Public Health Sign On Letter to CalGEM
Uduak-Joe Ntuk,
Supervisor, California Geologic Energy Management Division
Department of Conservation
801 K Street, MS 24-02
Sacramento, CA 95814

RE: Oil and Gas Extraction in California and Public Health Evidence

Dear Supervisor Ntuk:

We, the undersigned organizations and individuals, represent medical, health, and public health professionals from across California. This letter builds upon the statements provided by signatories at several of CalGEM’s pre-rulemaking hearings over the last six weeks – and also represents comments many of us would have made at in-person hearings that were canceled as the result of the COVID-19 pandemic. While so many of us are working on the frontlines of the pandemic response, we want to ensure the State of California takes the most preventive action possible on a different, still dangerous public health crisis confronting our state: oil and gas operations in close proximity to homes, schools, day care centers, health facilities and other sensitive land uses.

We want to ensure that the State uses the most up-to-date and relevant epidemiological research as it considers policies to protect the millions of Californians whose health is currently at risk from oil and gas operations. The report produced in response to SB4 by the California Commission on Science and Technology identified the radius of potential health impact from oil and gas extraction as approximately half a mile (~2650 feet). According to an analysis of CalGEM data (updated 3/3/20), there are 74,775 active wells in California, of which 9,835 wells are within 2500 feet of a sensitive land use (Ferrar, 2020). The total population of California living within 2500 feet of an active well is over 850,000 (Ferrar et al., 2018). There are 121,903 students who go to school within half a mile of an active drill site in California (Ferrar, 2020).

Recent reviews of scientific literature show growing evidence of adverse exposure and health impacts associated with petroleum extraction (Deziel et al, 2020; Johnston, Lim, & Roh, 2018; Shonkoff, Hays, & Finkel, 2014). A single drill site typically operates for decades and the extraction process produces emissions of multiple health-hazardous air pollutants, including benzene, toluene, ethylbenzene, xylene, formaldehyde, hydrogen sulfide, and methylene chloride. Many of these compounds are known to be toxic to human health and are classified as carcinogens, causing respiratory harm, and endocrine disruptors. Many of them also cause long-term developmental or reproductive harm—a consideration for health across generations (Zielinska, Campbell, & Samburova, 2014; Moore, Zielinska, Pétron, & Jackson, 2014; Field, Soltis, & Murphy, 2014; Colborn, Schultz, Herrick, & Kwiatkowski, 2013). These chemicals can migrate off-site due to permitted and fugitive emissions, spills, leaks, or accidents.

The current body of knowledge draws from scientific studies on upstream oil and gas extraction from across diverse areas of the US and globally and provides a substantive and credible body of evidence to inform public health efforts by the State of California. For example, despite diversity in extraction techniques, geology and local populations, scientific studies have consistently identified drilling activities to be significantly associated with adverse birth outcomes in Pennsylvania (Casey et al., 2015; Hill, 2012; Stacy et al., 2015), Colorado (McKenzie et al., 2014; McKenzie, Allshouse, & Daniels, 2019), Texas (Whitworth, Marshall, & Symanski, 2017; Walker Whitworth, Kaye Marshall, & Symanski, 2018) and Oklahoma (Janitz, Dao, Campbell, Stoner, & Peck, 2019). While the exposure measurements in these studies vary based on the community, such adverse perinatal effects are associated with material proximity of ½ mile to 3 miles from drill activity.

From the perspective of all Californians, and the world, oil and gas production is also a major driver of climate change. Extraction is the primary step in a larger fossil fuel cycle that is responsible for the greenhouse gas emissions that are causing global warming. Climate change poses the greatest health threat humanity has ever faced. Warming temperatures and increasing extreme weather threaten our health, air, water, food, shelter, and economic security, posing an existential threat to humanity. Health professionals in California, the U.S. and globally recognize that climate change is impacting the health of people now and is a health emergency that ultimately is as grave as the current COVID-19 crisis, if not more so.

In California alone, if we continue with burning fossil fuels per usual, the coming decades will bring an increase in the average annual maximum daily temperature by up to 8.8 degrees Fahrenheit, a decrease in water supply from snowpack by up to two-thirds, an increase of 77% of total area burned by wildfire, and complete erosion of up to two-thirds of all beaches in the Southern part of our state. All of these changes have dire health consequences, especially for our children and future generations.

California is perceived as a national and global leader in the fight against climate change and has made a clear commitment to reduce its greenhouse gas emissions through an equitable transition to healthy, clean, renewable energy. If our children – and their children – are to inherit a liveable planet, we must transition away from oil and gas extraction immediately to clean, renewable energy. Moreover, the health impacts resulting from climate change are – and will continue to be – felt first and worst by disenfranchised communities, exacerbating existing health, social, and economic injustice. Black, Latino and other marginalized and low-income communities living fence-line to oil operations in California already bear a disproportionate burden of health impacts associated with fossil fuel production. Indigenous communities on whose ancestral lands the oil is extracted bear the generational impacts. In all ways, continuing to drill for oil -- rather than transitioning as quickly as possible to clean, renewable energy -- is antithetical to our vision for a healthy and just California. As health professionals we understand that health is inextricably tied to justice, and that upstream solutions, hard though they may be, save lives.

We the undersigned ask CalGEM to take preventive action to protect public health given the substantial and growing body of epidemiologic and toxicologic evidence about the negative health effects of oil and gas drilling, including:

- Immediately implement physical setbacks of at least 2500 feet to protect the health of the babies, children and adults most immediately impacted by oil and gas development in California.

- Strengthen the regulation of the chemicals used in oil and gas drilling, requiring full disclosure by privately owned companies of the toxicity, use, and disposal of all chemicals involved in oil and gas drilling, extraction, maintenance, odor control and all other uses.

- In the short time period before complete cessation of fossil fuel drilling in California, strengthen the permitting process to evaluate and fully mitigate all potential health impacts prior to the approval of any new wells or expansion of existing wells.

- Increase exposure monitoring, including monitoring for excursions and leaks with real-time public disclosure.

- Immediately prohibit use of diesel engines at oil production sites.

- Create a dedicated CalGEM health advisory group with representatives from local health departments, public health NGOs, independent research institutions, and organizations representing clinical health professionals and community health experts. Specifically, this health advisory group could offer guidance to CalGEM in evaluating the health harms of chemicals used in oil and gas extraction, interpreting the health implications of excursions and leaks and translating this information to the public, evaluating the health implications of new requests for permits, and developing a better framework for understanding cumulative impacts.

- Develop an expedited plan and timeline to cease oil and gas extraction and production in California, bringing the State into full alignment with the climate goals laid out by the Intergovernmental Panel on Climate Change.

- Work with other state agencies to develop a comprehensive just transition plan aimed at 1) the proper abandonment, clean up and remediation of oil wells; and 2) robust investments to protect workers in the fossil-fuel industry who stand to lose their jobs and the people in communities where oil production is currently a key part of the regional economy. Specifically, CalGEM should pursue policies to ensure that fossil fuel companies, rather than taxpayers, bear the cost of abandonment, clean-up and worker transition, including but not limited to strengthening bonding requirements for operators.

- Strengthen engagement with indigenous communities in this process and overall, including meeting with tribes to understand the specific health and safety issues facing tribes whose lands have been appropriated and developing protocols for clean-up of oil spills on indigenous lands.

Fossil fuel extraction is an industrial practice that does not belong in our communities or in our California. The health and safety risks posed by oil and gas extraction are both significant and well documented. There is no reason for this inherently dangerous practice to continue harming the health of Californians when safer, cleaner alternatives exist.

As health professionals, we have a responsibility to speak out against the practices and policies that are harming the health of our patients and communities. Moreover, the integration of public health into CalGEM’s mission and this first public health rule-making process in your agency’s history (including its previous incarnations) provides an opportunity to build a long-term partnership with the public health community. We would welcome such a relationship, not just to support establishing the strongest possible health protective regulations in the current process, but also in developing policies over time that move us upstream and transition to a clean, health-promoting and just energy system. Our lives - and our children’s lives - depend on it.

References found here:

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