Patricia DeMarco Ph.D.

"Live in harmony with nature."

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The Perils of “Deconstruction”- What fate for our environment and health?

March 3, 2017

We live in a strange time when protecting the environment through government regulations has been demonized as the enemy of jobs and progress. I find this most distressing because I grew up in the height of the Industrial Revolution when the skies of Pittsburgh were dark with smoke. Pollution was an ever-present part of daily life: streetlights were on all day; people wore brimmed hats to keep the ashes off of their faces, and “Ring around the collar” was the lament of housewives. The Monongahela River was so polluted with effluent from steel mills, glass works, coke works and smelters that the water was as acid as vinegar, and practically lifeless. Strip-mined lands were left to leach and drain acid into streams, leaving 3,000 miles of Pennsylvania waterways permanently running orange and lifeless.

cayhouga-river-on-fireIn 1969, the confluence of several highly publicized events from pollution of air, water and land combined to focus attention on the need to control pollution. Heat inversions trapped emissions close to the ground creating suffocating smog, as in The Smog of Thanksgiving weekend in New York in 1966 and the prevailing conditions in San Diego and Pittsburgh. In June 1962, the Cuyahoga River in Cleveland caught fire and burned two bridges when sparks from a train ignited the oil-soaked debris in the river. Such events happened frequently in American rivers in the late fifties through the 1960s. The Santa Barbara Oil spill of January 28, 1969 brought attention to the spills that occurred regularly from tankers running aground, or pipelines rupturing or leaking. The widespread toxic effects of agricultural pesticides like DDT and the way their effects permeated through the food chain came to attention through Rachel Carson’s book Silent Spring. It was the combined impact of all of these perceptions, rolled into the turbulent times of the early 1970s over war protests, women’s rights movement, the civil rights movement and anti-nuclear sentiment over open air testing of nuclear weapons that galvanized protests from 20 million people nationwide on the first Earth Day 1970. Environmentalists and labor unions worked together and built a broad coalition around clean air and clean water.

Congressmen marched with their constituents pledging to make changes, and it was President Nixon who gave the foundations for bipartisan remedy to this recognized crisis. In his 1970 State of the Union speech, Nixon called environmental preservation a “common cause of all the people of this country.” He went on: “It is a cause of particular concern to young Americans, because they more than we will reap the grim consequences of our failure to act on programs which are needed now if we are to prevent disaster later. Clean air, clean water, open spaces—these should once again be the birthright of every American.”[i] The Environmental Protection Agency was established soon after, with the foundations of environmental protection policy enacted into law with bipartisan support: the Endangered Species Act, the Clean Air Act, the Safe Drinking Water Act, the Toxic Substances Control Act. The Environmental Protection Agency was not an attack upon States Rights or a suppression of individual freedom of actions to pursue economic advantage. Federal environmental protections recognized that pollution knows no boundaries. States alone would be unable to address significant problems of air pollution, watershed, river and stream contamination or the ubiquitous dispersion of toxic chemicals throughout the country. National standards and federal enforcement are necessary and fair.

President Trump has appointed Administrators in the Department of the Interior, the Environmental Protection Agency and the Department of Energy with clear connections to fossil industry interests going back whole careers. According to White House Chief Strategist Steve Bannon, President Trump’s cabinet picks are aimed at deconstruction of the administrative state, meaning weakening regulatory agencies and other bureaucratic entities.[ii] Today, Republicans call to roll back or rescind protections that have made America the gold standard worldwide for overall environmental quality. President Trump’s budget proposes a 25% cut of the Environmental Protection Agency’s budget, and a 20% reduction in staff. [iii] Under the Congressional Review Authority, dozens of regulations adopted or even amended in the last months of the Obama Administration are being rescinded.[iv]


Some 5000 union members, led by the United Mine Workers of America, march through downtown Pittsburgh to the William S. Moorhead Federal Building Thursday, July 31, 2014. Thursday is the first of two days of public hearings being held by the Environmental Protection Agency in Pittsburgh to discuss stricter pollution rules for coal-burning power plants proposed by the EPA.(AP Photo/Gene J. Puskar)

Some 5000 union members, led by the United Mine Workers of America, march through downtown Pittsburgh to the William S. Moorhead Federal Building Thursday, July 31, 2014. Thursday is the first of two days of public hearings being held by the Environmental Protection Agency in Pittsburgh to discuss stricter pollution rules for coal-burning power plants proposed by the EPA.(AP Photo/Gene J. Puskar)

Do people know what effect this wanton behavior will have on the health and well-being of American people, workers, communities and natural preserves? How did it become a desirable outcome for coal waste to be dumped into streams? Or volatile toxic releases to be exempt from regulations, as with hydraulic fracturing? Do Americans really want unrestrained mining, drilling and ranching on public lands? Does increased access to wildlife refuges and national parks require that restrictions be lifted on lead ammunition and fishing that poisons thousands of birds and fish? Do workers really want the Risk Management Program that protects workers, first responders and communities from industrial spills and accidents to be eliminated?

These actions slip through a Congress in the thrall of a demonic drive to “Make America Great Again” defined by military might alone. Shifting $54 billion from domestic spending to military force buildup while the President irritates allies and aggravates enemies sets the stage for war, not peace and prosperity. Budget is policy. This proposed budget, unrestrained with either mercy or compassion for average working Americans and oblivious to the needs of the future, is a prescription for disaster.

imagesIn towns, cities, communities across America, people with vision and concern for the future are making plans for a socially equitable and environmentally sustainable society. These efforts will not fall to the greed and corruption perpetrated on the people by a demagogue. All people share our common humanity regardless of divisions in political persuasion, culture, religion or economic status. We all care about the future for our children, and value safe drinking water, fresh air, accessible and safe food, and secure and safe work places. Most people value the national parks and refuges as the legacy of our land.[v] Government budget and investment choice can steer towards processes that make the jobs and industries thrive or collapse. In a budget steering toward military might over a sustainable new economy, with infrastructure plans looking to the past rather than to the future, people are beginning to recognize that the fate of those outside the elite 1% is to serve as cannon fodder.

Stand up for the hard-won protections of our life support system- fresh air, clean water, fertile ground and biodiversity of species that constitute the Web of Life, of which we are but one part. America’s greatness lies in leading toward a future that serves all of the people with justice and security, with equal opportunity to thrive and pursue our dreams, and with respect for the resources of our land that support us all. We depart from the hard-won protections of our common resources at our own peril.


[i] President Richard M. Nixon. 215 – Special Message to the Congress About Reorganization Plans To Establish the Environmental Protection Agency and the National Oceanic and Atmospheric Administration. July 9, 1970. Accessed March 1, 2017.

[ii] David Z, Morris. Fortune Magazine, February 25, 2017. Accessed February 26, 2017.

[iii] President Donald Trump. Address to Joint session of Congress, February 27, 2017. Accessed March 1, 2017.

[iv] Brian Resnick and Julia Belluz. Sudden Changes at the EPA, USDA, and CDC under Trump explained. January 25, 2017.

[v] Anthony Leiserowitz, Edward Mailbach, Connie Roser-Renauf, Matthew Cutler and Seth Rosenthal. Trump Voters and Global Warming. Yale Program on Climate Change Communication. February 6, 2017.

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The Limits to Methane Regulations- Comment to the EPA

Environmental Protection Agency


Oil and Natural Gas Sector: Emission Standards for New and Modified Sources

My name is Patricia DeMarco. I am a biologist by training with a thirty-year career in energy and environmental policy.[1] I speak on behalf of my grandchildren and the unborn children of the 21st century whose fate we determine by our actions today. I support the EPA’s efforts to regulate the oil and gas development industry as part of the 2009 Endangerment Finding, where the EPA Administrator found that the current, elevated concentrations of greenhouse gases in the atmosphere—already at levels unprecedented in human history—may reasonably be anticipated to endanger public health and welfare of current and future generations in the United States. In your background of the regulation you state:

“As Earth continues to warm, it may be approaching a critical climate threshold beyond which rapid and potentially permanent—at least on a human timescale—changes not anticipated by climate models tuned to modern conditions may occur.”!documentDetail;D=EPA-HQ-OAR-2010-0505-4776


In the face of such dramatic findings, the regulations proposed here have the effect of putting a Band-Aid on a hemorrhage. The regulations you are considering come late in the process for an industry shamefully protected by Section 322 of the National Energy Act of 2005 with exemptions from the Clean Air Act, the Safe Drinking Water Act and the Resource Conservation and Recovery Act. These exemptions for high volume hydraulic fracturing and other deep drilling operations assure weak regulatory provisions. Nevertheless, as citizens we must reiterate the plea for regulations that take consideration of the public health and safety for those affected by fugitive methane and volatile organic compounds produced at all stages of the gas and oil production process.


As you consider the reams of technical comments received in this docket, I ask that you recognize that the hydraulic fracturing process for developing natural gas from deep shale formations happens in neighborhoods, next to schools, in and under parks and on farms where our food is grown. The industry has intruded with impunity into the most intimate parts of communities and sets up industrial operations adjacent to sensitive areas and in watersheds. Fugitive emissions from such operations affect people where we live, work and play. The EPA’s mission is to protect human health and the environment, but has lost the confidence of the people because the industry has eviscerated its capacity to act strongly in the public interest. The EPA’s purpose is to ensure that all Americans are protected from significant risks to human health and the environment where they live, learn and work. These regulations restricting the emission of methane and volatile organic compounds from oil and gas industrial operations must draw a clear line of safety for the public.


Hydraulic fracturing now takes place in 39 states, with millions of people living within five miles of a fracking facility. For people in the zone of impact, the national average data used for assessing “significant risk” are not relevant. If your house is within 100 feet of a well, or your school is 200 feet from a compression station, or your business is 300 feet from a processing facility, you are exposed to numerous volatile organic compounds. Theo Colborn and colleagues compiled a list of 632 chemicals (an incomplete list due to trade secrecy exemptions) identified from drilling operations throughout the U.S. Their research found that 75% of the chemicals could affect the skin, eyes, and other sensory organs, and the respiratory and gastrointestinal systems. Approximately 40–50% could affect the brain/nervous system, immune and cardiovascular systems, and the kidneys; 37% could affect the endocrine system; and 25% could cause cancer and mutations.[2]


Fugitive methane mobilized by the fracking process has migrated into water supplies, even wells posing significant health and safety hazards to the persons affected. Inquiries for documentation about the number of people for whom the gas companies are providing trucked drinking water were not obtainable, as proprietary information. Requests for documentation of the composition of emissions were not obtainable because the industry has no requirement to disclose, or even measure what they are. This arrogant attitude of disregard for the concerns of people about their health and safety cannot stand.


These regulations on methane and VOC emissions should apply to existing oil and gas facilities as well as new and major modifications. Strengthen the requirements for documentation and reporting of leaks at all stages of the operations: Pre-production, Production, Processing and Transmission.[3] Establishing required protocols for monitoring and reporting leakages of methane and volatile organic compounds will contribute to the understanding of this entire system.[4] Annual or semi-annual data collection is insufficient to protect the public health.[5] Continuous monitoring stations should be required for every unconventional oil and gas facility that is within five miles of residences, businesses, schools, parks or populated areas. The data from such monitoring stations should be publicly available, and local authorities should be notified when levels exceed established limits of safety. Corporate voluntary compliance protocols are inadequate to protect the public health and safety.


Uncertainty remains over a potential environmental benefit of High Volume Hydraulic Fracturing that has public health implications. Natural gas is more efficient and cleaner burning than coal. When burned, natural gas releases 58% less CO2 than coal and 33% less CO2 than oil. Because of that, it has been promoted as a transitional fuel to begin conversion to greener energy such as wind and solar. Although natural gas burns more cleanly than coal, a recent study argues that replacing all of the world’s coal power plants with natural gas would do little to slow global warming this century. Switching from coal to natural gas would cut the warming effect in 100 years’ time by only about 20%. [6]Although a 20% decrease in warming over 100 years is significant, the consequences of the warming not prevented will have grave implications for public health.[7]


If the objective of this regulation is to reduce the emission of methane and other VOC’s as greenhouse gases affecting climate change, I question the effectiveness of the investment contemplated in this regulation as the best way to do so. As stated in the background of this proposed regulation, the EPA estimates the total capital cost alone of the proposed regulation will be $170 to $180 million in 2020 and $280 to $330 million in 2025. This amount of investment in solar and renewable technology implementation would have a far greater positive effect on greenhouse gas reductions with virtually no public health effects. We require a comprehensive energy policy that moves forward to an economy that is not based on fossil fuels. Continuing to build out the infrastructure, fine-tuning the way we extract oil and gas, is not solving the underlying problem.


Specific Recommendations:[8]

Recognizing that the process is in motion, the following specific recommendations may help to make these regulations more effective.


  1. Require Reduced Emission Completions (REC), also known as “green completion,” to reduce methane and other VOC leaks for all wells, not only gas wells. RECs and green completions refer to technologies that capture methane and other gases at the well head during and after well completion and avoid their release into the atmosphere.
  2. Require Leak detection and repair (LDAR) programs for all stages of oil and gas development.
  3. Require advanced technologies to control fugitive emissions.
  4. Require reduction of diesel particulate matter through the use of cleaner combustion engines and alternative fuel types at oil and gas development operations, especially in the transport of water, wastes and chemicals from High Volume Hydraulic Fracturing operations.
  5. Limit venting and flaring gas associated with oil production and ensure that all gas is captured or used on-site.
  6. Require comprehensive characterization of all pollution sources in unconventional oil and gas development and quantitative assessment of pollutants and emission rates through research and updated federal and state inventories.
  7. Improve air quality monitoring before, during, and after well development and around all sources.
  8. Expand the federal and state ozone monitoring network to better characterize air quality in rural areas highly impacted by pollution from oil and gas development.
  9. Require identification and implementation of adequate and protective setback requirements to reduce the exposure of residents to intermittent and chronic levels of air pollutants and toxins. Such research could draw on findings from analyzing the dispersion of air pollution as a function of the distance from road traffic and consider data from the effects of new or existing setback rules in states with unconventional oil and gas development. See, for example, the study being conducted by the Geisinger Health System in Pennsylvania.[9]


In closing, I call for the closure of regulatory loopholes in federal environmental programs to fill data gaps, increase transparency and oversight of the oil and gas industry and ensure public health protections. As the evidence of significant and ongoing public health effects from unconventional oil and gas drilling accumulate, it is unconscionable to continue expanding and protecting this industry. In the interest of protecting the health of our planet and the health of our people, we must cease developing fossil deposits that are destroying our life support system.


Thank you.


[1] See full Curriculum Vitae at


[2] Colborn T, Kwiatkowski C, Schultz K, Bachran M. 2012. Natural Gas Operations from a Public Health Perspective, Human and Ecological Risk Assessment: an International Journal 17(5):1039-1056.

[3] J. Bradbury, M. Obeiter, L. Drucker, A. Stevens, W. Wang. “Clearing the Air – Reducing Upstream Greenhouse Gas Emissions from the U.S. Natural Gas System.” World Resources Institute. April 2013. Accessed September 25, 2015.

[4] Ramon Alvarez, Steven Pacala, James Winebrake, William A. Chaneides and Steven P. Hamburg. “Greater Focus Needed on Methane Leakage from Natural Gas Infrastructure.” PNAS. Vol. 109 no. 17. Pp. 6435-6440. Accessed September 25, 2015.

[5] Bamberger, M., Oswald, R. (2012).Impacts of Gas Drilling on Animal and Human HealthNew Solutions: A Journal of Environmental and Occupational Health, 22(1): 51-77.

[6] Finkel ML, Law A. The rush to drill for natural gas: a public health cautionary tale. Am J Public Health. 2011;101(5):784–785.

[7] Howarth R, Santoro R, Ingraffea A. Methane and the greenhouse-gas footprint of natural gas from shale formations. Clim Change. 2011;106(4):679–690.

[8] Tanja Srebotnjak Miriam Rotkin-Ellman. “Fracking Fumes – Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities.” Natural Resources Defense Council. Issue Paper ip:14-10-a. December 2014. Accessed September 24, 2015.

[9] Geisinger Research, “Geisinger Leads Marcellus Shale Initiative Coalition Explores the Potential Health Effects of Natural Gas Mining in the Region,” Geisinger Research Connections Winter: 1–3, 2013.