Comments to EPA re: Proposal to Approve California SIP Revisions

Earthjustice and partner organizations urge the EPA to reject California's SIP revisions, claiming they create loopholes for oil and gas polluters. The authors argue that RACT must apply to all wells regardless of production volume or oil gravity, and that the EPA failed to conduct a required environmental justice analysis. They contend that current exemptions for heavy oil and low-production wells disproportionately harm frontline communities and that monitoring and reporting frequencies are insufficient to ensure compliance with the Clean Air Act.

• The EPA failed to conduct an environmental justice analysis for the proposed SIP, which the authors claim is inconsistent with Executive Order 12898.
• The proposed SIP and EPA guidelines improperly exempt low-production wells (those producing less than 15 barrels of oil equivalent per day), including idle wells, from RACT requirements.
• The SIP is legally deficient because it exempts wells producing heavy oil (API gravity of 20 degrees or less), which constitutes a majority of California's oil production.
• The authors argue that the EPA's exemption for wellhead-only sites is illogical as these sites still contain components prone to leaks, such as flange seals.
• The document disputes the EPA's claim that RACT is economically infeasible, stating that leak detection technology like optical gas imaging (OGI) is already used at other wells in the source category.
• Current monitoring frequencies in the SIP (quarterly) and federal guidelines (semiannual) are deemed insufficient; the authors advocate for monthly monitoring to better protect public health.
• The SIP's annual reporting timeline is criticized as being too infrequent to allow for effective oversight or prompt detection of leaks.
• Oil and gas activity in California is linked to severe health impacts in frontline communities, particularly in the San Joaquin Valley and South Coast Air Basins.

APA

Earthjustice (2024). Comments to EPA re: Proposal to Approve California SIP Revisions. https://earthjustice.org/wp-content/uploads/2024/12/epa-cal-sip-comments_2024-06-03.pdf

Chicago

Earthjustice. Comments to EPA re: Proposal to Approve California SIP Revisions. 2024. https://earthjustice.org/wp-content/uploads/2024/12/epa-cal-sip-comments_2024-06-03.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Comments to EPA re: Proposal to Approve California SIP Revisions |date=3 June 2024 |url=https://earthjustice.org/wp-content/uploads/2024/12/epa-cal-sip-comments_2024-06-03.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2024comments, author = {{Earthjustice}}, title = {{Comments to EPA re: Proposal to Approve California SIP Revisions}}, publisher = {Earthjustice}, year = {2024}, month = jun, url = {https://earthjustice.org/wp-content/uploads/2024/12/epa-cal-sip-comments_2024-06-03.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }