March 27, 2024
Doug Ito
State Oil & Gas Supervisor
California Geologic Energy Management Division
715 P Street, MS 1803
Sacramento, CA 95814
Via email: Doug.Ito@conservation.ca.gov and CalGEMRegulations@conservation.ca.gov
Re: Support for the Well Stimulation Treatment (WST) Permitting Phase-Out Regulations
Dear Supervisor Ito,
Thank you for the opportunity to provide written public comment on this draft rulemaking addressing public health and safety impacts from oil and gas production operations in California. The undersigned over 100 organizations write to express strong support for the Well Stimulation Treatment (WST) Permitting Phase-Out Regulations. Given California’s status as the seventh largest oil producing state in the country and the fifth largest economy in the world, this rule is not only urgently needed to protect California’s communities and environment, it will also show climate leadership nationally and internationally at a critical time. As such, we urge you to complete this vital rule quickly. Additionally, we urge you to build on this leadership with further action to address the grave public health and climate threats that are similarly associated with enhanced oil recovery and all new oil and gas extraction.
Fracking and other dangerous forms of well stimulation in California have plagued our communities for decades, as oil and gas companies placed extraction and profits above the health of residents. The pollution from fracking contributes to a litany of health issues caused by oil and gas drilling, including nausea, rashes, cardiovascular disease, pregnancy complications, and more. This is in addition to fracking’s global impact, as the greenhouse gas emissions associated with the fossil fuel extraction and use that fracking facilitates further destabilize our already imperiled climate.
In 2021, Governor Newsom instructed CalGEM to carry out this rulemaking, in line with CalGEM’s stated mission to prioritize protecting public health, safety and the environment in its oversight of the oil and gas industries in order to help California achieve its landmark climate and clean energy goals. Later that year, CalGEM took firm action and began correctly exercising its authority to deny fracking permits on public health and climate grounds. The agency can and should continue to act on its authority to deny permits that pose a danger to public health, including by adopting the proposed WST phase-out.
The completion of this rulemaking is imperative and urgent. Fracking has no place in any community – let alone environmental justice communities already overburdened by several health risks, with fracking and other well stimulation methods worsening the health harms our residents already face and are forced to endure. The completion of this rulemaking in 2024 will bring greater safety to our communities and demonstrate to the public that CalGEM, and their government, prioritizes public health and safety.
Additionally, to help inform public comment on CalGEM’s rulemaking efforts, we call for the release of the full public health expert advisory committee report as a resource to better understand the public health risks of oil and gas production in California. These findings are relevant to this proposed prohibition of WST permitting because the rulemaking requires a comprehensive assessment of public health benefits associated with limiting proximity of sensitive receptors to oil and gas production in California, and the expert advisory committee’s findings indicate “a causal relationship between close geographic proximity to oil and gas development and adverse respiratory and perinatal outcomes.” While a summary of the full public health expert advisory report was made public, and is cited in the Initial Statement of Reasons (p. 8), we call on CalGEM to release the full report so that all residents who live, work, study, play, or do business near an oil and gas production site are informed of the risks that extraction poses to their community health.
We also know that this rulemaking is one important step of many needed on the path to a healthy, just, and climate-safe future. Enhanced oil recovery techniques, including high pressure cyclic steam injection, result in many of the same health and safety, environmental, and climate harms as fracking. Indeed, CalGEM’s advisory panel identified a “causal relationship” between proximity to “oil and gas development” in general, not just fracking specifically, and adverse health impacts. Given these impacts, CalGEM must also continue to phase out oil and gas extraction. We view this fracking rulemaking as one of many subsequent efforts to create the safe and sustainable California that CalGEM envisions.
CalGEM is California’s leading agency when it comes to regulating oil and gas extraction, and it must continue to prioritize our health and climate when regulating oil and gas.
Sincerely,
Kobi Naseck
Coalition Director
VISIÓN (Voices in Solidarity Against Oil in Neighborhoods)
Susan Penner
Co-Chair, Legislative Working Group
1000 Grandmothers for Future Generations
Valerie Ventre-Hutton
Legislative Volunteer
350 Bay Area Action
Alan Weiner
Chapter Lead
350 Conejo / San Fernando Valley
Will Brieger
Chair, Legislation & Policy Team
350 Sacramento
Carol Millar
Steering Committee Member
350 Santa Barbara
Cheryl Weiden
Member, Steering Committee
350 Silicon Valley
Patty Glueck
Co-Founder
Aliso Moms Alliance
Robert J. “Roy” van de Hoek
Environmental Scientist
Ballona Wetlands Institute
David F. Gassman
Co-Convenor
Bay Area-System Change Not Climate Change
Haleemah Atobiloye
Program Manager
Breast Cancer Action
Ana Rosa Rizo-Centino
Board President
Central Coast Environmental Voters (CCEV)
Katie Valenzuela
Senior Policy Advocate
Central Valley Air Quality Coalition (CVAQ)
Lisabeth Ryder
Co-Chair
CERBAT
Tama Becker-Varano
Lead Organizer
Change Begins With ME (Indivisible)
Suzanne Hume
Leader
CleanEarth4Kids.org
Janet Cox
CEO
Climate Action California
Haley Ehlers
Executive Director
Climate First: Replacing Oil & Gas (CFROG)
RL Miller
President
Climate Hawks Vote
Amanda Millstein
Medical Doctor, Co-Founder
Climate Health Now
Rev. Charlotte Bear
Co-Chair
Climate Reality Project: Monterey Bay
Miguel Alatorre Jr.
Executive Director
El Pueblo Para el Aire y Agua Limpia de Kettleman City
Meghan Sahli-Wells
California Director
Elected Officials to Protect America
Linda Krop
Chief Counsel
Environmental Defense Center
Bill Allayaud
CA Director of Government Affairs
Environmental Working Group
Leah Redwood
Action Coordinator
Extinction Rebellion San Francisco Bay Area
Chirag G Bhakta
California Director
Food & Water Watch
Lauren Ornelas
Founder & Senior Programs Director
Food Empowerment Project
Miriam Eide
Executive Director
Fossil Free California
Kyle Ferrar
Western Program Director
FracTracker Alliance
Nicole Ghio
Senior Fossil Fuels Program Manager
Friends of the Earth
Betsy Taylor
Executive Director
Livelihoods Knowledge Exchange Network (LiKEN)
Dave Shukla
Operations Director
Long Beach Alliance for Clean Energy
Karen Reside
President
Long Beach Gray Panthers
Joanne Hadley
Founder/coordinator
Manhattan Beach Huddle
Alicia Nichols-Gonzalez
State Manager
Mothers Out Front
Paulina Torres
Staff Attorney
Natural Resources Defense Council
John Sorensen
Member
NorCal Elders Action Network
David Warren
Member
Northern California Elders Climate Action
Michael Stocker
Director
Ocean Conservation Research
Ilonka Zlatar
Organizer
Oil and Gas Action Network
Bill Sive
West Coast Coordinator
Queers X Climate
Chance Cutrano
Director of Programs
Resource Renewal Institute
David Swanson
Campaign Coordinator
RootsAction.org
Glayol Sahba MD
Steering Committee Member
Sacramento Climate Coalition
Emily Brandt
Secretary
San Joaquin Valley Democratic Club
Robert Whitehair
Co Leader
San Mateo Climate Action Team
Masada Disenhouse
Executive Director
SanDiego350
Rachel Altman
Administrator
Santa Barbara Standing Rock Coalition
Pauline Seales
Organizer
Santa Cruz Climate Action Network
Steve Palmisano
Leader of Earth Care Group
Santa Cruz Zen Center
Miguel Alatorre Jr.
Executive Director
The UNIDOS Network
Diana Cassady
Facilitator
Third Act Sacramento
Allan Moskowitz CFP
CEO
Transformative Wealth Management, LLC
Carla D Grady
Admin
Transition Sebastopol
Valerie Kuo
Co-Executive Director
USC Environmental Student Assembly
Jed Pauker
Leader
Venice Resistance
Karina Maher, MD
Member
Voting 4 Climate & Health
Janice Schroeder
Core Member
West Berkeley Alliance for Clean Air and Safe Jobs
Mati Waiya
Executive Director
Wishtoyo Foundation
Woody Little
Organizing and Special Projects Manager
Last Chance Alliance
Cori Lopez
Coordinator
CA Youth vs. Big Oil
Igor Tregub
Chair
CADEM Environmental Caucus
Melissa Romero
Deputy Legislative Director
California Environmental Voters
Susan Stephenson
Executive Director
California Interfaith Power & Light
Barbara Sattler
Leadership Council
California Nurses for Environmental Health and Justice
Hollin Kretzmann
Senior Attorney
Center for Biological Diversity
Marven Norman
Policy Coordinator
Center for Community Action and Environmental Justice
Gustavo Aguirre Jr.
Climate Equity & Environmental Justice Director
Central California Asthma Collaborative
Nayamin Martinez
Executive Director
Central California Environmental Justice Network
Mark Accomando
Co-Chair
Climate Reality Project: Riverside County
Cherry Robinson
Coalitions Chair
Climate Reality Project: San Diego
Dee Fromm
Managing Director
Coastal Lands Action Network
Moshe Heyn
Rabbi
Coastside Jewish Community
Bahram Fazeli
Policy Director
Communities for a Better Environment
Liza Tucker
Consumer Advocate
Consumer Watchdog
Muriel MacDonald
Deputy Organizing Director
Dayenu: A Jewish Call to Climate Action
Marcia Hanscom
Community Organizer
Defend Ballona Wetlands
Elizabeth A. Fisher
Senior Attorney
Earthjustice
Martin Bourque
Executive Director
Ecology Center
Zachary Norris
California Climate Director
Greenpeace USA
Mordecai Cohen Ettinger
Founding Director
Health Justice Commons
Jennifer Tanner
Leader
Indivisible CA Green Team
Susan Morgan
Founder and Director
Indivisible Marin
Rebecca Elliot
Admin
Indivisible San Jose
Peter Hosey
Steering Committee member
Indivisible SF
Veronica Wilson
California Organizer
Labor Network for Sustainability
Bonnie Lockhart
Organizer
Labor Rise Climate Jobs Action Group
Joey Smith
Owner & Manager
Let’s Go Farm
Leslie Austin
Director
Let’s Green CA!
Allie Rosenbluth
US Program Manager
Oil Change International
Alison Huyett
Campaigns Director
Patagonia
Martha Dina Argüello
Executive Director
Physicians for Social Responsibility – Los Angeles
Harry Wang, MD
President
Physicians for Social Responsibility – Sacramento
Robert M. Gould, MD
President
Physicians for Social Responsibility – San Francisco Bay
Alejandra Warren
Executive Director
Plastic Free Future
Faith Strailey
Chair
Plumas County Democratic Central Committee
Matt Nelson
Executive Director
Presente.org
Faith Myhra
Member
Protect Playa Now
Martha Camacho Rodriguez
Director
SEE (Social Eco Education)
Gabriela Facio
Senior Policy Strategist
Sierra Club California
Nathan Taft
Senior Digital Campaigner
Stand.earth
Shoshana Wechsler
Co-Coordinator
Sunflower Alliance
Marilyn Price
Co-Chair
Sustainable Mill Valley
Steve Willett
Coordinating Committee Member
SystemChangeNotClimateChange
Kayla Karimi
Staff Attorney
The Center on Race, Poverty, and the Environment
Magi Amma
Chair
The Climate Alliance of Santa Cruz County
Woody Hastings
Phase Out Polluting Fuels Program Manager
The Climate Center
Manuel J. Espinosa
Principal
The Phoenix Group