Good morning everyone, and thank you, Commissioners. My name is Emma Pabst and I’m the Global Warming Solutions Associate with Environment Texas -- a non-profit advocate for clean air, clean water, and open spaces.
We support curtailing oil production and urge you to prioritize production cuts for producers and fields with the worst records of excessive flaring.
In implementing proration, the RRC has a unique opportunity to make a difference for public health and the environment in Texas by using waste from excessive flaring as a metric for allocating production.
The Commission’s constant approval of flaring permits, has created, as Chairman Christian recently stated, an “incentive to flare out of convenience and economics rather than necessity,” which may explain why, in 2019, producers flared and vented enough gas to power the state of Texas for an entire year.
Research shows that flaring in the Permian Basin emits as much smog-forming nitrogen oxide pollution as nearly three mid-size coal-fired power plants, and yet, reported quantities of flaring remain much lower than satellite imagery reveals. The Texas Commission on Environmental Quality noted that sulfur dioxide, another dangerous byproduct of flaring, frequently exceeds safe levels in Texas’ Permian Basin.
You must stop polluters from poisoning our air and water and jeopardizing the future of my generation and that of my children. According to the federal government, left unaddressed, global warming will cause billions of dollars in property damage along the Texas coast and lead to an additional 1,300 deaths due to extreme heat in Texas per year. It’s clear Texas must dramatically reduce its carbon emissions, and according to analysis from Environment Texas, flaring in the Permian basin contributed to over 2% of projected US greenhouse gas emissions in 2019.
As Commissioner Sitton and Rystad energy have already done the research on which companies have the worst rates of flaring, it shouldn’t be too difficult to develop a proration plan which has co-benefits for public health.
When our legislators charged the Commission with defending the state we call home, they entrusted each of you with the time-honored duty of preserving Texas’ natural resources and environment. Today, you have the opportunity to honor that legacy. In a state with seven of the country’s ten most at risk counties for asthma attacks, we owe it to our kids to make sure we get this right. I urge you to use the power granted to you by the great state of Texas in order to issue statewide production cuts, prorating cuts to companies with the worst rates of flaring. Such a step will help stabilize the market, while significantly reducing the damage from flaring.
The people of Texas are counting on you to help conserve our natural resources and protect our health and environment.

Thank you.