We envision a safe, stable, and equitable future where all children breathe clean air.  As you are aware, as part of the Inflation Reduction Act, Congress directed the EPA to update the requirements for the Methane Reporting Program to include empirically collected data to ensure the accuracy of total reported emissions.  Colorado has been a national leader in fighting climate change by adopting strong policies to cut methane emissions from the oil and gas sector.  Just recently, the Colorado air quality control commission finalized a rulemaking on reporting emissions for the GHG intensity verification rulemaking as we move toward direct measurement since pollution is often underreported.  After so many years of basing pollution on calculated estimates, we will finally have critical measured data so the state and the industry can make better informed decisions on how to truly reduce pollution and hit our state's target GHG reductions.  This rulemaking had unanimous support, including support from the industry.  The protocols are still being developed, but we know that top-down basin-level data provides a broad view of total emissions in the region, while site-level data can provide insight at a local level and combined will improve and enhance our understanding of reported emissions.  As a mom of five kids living about a half mile from a large-scale oil and gas development site which is now in production, I realize just how unfortunate it is that operators have been allowed to estimate the pollution coming from their sites for so long.  However, it is not too late to move forward on a better path.  The EPA can and should further strengthen reporting requirements in the final rule by more comprehensively incorporating measurement data, including from aerial observations, account for intermittent emissions with statistical methods and provide clear guardrails for operator measurements and self-reporting.  Ideally for sake of our children's health and our climate's health, we would strive for zero pollution.  However, as these comments relate to the Methane Emissions Reduction Program, which cuts methane from oil and gas operations through a charge on wasteful pollution, it is critical that the amount of pollution is verifiable so the MERP waste charge is assessed on the true volume of pollution created by the oil and gas industry and, through this charge, operators are further compelled to reduce wasteful emissions.  Nothing less than our air, our climate and our families are at stake.  Thank you for your time.
Julius Banks
01:03:32
EPA staff, any comments or questions for Ms. Anderson? Okay. Let's go to Shaina Oliver.
Shaina Oliver
01:04:11
Hello?  Can you hear me?
Julius Banks
01:04:17
We can hear you.
Shaina Oliver
01:04:18
Okay.  Thank you for taking my comments today.  I am Shaina Oliver, and I am also a Field Coordinator with Moms Clean Air Force, Colorado.  Importantly I'm speaking as a mom today and as well as being an indigenous people's rights advocate for our right to a safe environment and right to clean air, water and soil, as well as being able to have access to equitable solutions, and also pushing for the Pipeline Hazardous Materials Safety Management Administration to adopt comprehensive public protective standards to protect public safety and the environment.  Today we're really pushing for, you know, being from a disproportionately impacted community where a lot of our communities have been pushed near oil and gas lines, and as well as the need for pipeline safety is urgent for those communities that are disproportionately impacted by oil and gas, by the unknown and unseen pipeline service of oil and gas, we really do need to make sure that we have the most advanced and available technology reporting accurate data of leak detection around pipelines and emissions, and reducing those hazards in our community and to protect our environment, as we see that extreme heat is real in our communities and a lot of communities are disproportionately impacted this year due to the extreme heat and weather events that are currently taking place. It is very urgent for this administration to take seriously and act on measures that will cut methane from pipeline services that are transporting natural gas, which is really detrimental to our environment and further contributes to climate change and to the crisis that we're seeing and will further cost our communities a lot of funding to repair our community after devastations like we've had in the past, like in the Firestone neighborhood with the pipeline leak explosion that happened to the community here in Colorado. We really do need to make sure and ensure that we have the most available, advanced technology being utilized and reporting systems that ensure that we are meeting greenhouse gas reductions through these programs that are available right now and to really ensure that our communities are being protected. And being from a tribal community, I am from the Navajo Reservation and Tribal Affiliate, and seeing the devastation of extraction at all levels, we continue to be undermined for our public health and safety, so I really push for this administration to urge you to take the steps in ensuring that our communities are being protected.  So thank you.
Julius Banks
01:08:00
Thank you very much, Ms. Oliver.  One comment before I go to panelists is that the pipeline safety issues are under purview of the federal Department of Transportation, so those interests are going to be outside the scope of our proposed regulation here.  Any other comments before we move on from EPA staff?  Thank you.  Let's move on to Marie Demarco.
Marie Demarco
01:08:54
Hello, my name is Marie Demarco.  I'm a Health Educator and Advocacy Coordinator with Physicians for Social Responsibility Pennsylvania.  PSRPA is a public health non-profit that advocates for social and environmental justice across Pennsylvania to improve individual and community health.  As part of my work as a health educator, I do research on the health outcomes associated to methane exposure caused by oil and gas drilling or fracking in Pennsylvania and across the United States.  Thank you for the opportunity to submit public comment today.  The harmful effects fracking has on public health of our communities are detrimental.  By reducing methane emissions and advocating for methane safeguards, we can improve air quality, water quality, and our health.  It is essential to place emphasis for those living nearby oil and gas operations that methane emissions can increase risk of heart disease, lung disease, asthma, as well as infertility for men and women, and can influence cancers such as acute lymphatic leukemia and Ewing sarcoma.  Living near oil and gas wells also can result in reduced life longevity in comparison to those that do not live within close proximity according to the compendium published by Physicians for Social Responsibility, national and concerned health professionals of New York with scientific medical and media findings demonstrating the risks and harms of oil and gas drilling.  As a public health professional, I ask that EPA ensures the reporting of the following to Subpart W of the Greenhouse Gas Reporting Program.  I request that reports are based on empirical data and accurately reflect total methane emissions from applicable facilities, as well as allow operators to submit empirical emissions data in a manner prescribed by EPA.  I also ask that the following changes be finalized.  EPA proposes to require reporting of large release events defined as emission events who are currently not reflected in Subpart W reporting and can be large events further harming our health.  EPA moved towards updated emission factors that will better capture intermittent emission and provide more accuracy for reporting, and as well as EPA will require operators to report higher emissions on malfunctioning equipment, as Subpart W does not accurately account for emission from equipment malfunctions.  Still, there is more work to be done to ensure the strongest possible emission safeguards are finalized by EPA to protect public health, including integrating top-down data to give a fair picture of the overall accuracy of reported emissions.  As well as ensuring precise statistical analysis and methods are finalized to account for intermittent emission events that may be missed by individual operations and should define guardrails and require independent verifications of self-reported measurements from oil and gas companies to ensure that any company reported data accurately reflects ongoing operations.  Most importantly, we must protect our public health and climate.  Thank you for your consideration.
Julius Banks
01:12:19
Thank you.  Any comments or questions from EPA for Ms. Demarco?  All right.  We're going to bounce back up to our third speaker, who I think is available, Antoinette Reyes, are you there?
Kellie Dubay
01:12:45
Antoinette, you may not have been on when we gave instructions.  You might see an invitation to be a panelist, so feel free to accept that panelist invite, and then you'll be able to unmute.
Antoinette Reyes
01:12:57
Thank you.  Okay.  Sorry for joining late.  Thank you for the opportunity to speak today.  My name is Antoinette Reyes.  I live in Las Cruces, New Mexico, I am a health-conscious environmental advocate.  I'm speaking today in support of the proposed changes to Subpart W of the Greenhouse Gas Reporting Rule.  But I also believe the rule can still be further strengthened.  The proposal to report large release events and the efforts to improve the accuracy of emissions data will make a difference in ensuring that reported emissions more closely reflect real world pollution levels.  Reporting of large emission events and equipment malfunctions is an incredibly important change since in the past, emissions have been grossly underestimated based on studies.  Intermittent events account for a significant share of overall emissions in certain basins, and robust analytical methods are necessary to account for these.  Please consider incorporating measurement data from aerial observations that provide a full picture of total emissions in a region and supporting stationary continuous optical gas imaging for leak detection.  I also ask that you please reduce the threshold to define a super emitter event as well as require more frequent reports temporarily after a super emitter event as well as set a requirement for how soon a leak must be fixed that led to a super emitter event.  Then lastly, please do more to ensure self-reporting is accurate by requiring independent verification of self-reported measurements and consider updating the EPA's Method 21 to a process that is less susceptible to human error.  Thank you for your time today.
Julius Banks
01:14:59
Thank you.  Before moving on to our group 3, I just will remind everyone who may not have been able to join us earlier that all comments received, whether they be at this hearing or in writing, carry equal weight.  We have not screened any speakers for the webinar in advance.  So again, all comments received will receive equal and carry equal weight.  With that said, we're going to move on to speakers for group 3.
Kellie Dubay
01:15:36
Julius, just so you know, everyone appears to be here.
Julius Banks
01:15:39
Excellent.  All right, let's start with Bruno Marion.  If you're ready, Bruno.  I'm sorry, is that Bruno Marino?  Maybe we have the name incorrect there.  All right.  Last call for Bruno.  Okay, let's come back to Bruno.  There he is.
Bruno Marino
01:16:46
Can you hear me now?
Julius Banks
01:16:48
Yes, we can hear you.
Bruno Marino
01:16:49
All right.  Sorry about that.  Hello, I am Bruno Marino, CEO of Plants for Emission Management Inc. of Cambridge,  Mass.  Thank you for the opportunity to testify today. PEM Inc. supports EPA's revisions, particularly the focus on accuracy, empirical data, and direct measurement, and emphasizes the availability and cost-effectiveness of advanced emissions measurement technology.  Importantly, the differentiation of fossil versus modern methane flux for a commercial operation is not clear, and should be addressed in revisions.  The distinction is crucial for these uncertainties in verifying actual net emission reductions and as a foundation for pivotal emission offsets.  Indeed, without empirical data, planned methane reductions and offsets, as well as charges for waste emissions, may be perceived as inaccurate and unreliable by stakeholders.  One attractive solution to this problem is analysis of radiomethane or carbon-14 methane, which is the anthropogenic perturbation itself to the climate system.  Radiomethane flux accounting, however, is not achievable with current bottom-up or top-down policy methane detection methods.  As a fossil fuel, radiomethane [inaudible] is released into the atmosphere from oil and gas operations, for example, from all sources, is readily measurable as a decrease in the ratio of atmospheric -- this defines an emission line to calculate the abundance of fossil methane leakage.  This can [inaudible] diverse geographic -- from small to very large --.  As a further safeguard, a central reference for-- methane could be established by a third party to electronically verify and certify field measurements in the -- traceability to a system of international units ensuring universality and equivalence of results across all measurements and all locations simultaneously. PEM's radio methane measurement technology and sensor system architecture under development will provide even higher level of accuracy than other technologies by distinguishing exact methane sources.  EPA's final rule should encourage and allow the use of radiomethane measurement technology to achieve its goals.  Thank you for your time.
Julius Banks
01:20:21
Thank you, sir.  Any comments for Bruno from EPA staff?  All right.  We will move on to our next commenter, Cheyenne Branscum.
Cheyenne Branscum
01:20:52
Hello, everyone.  I'm Cheyenne Branscum, I am a tribal citizen in Oklahoma and I really appreciate a chance to speak today.  I am a single mom and like I said, I'm a tribal citizen, so I really feel that if climate change isn't going to affect me, it will affect my children.  We are very much the face of front-line communities, and the people that will be impacted by the decision that you make, I am very encouraged by the current proposed rule change.  I think it's an opportunity to go much further.  I would really, really love to go much further.  We have the technology, for example, for continuous measurement for affected facilities, and we can do that, and I am not sure why we're not where there is so much at stake, and I would love to see that changed.  And I really want to ensure that all data remains publicly available.  And then the biggest ask is if your other speakers have asked, an extension on this comment period be made.  This is a really complicated issue.  This is a really complicated rule change, and if you're someone like me, your life is very busy and you're trying to survive day to day, and you don't have all of the time and luxury and education to process all of this.  And I would love for people to have a little bit more time to understand and to relay comment on these huge things that are going to change them that affect them and their children.  So I appreciate the chance to speak today.
Julius Banks
01:23:07
Thank you very much.  Any comments or questions from EPA for Cheyenne?  Ms. Branscum, as we've stated a few times before, you are more than welcome to request an extension to the comment period in writing.  Thank you.  Cyrus Reed.
Cyrus Reed
01:23:43
Thank you, can you hear me?
Julius Banks
01:23:45
Yes, we can.  Go right ahead, sir.
Cyrus Reed
01:23:47
Thank you very much.  I'm here on behalf of the Lone Star Chapter, the Texas chapter of the Sierra Club to speak on the rulemaking, EPA-HQ-OAR-2023-0234, the Subpart W methane reporting proposal.  My name is Cyrus Reed, I live in Austin, Texas with my wife and two of my three children that are still here living in Texas.  While here in Travis County, we don't have hundreds of oil and gas wells or much production, as an organization, we work with hundreds of communities and thousands of members and supporters who are impacted by pollution from oil and gas wells and associated equipment, and right here in Austin, we are seeing the ravages of climate change.  We're on day 45 of 100 degrees or higher, first time in our history, and certainly some of that climate change is caused by methane emissions.  Also as conservation director, I frequently advocate at the Texas legislature as well as state agencies like the railroad commission and TCEQ, and on the whole, our political leadership in Texas has not been supportive of more rigorous reporting or lower methane emissions which means this rulemaking is very important.  So first, I want to thank you all for this very good proposal.  We think it should be improved but there's a lot of good in this proposal.  Here in Texas, we are the top oil and gas producer in the country.  I can give you a bunch of statistics, but for a time, I won't.  We also have lots of so-called orphaned and abandoned wells that are also likely leaking methane emissions.  And we don't actually have an accurate way to know how much methane emissions there are.  There's a lot of uncertainty as you know in reporting, and venting, flaring that's not correctly done, blowouts of fugitive emissions are very common here.  We don't believe our regulators have done a good job to make sure they don't happen, and a number of studies other folks have mentioned have shown that methane emissions are likely much higher than what's been reported in the current Subpart W.  So there are some aspects of this rule we very much support.  As others have mentioned, we very much support the accounting for super emitting events, requiring reporting of other large release events, we think that's a good part of this rule.  We appreciate the updated emission factors that we think will be more accurate to move towards equipment-based factors that use real world data adjusted for infrequent large emitters and obviously we support the equipment malfunctions and the multiple changes that you would have operators make to report higher emissions.  Still as others have already mentioned, there are some ways to strengthen this rule, both more comprehensively or incorporating measurement data including from larger aerial observations, accounting for intermittent emissions, as others have mentioned, lowering the reporting requirements from 25,000 tons of CO2 equivalent to 10,000, also requiring folks to actually fix the leaks in these super emitter events, and then providing clear guardrails for operator measurements and self-reporting, let me see where I am on the time. Oh, so the Sierra Club will be submitting some pretty extensive written comments that will go into detail on those.  I also want to say separate from the rule itself, it going to be really important to have audits and checks on data reporting, and then figure out how to provide information about the role of both to industry, but also to the state agencies like here in Texas that may be partially responsible for assuring compliance, that's going to be important as well and we'll submit some written comments on how to make that happen.  So with that, I got two seconds left so I'll end.  Thanks.
Julius Banks
01:27:52
Thank you.  Any comments or questions from EPA for Mr. Reed?  All right.  Let's continue, the fourth speaker, Camilla Fiebelman.
Camilla Fiebelman
01:28:15
Can you hear me all right?
Julius Banks
01:28:17
Yes, we can.
Camilla Fiebelman
01:28:18
Great, thank you.  I'm Camilla Fiebelman, director of the Rio Grande Chapter of the Sierra Club, and I represent our 35,000 members and supporters in New Mexico and west Texas.  And I facilitate our New Mexico methane table, which represents dozens of community and environmental groups in New Mexico that have worked since the discovery of the methane hot spot over the four corners to eliminate methane waste and pollution.  And the health impacts of co-pollutants that emit with methane.  Rules like these are key to truly protecting our communities from the devastating heat of climate change and the deep impacts of air pollution.  We're grateful to our Governor, Michele Grisham, for establishing methane and ozone precursor rules, but, and I apologize to my fellow Sierra Club director to the east, with neighbors like Texas, we need to ensure that industry is following a nationwide standard for reporting their waste and pollution, especially since it so badly impacts our border communities in the heat of Permian basin extraction.
Camilla Fiebelman
01:29:29
For our methane reductions efforts to work, we need to be sure that we're measuring the extraction correctly.  That's especially true here in New Mexico where we're the second most prolific oil extractor in the country, and where our rural oil and gas extracting counties get D and F grades on ozone from the American Lung Association. In November of 2022, the publication Capital & Maine as reported by Jerry Redfern published that NASA's Jet Propulsion Labs ground scan camera found a massive methane leak from what appeared to be a gas well 10 miles southeast of Carlsbad, New Mexico with a plume extending two miles.  But this wasn't even the express purpose of the camera or the project.  The researcher described the methane results as a side effect or something that he could mine for the benefit of our communities, and yet caught the venting of more than 43,000 pounds of methane per hour.  This is the type of event that we want to avoid, and that may make the totals that we see emitted quite inaccurate.  So in summary on this rule, EPA's proposed updates to Subpart W of the Greenhouse Gas Reporting Program include improvements to enhance the accuracy of reported emissions from oil and gas industry, including requirements to report large release events and new emission factors based on recent measurement studies.  EPA should strengthen reporting requirements in the final rule by comprehensively incorporating measurement data including from aerial observations, account for intermittent emissions with statistical methods, and provide clear guardrails for operator measurements and self-reporting, EPA should finalize other important improvements it has proposed to enhance the accuracy of reported emissions including requirements to report large release events and new emissions factors based on recent measurement studies.  And I'll close by saying that, at least in New Mexico, the large majority of extraction is taking place on public lands, private industry is extracting publicly held resources off our public lands, and in many cases failing to truly report the cost and impact to our communities.  I thank you for bringing that practice to an end, and I think you can do that by slightly improving this rule.  Thank you for your time.
Julius Banks
01:32:22
Thank you very much.  Any comments for Camilla?  We'll move to our fifth speaker, Joan Brown.
Joan Brown
01:32:50
Good afternoon.  Thank you for this opportunity to speak to you regarding the EPA proposed edits to Subpart W of the Greenhouse Gas Reporting Rule.  My name is Joan Brown.  I'm a Franciscan sister and I'm the Executive Director of New Mexico in the El Paso region Interfaith Power and Light.  We work with people of faith, congregations, faith-based communities to care for creation, climate change all over New Mexico and El Paso region, and that's thousands of people and congregations.  Regarding this issue of pollution, air pollution, oil and gas industry, methane, we have worked closely with those in those regions in our state but particularly in the Permian basin for over a decade.  We're grateful for these rules, but we believe they need to be stronger to ensure that the emissions are based on real world measurements with correct data, and also that incidences of larger intermittent emissions need to be included.  In our work, we have immersion retreat experiences with people of faith in the Permian, and we experience on the ground with some of those community members this malfunctions of thief hatches and other equipment so these issues need to be addressed and they can be with optical gas imaging in these facilities, the technology is available.  During our retreats, we also listen to community members and hear concerns, many concerns of health related to air quality and water in the Permian basin region.  And while large corporations and a few people in power are making the most money in the region, that region suffers great economic inequity and there are also many Hispanic residents and new immigrants.  So these rules must address environmental justice concerns, which have been lifted up by the Biden administration as a priority.  In addition, I know that technical comments are being held in high esteem but I believe also that ethical moral values, implications need to also be held equally.  Moneys from the Methane Reduction Program that are collected from excess methane emissions need to go for further monitoring emissions tracking to ensure adequate reporting and other needs for our front-line communities.  Some new technology including aerial monitoring could assist in detection in quantifying of emissions in hard to reach and isolated areas.  Often our community members state that we can have all the regulations we want, but if they're not enforced, that does not help, and it doesn't.  So EPA must be very vigilant with these companies to have strong and clear guardrails to require independent verification of the self-reported measurements to address these concerns.  The front-line communities and some of us do not trust the self-reporting and rightfully so of corporations in the region.  We all are experiencing this summer as unprecedented in terms of heat, drought, fires, et cetera, and it may be a tipping point.  In our state and region, we often say that our state and many areas in our state and region have been targeted as sacrifice zones for extractivism.  I think we have moved into a new place where we knowingly now are choosing to create a planetary sacrifice zone of the entire planet.  So we have a great ethical, moral, and spiritual responsibility to address this.  We must work for the common good to choose life and not a planetary sacrifice zone.  Women, children, men, species, and the vulnerable are at stake as we all are in our common home.  So thank you for strong rules.
Julius Banks
01:36:49
Thank you, Sister Brown.  Are there any comments from the EPA panel?  Thank you again.  Let's move on to Bill Midcap.  Is Bill Midcap available?
Bill Midcap
01:37:29
Sorry, I did not unmute.  I just jumped over. Can you hear me now?
Julius Banks
01:37:37
Yes, we can.
Bill Midcap
01:37:39
Okay.  My name is Bill Midcap.  I reside in Parker, Colorado and work for Rocky Mountain Farmers Union.  Thank you for this opportunity to comment on EPA's proposed update, Subpart W of the Greenhouse Gas Reporting Program.  Rocky Mountain Farmers Union is a general farm organization founded in 1907, we represent family farmers and ranchers in Wyoming, Colorado, and New Mexico.  Rocky is dedicated to sustaining our rural communities to wide stewardship and use of natural resources and to the protection of our safe, secure food supply.  I certainly doubt if you hear from many other farm groups or farm organizations, but Rocky Mountain Farmers Union stands in support of greater protections to curb methane pollution from the oil and gas sector.  Folks, farmers, and ranchers are on the front-lines of climate change, and that puts our nation's food supply at risk.  Global warming has already cost producers hundreds of millions of dollars that will never be recovered.  Severe storms and drought related to climate change have farmers and ranchers guessing about their future.  As temperatures increase, producers are experiencing declining yields and declining quality in the food that they supply to consumers in America and all over the world.  Climate change is expected to have negative effects on most crops and livestock.  As temperatures increase, crop production areas may shift to follow the temperature range for optimal growth and yield, though production in many given locations will be more influenced by the availability of adequate moisture during the growing season.  Today producers spend over 15 billion, with a "b", a year on pesticides to control weeds and insects.  Those costs are only expected to rise with increasing temperatures and emissions attributed to climate change.  Rocky believes that the EPA should define guardrails and require independent verification of self-reported measurements from companies to ensure any company reported data is accurate and represents their emissions and that the data is not limited to unrepresented sites or equipment that typically has lower emissions.  We support changes to account for super emitting events.  EPA proposes to require reporting of other large release events and Rocky supports this important addition because these emission events are not currently reflected in Subpart W reporting and some of those events are extremely large.  Rocky supports updated emission factors; most operators calculate their emissions using EPA's default assumptions for pollution from different types of equipment.  This is critical that these emission factors accurately reflect real pollution.  Farmers and ranchers know all too well that equipment breaks down.  EPA is proposing multiple changes that would require operators to report higher emissions when they discover malfunctioning equipment such as open hatches or stuck dump valves and Rocky supports these changes because Subpart W currently does not accurately account for these emissions from equipment failures.  As the EPA drafts regulations to reduce methane pollution from the oil and gas industry, please keep in mind that these protections are needed more now than ever to protect our health, our safety, our food security, and our planet.  Thank you.
Julius Banks
01:41:27
Thank you.  Any comments or questions from EPA for Bill?  Thank you again.  Our seventh speaker, Arthur Gershkoff.
Arthur Gershkoff
01:41:59
Hello?
Julius Banks
01:42:01
Hello, Arthur.  We can hear you.
Arthur Gershkoff
01:42:04
Okay.  My name is Arthur Gershkoff.  I am a retired physician from Pennsylvania and I'm speaking on behalf of the Clean Air Council.  As a retired physician, I'm concerned about the health and well-being of our citizens and our nation.  Fossil fuel extraction, processing, and distribution are associated with releases, emissions containing methane and other volatile gases, that can cause illness and increased risk of cancer, respiratory system disease, and other ailments.  People who live and work close to extraction wells and processing facilities are at major risk of deteriorated health.  Neighborhoods near such sites are often communities of color and often poorer families that can't afford to live elsewhere.  Therefore, I greatly appreciate and value these EPA regulations to promote obtaining accurate data and to develop strategies and incentives to reduce emissions over time.  Extraction wells and processing facilities should be monitored frequently for leaks, ideally using optical leak detection equipment that also provides quantification data.  If possible, continuous 24-hour per day monitoring by mounted fixed-position optical leak detection monitors to detect leaks and quantify leakage flow rates may provide more accurate data.  It may be possible to combine such equipment with computerized hardware and software that can capture leak characteristics in real time, and alert staff who monitor settings to act promptly to initiate procedures to seal a leak.  In addition to improving the accuracy of measuring and reporting leaks of such equipment, the EPA should also use some of the Methane Emission Reduction Program funds to pay for external professionals knowledgeable in monitoring techniques to work with the EPA to verify reports from facilities of the amounts of emissions leaked.  Such professionals may also have access to data from satellites and overflying planes and be able to interpret such data.  The EPA should also consider recruiting residents of communities near fossil fuel extraction and processing sites to participate in community-focused air monitoring, perhaps with those professionals.  The EPA must develop clear standards and expectations to allow reasonable time periods for companies to act to identify and stop leaks.  The EPA should level fines only for those companies that have the capability to stop a leak, but purposefully and repeatedly ignore and delay their responsibilities to act.  The technical assistance offered to companies by the EPA may be crucial to help companies apply the best and safest techniques to seal leaks.  I applaud the EPA's goal of developing cooperative relationships with fossil fuel companies.  The plan to treat certain data as confidential is an important component of this cooperation.  However, the EPA may need to balance or modify confidentiality of certain data needed by communities in response to super emissions that threaten the health of communities, and which need to be investigated openly and publicly.  Thank you for the opportunity to give public information to the EPA.
Julius Banks
01:46:01
Thank you, Dr. Gershkoff.  Any comments from EPA?  Okay.  Thank you again.  Let's go to our final speaker, Becca Edwards.  This is our final speaker for this group.
Rebecca Edwards
01:46:35
Good afternoon.  My name is Dr. Rebecca Edwards.  I'm a Climate Action Fellow at Texas Impact and the General Board of Church and Society for the United Methodist Church.  I am an Atmospheric Scientist and a candidate for ordination in the United Methodist Church.  It is a core tenet of my faith that humans are called to care for their neighbors.  What's more, we are called to offer our particular care for neighbors who are the most vulnerable.  Methane pollution is harmful to our neighbors in several ways, from the health impacts of air pollution to the consequences of climate change.  Because the impacts of these environmental problems are most severe for people who are already vulnerable, and because climate change impacts are borne by the people least responsible for greenhouse gas emissions, people of faith care deeply about mitigating the causes of climate change.  In summary, Texans of faith feel called to advocate for a healthy environment, where all people can thrive.  Reducing methane emissions is a critical part of ensuring a healthy environment.  That starts with appropriate quantification of methane releases from the oil and gas sector.  In service of the goal of reducing or eliminating those emissions.  Subpart W of the Greenhouse Gas Reporting Program offers the public transparency on climate pollution from oil and gas facilities; however observational studies reveal that significant amounts of methane continue to be released without being included in Subpart W reporting.  Accurately recorded emissions data is foundational for effective climate policy and environmental quality.  To improve the accuracy of methane reporting under Subpart W, we support the following proposed changes:  EPA should integrate top-down basin-level measurement data which provides a full picture of total emissions in a region or basin, strengthening the overall accuracy of reported emissions.  Intermittent events account for a significant share of overall emissions from the oil and gas sector, but may be missed by individual one-time measurements.  Emission factors could benefit from recently available statistical techniques that can quantify the contribution of intermittent events.  A second benefit of this approach is the simplification of the calculations used by reporters which improves compliance.  The EPA should require operators to report large release events, defined as emissions of more than 100 kilograms per hour or those that release 250 mega ton CO2 equivalent per event, which are not currently reflected in Subpart W reporting despite their important contributions to climate pollution.  Finally, the EPA should improve accountability for self-reported measurements from companies by defining guardrails and requiring independent verification of self-reported measurements.  Thank you for the opportunity to offer these comments and thank you to the EPA for the work you do to care for our neighbors by ensuring a safe environment.
Julius Banks
01:50:02
Thank you, Dr. Edwards, and congratulations.  Any comments or questions?  Thank you once again.  So I know we are -- why don't I turn it over to ERG for the next step in our process here.
Kellie Dubay
01:50:24
Sure.  Thanks, Julius.  So we did have a break scheduled, but everyone -- we're kind of back-to-back on timing with speakers, so we're going to skip the recess and move straight into what would be our hearing re-opening, where EPA will switch from Julius Banks as our hearing chair to our second session hearing chair, Mark DeFigueiredo, and panelists will remain the same during this period of switching, so we'll have Michael Hannan, Vasco Roma, and David Lyon, so for those not here for that initial introduction, that will happen now, and we'll move into speaker groups 4 through 7.  So the time slots obviously that folks were originally given will be a little bit behind, but we'll maintain 4 minutes per person, and if we need to go slightly over to get everybody who preregistered in, we will do that.  Obviously, I will defer to the hearing chair moving forward.  So with that, we will technically re-open and hear from Mark to introduce himself and the panelists again for those of you who may just be joining us.  So Mark, I'll turn it over to you.
Mark DeFigueiredo
01:51:52
Thanks very much, Kellie.  Again, my name is Mark DeFigueiredo.  I'm team leader in EPA's Climate Change Division and I'll be chairing the remainder of today's hearing.  On EPA's proposed rule to revise the reporting requirements for petroleum and natural gas systems, also known as Subpart W under EPA's Greenhouse Gas Reporting Program.  I'd like to ask our other EPA panelists to introduce themselves again.
Michael Hannan
01:52:17
Hi, my name is Michael Hannan.  I'm an Environmental Engineer with the Office of Atmospheric Protection in the Climate Change Division.
Vasco Roma
01:52:27
Hi, my name is Vasco Roma.  I'm an Environmental Protection Specialist, also with the Climate Change Division.
David Lyon
01:52:34
And David Lyon.  I'm a Special Adviser in the Climate Change Division.
Mark DeFigueiredo
01:52:40
Thank you.  I want to remind everyone that today's hearing is being recorded and transcribed to produce a written transcript of the hearing.  We will add the transcript to the public docket for this rulemaking and we'll carefully consider your comments as we develop the final rule.  If you do have questions about today's hearing or are interested in registering to speak, please send an email to<EMAIL_ADDRESS> Again, that's<EMAIL_ADDRESS>or you can send a message via chat to "Attendee Support".  If you are joining us via the phone, you can raise your hand by pressing star 9.  And our logistics team will add you to today's agenda if there's time slots available.  Please note that by registering for today's event, you're agreeing to abide by the ground rules of the virtual hearing.  And that includes rules of behavior.  EPA is committed to an environment of mutual respect and safety.  The agency will not tolerate harassment, discrimination, intimidation, inappropriate language and images, or sustained disruption of today's public hearing.  EPA expects all participants, including panelists, registered speakers, and attendees to conduct themselves in a respectful, professional, and civil manner.  We will monitor and moderate this virtual event to ensure that common standards of decency are upheld.  Just a quick reminder about providing testimony.  When I call on you to speak, you'll receive an invitation to become a panelist on zoom.  You'll need to accept the panelist invitation when it pops up on your screen.  And you'll then have the ability to unmute your line.  While you're providing testimony you're welcome to activate your camera.  You can do that by clicking on the "start video" icon.  And if you're joining via phone and I call your name, please press star 9 to raise your digital hand to let us know that you're here.  You can then press star 6 to unmute and speak.  Please state your name for the record.  A 4-minute timer will start when you state your name.  If you're testifying by phone, the timekeeper will alert you when you have one minute remaining.  And to be fair to everyone, we're going to be strictly enforcing the 4-minute limit.  We'll now begin with speakers in group 4 as they are listed on your screen.  We'll get started with Marlene Perrotte.  I apologize in advance for mispronunciations of speakers.  Marlene, you'll have 4 minutes.  Please feel free to go ahead whenever you're ready.
Kellie Dubay
01:55:33
Mark, if I may, just a quick reminder for folks that we have live closed captioning and live interpretation, so everyone has been doing a great job of speaking slowly.  If everyone could continue that as we move through the rest of our testimony, that would be great.  You're all doing a great job.
Mark DeFigueiredo
01:55:50
Thanks, Kellie.  With that, Marlene, please go ahead.
Marlene Perrotte
01:55:56
Hello?
Mark DeFigueiredo
01:55:58
Hello.
Marlene Perrotte
01:56:00
Hi.  My name is Marlene Perrotte.  I am a Sister of Mercy, and a concerned person of faith.  I am a citizen of New Mexico, and I stand in solidarity with the Permian basin especially and also the San Juan basin.  We have the ethical imperative and moral responsibility to care for our home, planet Earth.  We have to ensure we are doing all we can to improve air quality, health, and address climate chaos.  I'm no specialist, I'm just a concerned citizen.  And I support EPA's proposal requirement to account for super emitting events.  I also support EPA's proposal to update emission factors.  It is critical that these emission factors accurately reflect real pollution.  This will better capture intermittent emissions and provide more accurate reporting.  I also support EPA's proposal to address equipment malfunctions.  These multiple changes would require operators to report higher emissions when they discover malfunctioning equipment, such as open thief hatches or stuck dump valves.  Also, instead of industry self-reporting methane leaks, we need to fund inspection, enforcement, and implementation rules.  EPA, Environmental Protective Agency, we haven't done very well regulating the industry.  Thank you.
Mark DeFigueiredo
01:58:35
Thank you for your testimony, Sister.  Do we have any questions from the panel?  All right.  Thank you again for your testimony.  We'll move on to our next speaker, Ann McCartney.  Ann, you'll have 4 minutes.  Please feel free to get started whenever you're ready.  Ann, if you're there, there should be an icon that pops up.  There you go.
Ann McCartney
01:59:27
Found it.  Yeah.  Thank you.  My computer is slow.  My name is Ann McCartney.  I live in Los Lunas, New Mexico and I am cochair of New Mexico Interfaith Power and Light.  As a person of conscience, I am concerned about how we as a country take responsibility for our impacts on our air, our atmosphere, and the impacts of methane and other gas releases from oil and gas production on people.  I have visited the Permian basin in New Mexico and seen the dirty methane flares and heard from the people who live and work there about the health impacts they have experienced living in an area saturated with greenhouse gas emissions from oil and gas production.  Because of the air quality issues from gas emissions, my organization, New Mexico Interfaith Power and Light, together with Citizens Caring for the Future, are buying air purifiers for some of the most critically impacted residents of the Permian basin.  So the need for more precise and comprehensive reporting of greenhouse gas emissions is great.  I strongly encourage the EPA to strengthen the reporting requirements in the final rule you are considering, to improve the accuracy of reported emissions from the oil and gas industry.  These are technical rules, but they have real life importance for our state and our country.  I strongly encourage you to strengthen the reporting requirements by more comprehensively incorporating measurement data, including data from aerial observations, accounting for intermittent emissions by statistical methods, and providing clear guardrails for operator measurements in self-reporting.  Because we in New Mexico are the second largest producer of oil and gas in U.S., all the proposed changes are critical and needed here.  I particularly want to emphasize the importance of using the top-down measurement data, as current emission inventories are underestimating methane pollution to our detriment.  EPA should integrate top-down basin-level measurement data which will provide a full picture of emissions in a region or basin, which will strengthen the overall accuracy of reported emissions.  This is critical for our state, and the Permian basin region, as well as our Four Corners area, to get our arms around the health risk posed by the current and possibly increasing levels of oil and gas production here in New Mexico.  Second, self-reporting by oil and gas companies needs requirements for verification for self-reported measurements so companies are not limiting their reporting to unrepresentative sites or equipment that typically have lower emissions.  Please take these steps in strengthening greenhouse gas reporting to protect the air we all breathe, and thank you for this opportunity to make a comment.
Mark DeFigueiredo
02:02:42
Thank you very much.  Did we have any questions from the panel?  Seeing none, thank you very much for your time.
Ann McCartney
02:02:52
Thank you.
Mark DeFigueiredo
02:02:53
Our next speaker is Tracy Sabetta.  Tracy, you'll have 4 minutes.  Please feel free to get started whenever you're ready.
Tracy Sabetta
02:03:24

All right, am I off mute?
Mark DeFigueiredo
02:03:26

Yeah, we can hear you.
Tracy Sabetta
02:03:27
Sorry about that, the mute button was a little sticky.  Good afternoon and thank you for the opportunity to testify today.  My name is Tracy Sabetta, and I'm the State Coordinator Moms Clean Air Force in Columbus, Ohio.  Grateful for EPA's proposed improvements to Subpart W of the Greenhouse Gas Reporting Program that would enhance the accuracy of reported emissions from the oil and gas industry, including requirements to report large release events and new emissions factors based on recent measurement studies. Moms Clean Air Force has engaged for years in debate around reducing methane and other emissions from oil and gas facilities.  As a public health advocate and lifelong resident of the Buckeye State, I know what a profound impact reducing and accurately reporting methane pollution would have on states like Ohio.  We are currently home to more than 103,000 oil and gas production facilities.  We rank second in the nation for total residents living within a half mile of these facilities and second for students attending a school, daycare, or college within a half mile.  We support the changes being proposed in the Greenhouse Gas Reporting Program, particularly those that ensure large release events are reflected in Subpart W.  The movement toward major equipment-based emission factors that use real world recent data adjusted for infrequent large emitters, and changes that account for emissions from equipment failures and malfunctions.  Subpart W of the Greenhouse Gas Reporting Program provides the public critical insight on climate pollution from oil and gas facilities.  This reported emissions data is foundational for climate policy.
Tracy Sabetta
02:04:58
The accuracy of subpart W data is even more important now that the Inflation Reduction Act's methane fee, an important tool for incentivizing pollution reductions, is based on the emissions reported to this program.  Increased methane pollution and resulting climate impacts are already hitting us in Ohio and bringing along their own costs.  According to the bird polar and climate research center at the Ohio State University, one severe climate impact currently being seen in Ohio is a rise in overnight temperatures.  Records for overnight temperatures were recently broken in four major Ohio cities, with Toledo, Akron, Mansfield and Findlay setting records for average minimum summer temperatures.  These widespread temperature increases bring with them a strain on cooling systems, electric bills, and people's health, specifically in front-line communities across the state.  Now add the power outages experienced by many into the mix and you have a climate change recipe for disaster.  While we are generally supportive of the proposed changes, we do believe that EPA should strengthen reporting requirements in the final rule by more comprehensibly incorporating measurement data, accounting for intermittent emissions with statistical methods and providing clear guardrails for operator measurements in self-reporting.  Scientists have known for decades that air pollution is harmful to health and this is especially true for vulnerable populations such as older adults, people with underlying health conditions, communities of color, pregnant women, and children.  Air pollution from the oil and gas industry can cause respiratory diseases, asthma attacks and increased hospitalizations.  That is why strengthening the proposed rule is so critical.  On behalf of the 89,000 members of Moms Clean Air Force in Ohio, we believe the changes to the Greenhouse Gas Reporting Program are off to a really good start, and we hope that you will consider the proposed suggestions for strengthening the requirements.  This is an important step toward addressing the climate crisis and protecting the health and safety of children and families across Ohio, and across the country.  Thank you so much for this opportunity.
Mark DeFigueiredo
02:06:53
Thanks for taking the time to testify today.  Do we have any questions from our panel?  No?  Thank you very much for your testimony.
Tracy Sabetta
02:07:03
Thank you.
Mark DeFigueiredo
02:07:04
We'll move on to our next speaker.  Our next speaker is Margeret Bell.
Margeret Bell
02:07:29
Hello, do you hear me?
Mark DeFigueiredo
02:07:31
Yes, we can hear you.  Please go ahead.
Margeret Bell
02:07:33
 Yes, thank you.  Good afternoon.  My name is Margeret Bell.  I live in Albuquerque, New Mexico and I thank you for the opportunity to give comment on the proposed Subpart W updates.  New Mexico along with Texas as part of the Permian basin is at the nation's largest methane emitter.  Methane emissions have played a dominant role in our state's mega drought, and then the horrific wildfires that have destroyed hundreds of thousands of acres of forests and damaged acequias, which are local community irrigation networks, streams and aquifers, resulting in loss of water resources we cannot afford to lose.  The damage has been so catastrophic that the forests, lands, ecosystems, waters and multigenerational communities in northern New Mexico may never fully recover.  We are beyond a climate crisis.  We are in a climate catastrophe.  I am grateful to the EPA for the changes you're making to Subpart W, and I support those changes which include large release events, emissions from malfunctioning equipment, and updated emission factors.  However, we're dealing with the oil and gas industry which always has and always will put profits before the planet, and public health.  Therefore, think we're well past relying on company reported data to help address and reduce methane emissions.  Therefore, I would recommend that the EPA further strengthen Subpart W by requiring continuous optical gas imaging for all affected facilities.  This simple, readily available, easy to use noninvasive technology would result in more frequent and accurate data and help catch emissions data for super emitter incidents.  I would also recommend the EPA use top-down measurement approaches and data; studies based on observed, measured emissions at the regional level show that current emissions inventories are underestimating methane pollution.  EPA should integrate top-down basin level measurement data which provide a full picture of total emissions in a region or basin, strengthening the overall accuracy of reported emissions.  And include top-down approaches such as continuous aerial monitoring to detect and quantify especially large emissions from oil and gas sources.  These emission events generally do not have empirical emissions factors and calculating their magnitude would likely not be accurate.  Lastly, I would ask that the EPA require independent verification of self-reported measurements from companies to ensure any company-reported data accurately represent emissions and is not limited to unrepresentative sites or equipment that typically have lower emissions.  Thank you for your work to update Subpart W and for this opportunity to give comment.
Mark DeFigueiredo
02:10:47
Thank you, Ms. Bell.  Do we have any questions from the panel?  Thank you very much for your testimony.  We'll move on to our next speaker, Dr. Dakota Raynes.
Dr. Dakota Raynes
02:11:19
Good afternoon.  My name is Dr. Dakota Raynes, I am a Research and Policy Manager at Earth Works.  Thank you for listening to all of our testimony today.  Part of the work we undertake at Earth Works involves documenting the claims that oil and gas companies make regarding emissions reductions and comparing those claims to evidence collected by experts in the field of optical gas imaging.  Unfortunately, what we and other investigators frequently find is that industry rhetoric and reporting fails to match what we see in our on the ground site surveys.  If the information collected is accurate, shared in a timely fashion and remains publicly available, Subpart W of the Greenhouse Gas Reporting Program has the potential to provide the public, investors, insurers, and policy makers with crucial information about oil and gas pollution, which could enable better protection of communities and the environment.  The accuracy of Subpart W data is even more important now for several reasons.  First as others have mentioned, we are quickly running out of time to ensure that we are on track with the commitments made in the Paris Climate Accord and the target set by the Intergovernmental Panel on Climate Change.  Second the methane fee structure outlined in the Inflation Reduction Act relies on emissions data reported via this greenhouse gas program and third the United States is currently working toward exporting our approach to methane reporting, measuring, and mitigation to the rest of the world therefore, if we get this wrong, the consequences will not just impact our country, our communities and our little sliver of the environment, rather, the consequences will be felt around the world.  If we get this wrong, we run the risk of continuing to overestimate our progress and our chances of survival.  Congress directed the EPA to update Subpart W to ensure that reporting is based on empirical data and accurately reflects total methane emissions from applicable facilities.  Hence, we are pleased that the EPA's proposed updates include a variety of improvements that could enhance the accuracy of reported emissions such as requirements to report large release events.  Research has demonstrated, as many have already noted, that current emissions inventories vastly underestimate methane pollution.  Therefore, the EPA should integrate both top-down and bottom-up basin-level direct measurement data to provide a complete picture of the total emissions in a region or a basin.  In addition to measurements from various types of aerial observation, the EPA should also require data from optical gas imaging inspections under the EPA's forthcoming methane rule to more accurately account for methane emissions.  Emissions calculations as compared to direct measurements should only be used as a last resort, and the EPA should do everything in its power to ensure that such calculations are the result of robust statistical analysis that is based on real world measurements of pollution.  The EPA should also require operators that have a super emitter event to stop that emission as quickly as is possible, and report their greenhouse gas emissions monthly going forward, and submit a compliance plan to demonstrate how they will prevent additional such incidents from occurring.  Lastly, as many others have noted, the EPA should define clear guardrails and require truly independent verification of companies self-reported measurements to ensure that any company-reported data actually represents true emission levels and isn't based on unrepresentative samples of sites or equipment that typically have lower emissions.  Thank you so much for your time and consideration, and the work that you are doing on this particular rule.
Mark DeFigueiredo
02:15:08
Thank you, Dr. Raynes.  Do we have any questions from the panel?  Seeing none, thank you very much for your testimony.  We'll move on to our next speaker, Bryan Burton.  Bryan, you'll have 4 minutes and you can start whenever you're ready.
Bryan Burton
02:15:43
Hello.  My name is Bryan Burton.  I'm the Advocacy Manager for Healthy Air for the American Lung Association.  The American Lung Association strongly supports accurate accounting of emissions.  We also support the proposed changes to deal with malfunctions and the proposed requirement to better report large intermittent emission events.  However, these changes to Subpart W must go further to protect our most vulnerable citizens.  In 2019, following a spate of cancer diagnosis among children and pregnant women in southwestern Pennsylvania, the State Department of Health partnered with the University of Pittsburgh to study the possible health risks of our oil and gas industries.  In three reports released just this last week, the relationship between adverse outcomes and the proximity to gas operations has become more clear.  Children living within a mile of a well have a 500 to 700% greater risk of developing lymphoma and other cancers than their counterparts.  Also they found a quote "strong link between natural gas development and severe exacerbations, emergency department visits and hospitalizations for asthma in people living within 10 miles of one or more wells producing natural gas."  Finally, the research concluded that mothers give birth to smaller babies when living in proximity to active wells, compressor stations, and waste facilities.  Pennsylvania's new studies join a growing body of scientific and medical evidence that shows adverse health impacts on people living nearby oil and gas activities.  The EPA should use basin-level measurement data and top-down approaches such as continuous aerial monitoring to detect and quantify especially large emissions, particularly super emitters from oil and gas sources.  Large emission events or super emitters can be a significant source of greenhouse gases and will be required to be reported.  Continuous optical gas imaging is a simple, noninvasive qualitative process that consists of surveying a facility with a specialized infrared camera that makes gas leaks readily apparent on a screen.  This technology would result in more frequent and accurate data, and it would help catchy mission data for potential super emitter incidents.  Once detected, these significant leaks should be repaired within five days and the emitter required to submit a plan to prevent future emission incidents from occurring.  Furthermore, we encourage EPA to reduce the current reporting limit and methane emissions charge threshold of 25,000 metric tons of CO2 equivalent to 10,000 metric tons of carbon dioxide equivalent as originally proposed.  Once finalized, these revisions must require that all reported data including those under the proposed revisions to the onshore oil and gas production, gathering and boosting industries remain publicly available.  Reliably consistent and accurate measurement of greenhouse gas emissions are the only way to fairly implement the provisions of the Inflation Reduction Act's methane fee across the oil and gas industry.  To this end, there must be strong guardrails in place and mandatory independent third-party verification measures actively enforced to ensure a level playing field between all private firms and the oil and gas industry as well as trustworthy information sharing between state and local environmental regulators.  Thank you for the opportunity to provide comment, and for moving forward on removing a large achievable source of climate warming emissions from our atmosphere.  We look forward to continuing engagement with this agency as it implements this and further pieces of the Methane Emissions Reduction Program.  Thank you very much.
Mark DeFigueiredo
02:19:37
Thank you, Mr. Burton.  You had mentioned a few papers over the past week that were recently published.  Would you be able to provide citations to those, to submit that to our docket?
Bryan Burton
02:19:49
Absolutely.
Mark DeFigueiredo
02:19:50
Thank you very much.  Do we have any questions from the EPA panel?  Thank you.  We'll move on to our last speaker for this panel, Sarah Bradley.  Sarah, you'll have 4 minutes.  And you can get started whenever you're ready.
Sarah Bradley
02:20:24
Hello.  Can you hear me?
Mark DeFigueiredo
02:20:27
Yes, we can.
Sarah Bradley
02:20:28
Great.  Thank you for holding this hearing and giving the public the opportunity to give comments.  My name is Sarah Bradley, and I'm a faith-based organizer from the Nuns and Nuns Land Justice Project and I live in Albuquerque, New Mexico.  Almost two years ago, I had the opportunity to join a pilgrimage and immersion to the Permian basin in southeast New Mexico, which is one of the most productive oil and gas basins in the country and the world.  There I got to meet residents of the region and learn about the enormous challenges that the oil and gas industry is causing in the region, especially in their struggle for environmental justice and healthy air, soil, and water.  We drove through lands covered with fracking and drilling pipelines and rigs as far as the eye could see, and under a consistent brown haze of pollution, for miles and miles, we drove by constant illegal flaring and in the towns of Hobbs and Carlsbad, we met mothers, daughters, and wives who are watching their loved ones who work in the oil and gas industry fall sick, watching their bodies deteriorate.  They worry about the health of their families, seeing the clear connection between exposure to pollutants and long-term health impacts such as pulmonary and heart disease, asthma, chronic bronchitis, cancers, leukemia, and birth defects.  Walking around in a neighborhood that had a well right next to a children's park, residents could point to multiple houses where long term residents died from rare cancers that are proven to be connected to oil and gas pollutants.  In the Permian basin, organizers dedicated to protecting their community's health faced enormous push back and silencing.  It's David and Goliath out there, as the oil and gas companies employ a large portion of the residents and control everything in town, from community program funding to political leaders; so many everyday people are literally afraid for their lives, they're afraid for their health, but are afraid to speak out in their local towns, knowing that standing up could result in them losing their jobs and facing attacks from many sectors.  So given the imbalance of power in these kinds of places where the oil and gas industries are so strong, we need regulatory agencies to live up to their charge and protect the people and the environment and the planet as a whole.
Sarah Bradley
02:22:44

The EPA has a responsibility to protect front-line communities and we cannot protect anyone if we are not effectively and thoroughly monitoring what is going on in the air, ground and waters. The EPA must strengthen its rules, reporting requirements in order to improve accuracy and hold polluters accountable for harming people and the planet.  More specifically, reporting needs to be more comprehensive by incorporating top-down and bottom-up direct measurement data and aerial observations.  Intermittent emissions and leaks must be accounted for and clear standards for operating measurements and self-reporting are necessary. The EPA should define guardrails and require independent verification of self-reported measurements from companies.  The EPA should also finalize other important improvements that it has proposed including requirements to report large release or super emitter events, using major equipment-based emission factors which use real world data will help with accurate reporting as well.  Operators also need to be accountable for equipment malfunctions and report higher emissions when they know equipment is not working properly.  While such rules may be technical, together they are part of life and death importance to our human communities and life everywhere.  Accurate monitoring and holding companies accountable for these [inaudible] activities is the bare minimum we need to be doing in a time of climate collapse, and what the EPA does now is going to have a global impact in terms of mitigating the climate catastrophe.  It's my belief that political leaders and government officials in the U.S. today are not protecting our communities and our futures enough and I implore you to do more.  We have an ethical and moral responsibility to ensure we are doing all we can to safeguard front-line communities and make sure we have a livable climate future.  Thank you so much for your time and consideration.
Julius Banks
02:24:32
Thank you very much.  This is Julius Banks replacing Mark for a spell here.  Any comments for Sarah from EPA staff? Thank you very much.  Before we go to group 5, I wanted to make a very short announcement, and that announcement is that we will be holding -- EPA will be holding a technical webinar on the proposal for Subpart W to update the GHG emissions reporting requirement for the oil and gas sector.  That webinar will take place on September 7th from 2:00 to 3:00 P.M. Eastern.  We will send an invite at the conclusion of this hearing.  I've also requested that we send registration information in the chat to this hearing.  So again, we will be providing a technical webinar on the aspects of the Subpart W rulemaking on September 7th from 2:00 to 3:00 Eastern.  All right, thank you.  So let's keep going.  We'll go on to session 5.  And I understand that David Brezler is -- I believe he had to leave.  If he's able to join us, we'll connect him towards the end.  So let's move on to Liz Scott.  Liz, if you are available, you'll have four minutes.
Liz Scott
02:26:21
Hi there.  Good afternoon.  My name is Liz Scott, National Director of Advocacy for Healthy Air at the American Lung Association.  Thank you for the opportunity to provide comments today on the proposed Greenhouse Gas Reporting Rule.  The American Lung Association strongly supports accurate accounting of emissions.  Under Subpart W of the Greenhouse Gas Reporting Program, owners and operators of certain oil and gas facilities are required to report annual methane emissions using various methods.  Unfortunately, the methods used have been shown to underestimate the total emissions.  Getting this part right is crucial to achieving the emissions reduction needed to stave off even more catastrophic impacts of climate change and at the same time to clear the air of the co-pollutants often leaking alongside methane.  Climate change is a health emergency, and we cannot afford to pass off the health impacts of climate change as future problems because there is no shortage of climate disasters like flooding, wildfires, excessive heat, and storms threatening lives and livelihood right now.  These extreme weather patterns are being fueled by climate change, which is being fueled in part by methane emissions.  This is why the Lung Association was glad to see the inclusion of the Methane Emissions Reduction Program in the Inflation Reduction Act.  Revising the requirements under Subpart W to ensure that the reporting accurately reflect the total methane emissions from facilities is necessary to set up further tactics and strategies to reduce those methane emissions.  We support the proposed requirement to better report large intermittent emissions events.  These events are currently not reflected in Subpart W reporting, and expanding the requirement for their inclusion will help capture some potentially large emission events that are being missed otherwise.  We also strongly support the proposed changes to deal with malfunctions.  When equipment malfunctions occur, it is likely that emissions levels will be higher and requiring operators to report those higher emissions will lead to more accurate emissions data gathering.  Current methods are underestimating the levels of methane pollution.  We encourage EPA to integrate top-down basin-level measurement data to get a better picture of total regional level emissions.  This will help ensure that communities located closest to facilities are not suffering from escaped emissions, since we know that methane is not the only thing that leaks from oil and gas facilities.  Volatile organic compounds like benzene are emitted alongside methane and can worsen asthma symptoms and increase the risk of cancer, developmental, and neurological disorders.  VOCs can also react to form harmful ozone pollution or smog. Smog can increase the risk of premature death, contribute to asthma attacks, and aggravate existing lung and heart problems.  We also support more accurate accounting for intermittent events.  These events can account for a significant share of overall emissions but may be missed by one-time measurements.  We urge EPA to ensure robust methods and analysis are used to better account for these intermittent emissions events more broadly.  Additionally, one of the provisions of the Methane Emissions Reduction Program was to allow owners and operators to submit emissions data.  We strongly urge EPA to define clear guardrails and require independent verification of self-reported measurements.  Thank you for the opportunity to provide comments and for moving forward on a key pillar of the Inflation Reduction Act.  We look forward to continuing engagement with the agency as it implements this and further pieces of the Methane Emissions Reduction Program.
Julius Banks
02:29:52
Thank you very much.  Any comments for Liz from EPA?  All right, thank you again, Liz.  Let's continue to Kathryn Westman.  Kathryn Westman, are you available?
Kathryn Westman
02:30:25
Thank you.  I'm trying to start the video.  Thank you.  Good afternoon.
Julius Banks
02:30:32
Good afternoon.
Kathryn Westman
02:30:33
I'm Kathryn Westman from Gibsonia, Pennsylvania.  Thank you for having this hearing.  I testify as a registered nurse, as I call for tighter monitoring of the oil and gas industry, and call attention to the ongoing negative health effects of this industry.  And as a grandmother of three children, as I call for leading a healthy and sustainable and equitable future for all children.  Today I also speak as a person of faith, called to be a good steward of the Earth.  I am a member of the southwest Pennsylvania Synod of the Evangelical Lutheran Church in America, Creation Care Team of Lampa, which is the Lutheran Advocacy Ministry in Pennsylvania, and also Interfaith Power and Light of Pennsylvania.  From speaker group 3, Joan Brown highlighted many ethical and moral reasons that people of faith call to your attention, and I do too.  The current calculations and reporting methods underestimate their total emission.  Taking the liberty to misquote Greta Thunberg and Nero, I tell you, our house is on fire and we just keep fiddling.  I appreciate and support the amendments, encourage making them even stronger.  A speaker from group 1, Alice Lu, listed Clean Air Council's recommendations to strengthen the proposal.  In the interest of time, I would like to say I fully support all of the suggestions of the Clean Air Council and believe they all must be implemented, as soon as possible.  I support the extension of the comment period and will submit my request.  Thank you for all these needed amendments.  Please make them as strong as possible for the sake of our planet.  They are needed now, and thank you for taking my comments.
Julius Banks
02:32:50
Thank you, Ms. Westman.  Any comments from EPA?  All right, thank you again.  We'll move on to Kayley Shoup if she's available.  I received a message that she may not be on the line any longer.  Kayley, are you there?
Kellie Dubay
02:33:10
Julius, there's a chance this participant may be on the phone, so if that's the case, hitting star 9 would raise a digital hand to let us know.
Julius Banks
02:33:21
Okay.  We'll give Kayley a few seconds to see if that works and we'll jump to the next speaker and come back.  All right, let's move to the fifth speaker, Jozee Zuniga.  Hopefully I'm pronouncing that correctly.
Kellie Dubay
02:33:45
Again, Jozee, if you're on the phone -- we do have one participant on the phone.  If that's you, feel free to hit star 9 to let us know.
Julius Banks
02:34:04
I'm going to keep us moving then.  We'll go to the sixth scheduled speaker in this group, John Sonin.
Kellie Dubay
02:34:17
John, if that's you on the phone, please hit star 9 to raise your hand and let us know.  I'm not seeing a hand go up, Julius.
Julius Banks
02:34:34
Okay.  Richard Cole, the last scheduled speaker in this group.  Richard, are you available?
Kellie Dubay
02:34:45
Again, you can always hit star 9 if that's you on the phone, Richard.  I'm not seeing a hand, Julius.
Julius Banks
02:34:58
Okay.  I received a note that we may have another speaker that we could fit in then.
Kellie Dubay
02:35:04
Oh, I don't mean to interrupt, Julius, but we just had Kayley Shoup, who is one of our speakers for this group, raise a hand.
Julius Banks
02:35:12
All right, very good.  Kayley, are you on?  Is your audio working?
Kellie Dubay
02:35:20
We may have to raise her up to panelist.  Kayley, you might get an invitation to be a panelist and you can unmute yourself.
Kayley Shoup
02:35:51
Hello, can you all hear me?
Julius Banks
02:35:54
Yes, we can, Kayley.  Thank you.
Kayley Shoup
02:35:56
Okay.  I apologize about that.  I was having some technical difficulties.  So my name is Kayley Shoup, and I'm a community organizer with a small grassroots advocacy group called Citizens Caring for the Future.  I live in Carlsbad, New Mexico in the heart of the most active oil field in our country, the Permian basin.  I often rear to the Permian as the wild, wild west because it's so vast and busy that oil companies can get away with breaking the rules quite easily, simply because there's no one there to call them out.  Every time I drive out in the field, I'm reminded of the fact that we haven't even began to truly quantify the amount of methane pollution coming from my region.  This is why I think that Subpart W of the Greenhouse Gas Reporting Program is absolutely crucial.  A recent incident in the Permian underlines why you must take full advantage of the technology at your fingertips by incorporating measurement data, but why it's crucial that it also goes hand in hand with implementing strict guardrails for self-reporting at all sites as green washing from major oil companies becomes the norm.  In 2021, Exxon announced that it would be working with an independent certifier to certify that the natural gas produced at their Poker Lake facilities is responsibly sourced.  These sites are right outside of Carlsbad, and I knew that they would get way too much credit for cleaning up a few sites while continuing to pollute the air that I and my family breathe.  Fast forward to March 2022.  A NASA satellite caught a large emission event just miles out of Carlsbad.  This emission event was not reported to the state of New Mexico as is required.  No one knew of it, and never would know of it, if it wasn't for that satellite.  And as I'm sure you might have guessed, Exxon's XTO was responsible for this unreported event.  As your agency finalizes these rules, it is crucial that your regulations take into account the fact that the companies that knowingly got us into this mess of fossil fuel climate change will not be the ones to save us, and they are still as dishonest as ever.  Thank you for your time and for taking comment.
Julius Banks
02:38:15
Thank you very much, Kayley.  Any comments from EPA?  Okay, thank you again.  There were a number of speakers here who may have been on the phone.  Have we heard from any of the remaining speakers in this group?
Kellie Dubay
02:38:36