Tag Archives: testimony

William Lochstet Comments on Methane Emissions, August 2016

On August 4, 2016, PA IPL member William Lochstet delivered the following testimony on the topic of methane emissions to the Pennsylvania Department of Environmental Protection’s Air Quality Technical Advisory Committee.

________________________________

The EPA has found that the current and projected concentrations of the six greenhouse gases (GHGs) in the atmosphere threaten the public health and welfare of current and future generations through climate change.

Our climate is a common good we share with our neighbors. Many religious traditions address the question of who is my neighbor. Christianity suggests that even persons normally rejected by society are actually neighbors. The Pope recently wrote of the earth as our common home. Native American tradition suggests that neighbors extend seven generations into the future. We are all brothers and sisters together now, in the past and into the future. What we put into the atmosphere today will have effects years and centuries into the future.

We had hoped to reduce global warming by replacing coal with natural gas since it results in less carbon dioxide (CO2) per unit of energy produced, when burned. But, we find that so much methane is released along the way, that the overall climate change effect is greater.

The Global Warming Potential (GWP) of methane and CO2 need to be understood in relation to time. When CO2 is released into the atmosphere, it stays there for a long time, and produces a steady warming effect. Methane in air undergoes chemical reactions on a time scale of about 12 years, which ultimately produces CO2 and water vapor. A methane release has a huge warming effect in the beginning, but is equal to CO2 after several decades. The Global Warming Potential for methane is between 84 and 87 over 20 years, according to EPA. This can have a huge effect on the weather events that you and I will experience in the next 10 or 20 years. This is important for immediate disaster preparedness. It is important to present global warming projections in both 100-year and 20-year time frames.

We need to reduce methane emissions by half very quickly. The Natural Gas STAR Program is voluntary, and therefore will not succeed. California is considering a 45% reduction in greenhouse gases emissions, below 2012 levels by 2025.

Lastly, the United Church of Christ at its National meeting last June adopted a resolution calling for the complete transition to renewable energy by 2040.

William Lochstet Comments on Environmental Impact of the Atlantic Sunrise Project, June 2016

In June 2016, PA IPL board member William A. Lochstet submitted the following comments to the Federal Energy Regulatory Commission in regards to the Draft Environmental Impact Statement for the Atlantic Sunrise Project:

The staff of the Federal Energy Regulatory Commission (FERC) has prepared a draft environmental impact statement, FERC/EIS-0269D, for the Atlantic Sunrise Project, Docket No. CP15-138-000, (Ref. 1). This report (Page 4-196) states that:

The EPA found that the current and projected concentrations of the six GHGs in the atmosphere threaten the public health and welfare of current and future generations through climate change.

However, this report concludes (Ref. 1, Page 4-289) that the net change in GreenHouse Gas (GHG) emissions from operation of this project would be less than 0.1 percent of the year 2005 Pennsylvania total of 313 million metric tons of CO2 equivalent. The impacts of Marcellus Shale wells and gathering systems are ignored in this conclusion even though these are specifically highlighted (Ref. 1, Page 4-259). This report (Ref. 1, Page 4-288) also states:

Although climate change is a global concern, for this cumulative analysis, we will focus on the potential cumulative impacts of climate change in the Atlantic Sunrise Project area.

Such a choice ignores most of the earth where many more impacts will occur. How narrow a focus is appropriate for personal responsibility? Consider that person A drives person B to a bank to rob it. Person B is held for bank robbery. But person A only provided transportation to his/her friend who wanted to go to the bank. The law considers person A to be an “accessory,” which is also a crime. This is a broader focus which considers more of the whole.

Many religious traditions address the question of who is my neighbor. Christianity suggests that even persons normally rejected by society are actually neighbors. Native American tradition suggests that neighbors extend seven generations into the future. We are all brothers and sisters together now, in the past and into the future. How narrow a focus would our legal system allow?

Our environmental laws also take a broader view as is required by the National Environmental Policy Act of 1969 (NEPA), as amended. In fact, this position has been upheld by the court in Calvert Cliffs Coordinating Committee v. USAEC, 449 F. 2nd 1109 (D.C. Cir., 1971) which states:

We conclude, then, that Section 102 of NEPA mandates a particular sort of careful and informed decision-making process and creates judicially enforceable duties……But if the decision was reached procedurally without individualized consideration and balancing of environmental factors–conducted fully and in good faith—it is the responsibility of the courts to reverse.

Therefore, we will consider a full Life Cycle Analysis (LCA) for this entire system.

This pipeline does not exist as a whole, without connecting to a source of natural gas and a customer who has an intent to utilize its energy for a useful purpose. The Project would move 1.65 billion cubic feet per day (Ref. 1, Page 1-2) of natural gas. Using the good approximation that this is pure methane, there are 12 million metric tons of methane transported per year. If this methane is burned by the customers, it yields 33 million metric tons of CO2, and some water. Methane escapes into the air at the well site, during storage, processing, and delivery to customers. The total leak rate is estimated to be in the range of 3.6% to 7.9% of production, with a mean value of 5.8% of production (Ref 2). Taking production to be 12 million metric tons of methane, which is an underestimation, the total leaked in a year is 0.71 million metric tons of methane. Methane has an enormous Global Warming Potential (GWP) in the first few decades after release, before it undergoes chemical reactions and is no longer methane. This prompt surge in global temperature rise could trigger any of several tipping points. For instance, a large sudden rise in temperature for a few decades could melt the polar ice cap, so that it absorbs summer sunlight, rather than reflecting it as snow and ice do. Thus, the short term is important to consider here. Using the GWP of methane for the first 20 years of 86 (Ref. 3), the 0.71 million metric tons of methane is equivalent to 61 million metric tons of CO2. The total warming effect due to operation of this entire system for one year is the sum of the methane burned or leaked. This sum is 94 million metric tons CO2e over the first 20 years.

This EIS reports that, in 2005, Pennsylvania emitted 313 million metric tons CO2e of GHG (Ref.1, Page 4-289). There is no indication if this is for a 20 year or 100 year period, or what the separate quantities of the GHGs were in 2005. The report goes on to compare this value with its estimate of CO2e emissions from operation of the project. Nevertheless, 94 million metric tons is about 30% of 313 million metric tons. This pipeline does not operate, or exist without these other emissions.

It might be argued that 94 million metric tons CO2e is too small to be considered. Taken alone, it might not do much harm, but consider raindrops. One raindrop is not a problem, but put enough of them together and there is a flood. Every little bit counts! We are like the alcoholic who says that one little drink will not matter. Every ton of fossil carbon that is added to the atmosphere is a threat to our present and future, as was quoted in the EIS and repeated at the beginning of these comments.

Normal Methane Releases

In the normal routine of operation of this pipeline, there are activities which will release natural gas to the atmosphere. Some of these are ordinary operating and maintenance activities at compressor stations, meter stations, regulator stations and mainline valve sites. It would be helpful, and produce a more complete picture if the final EIS would present numerical values for these expected releases. It is unsatisfactory to merely state that they are not significant. Let the public see the numbers, and then let them decide.

Miscellaneous Comments

Section 4.9.8 discusses environmental justice issues (Ref. 1, Page 4-177). It presents population data by county, only. In order to conclude that no population group is disproportionately burdened by the project, it would be necessary to survey the pipeline path, rather than the whole counties. The data presented does not support the conclusion presented of no disproportionate burden.

Section 4.11.1.1 has a portion headed “Greenhouse Gases” ( Ref. 1, Page 4-196). This states that methane has a GWP of 25 over a 100-year time period which is from the IPCC 4th Assessment Report of 2007. The correct value as of the IPCC 5th Assessment Report of 2013 (Ref. 3) is 34 over 100 years, and 86 over 20 years. It would be helpful to compare GHG impacts over both the 100 year time period and the 20year time period, Please use up to date information.

Sections 4.11.1.3 and 4.13.8.10 describe the operation of compressor stations 605 and 610 which are to be powered by electric motors, with a natural gas-fired emergency generator (Ref. 1, Pages 4-208, 4-210, 4-289). The text seems to assume that the electricity has no GHG emissions. Since Pennsylvania is an electric choice state, the GHG burden for this electricity would depend on which supplier is chosen, and is not presently indicated. The GHG burden of the source of the electricity should be included.

Section 4.13.8.10 also states: “Methane (CH4), which is a product of natural-gas fuel combustion…” (Ref. 1, Page 4-289). Combustion of natural gas results in CO2 and water. Please correct this simple typo.

Section 4.13.8.10 also states : “Natural gas is a lower CO2 emitting fuel when compared to other fuel sources (e.g., fuel oil or coal),” and “This would result in a potential reduction is regional GHG emissions” (Ref. 1, Page 4-289). It is true that burning natural gas in a boiler produces less CO2, at the boiler, than burning coal. However, as described at the beginning of these comments, there are many places where methane escapes into the air, and so much escapes that the result is the GHG effect of burning natural gas exceeds the GHG effect of using either coal or oil (Ref. 2). Using natural gas is worse than coal for climate change. This is the life cycle analysis.

Conclusions

It is not only necessary to evaluate the environmental impact of this project to the region within 10 or 20 miles of the pipeline, but also to consider the impact to the entire country, and perhaps even also the rest of the world. Many faith traditions tell us that we are all brothers and sisters together on this planet. Operation of this pipeline for one year will be accompanied by the release of 94 million metric tons CO2e when evaluated over the first 20 years. This impact is greater than would be realized from using coal, which is far too polluting. And, this impact is also about 30% of the emissions for the entire state of Pennsylvania in 2005. The EPA recognizes that the current and projected concentrations of GHGs in the atmosphere threaten public health and welfare of current and future generations. This pipeline is thus a threat to public health and welfare, now and in the future. As a threat, this pipeline cannot be a public convenience or necessity.

References

  1. U.S. Federal Energy Regulatory Commission, 2016, Draft Environmental Impact Statement, Atlantic Sunrise Project, Transcontinental Gas Pipeline Company, LLC, FERC/EIS-0269D, Docket No. CP15-138-000, Accessed May 2016.
  1. Howarth, R.W., 2014, A bridge to nowhere: Methane emissions and the greenhouse gas footprint of natural gas, Energy Science and Engineering ; 2(2): 47-60 DOI: 10.1002/ese3.35
  1. IPCC. 2013. Climate change 2013: the physical science basis. Intergovernmental Panel on Climate Change. Available at: https://www.ipcc.ch/report/ar5/wg1, Accessed July 2014

_________________________

Pennsylvania Interfaith Power & Light is a community of congregations, faith-based organizations, and individuals of faith responding to climate change as a moral issue, through advocacy, energy conservation, energy efficiency, and the use of clean, renewable energy.

Rachel Mark Comments to IRRC on Oil & Gas Site Standards

On April 21, 2016, PA IPL member Rachel Mark offered the following statement at a public meeting on the subject of Regulation #7-484: Environmental Protection Performance Standards at Oil and Gas Well Sites

______________________________

I am speaking today as a member of Pennsylvania Interfaith Power & Light, a faith-based organization responding to climate change, and because as a concerned person, I worry every day about the future of the youngest members of my family.

I share the position of Interfaith Power & Light that the use of fossil fuels, including natural gas, is primarily a moral issue. We take seriously the accumulation of evidence by the scientific community that the continued use of fossil fuels is leading to a dangerous and uncertain future, with a very real possibility that our children will inherit a climate and a world that is out of their control. If a climate out of control is hard to conceptualize, we have only to think of the extreme weather conditions that are happening already, the sea level rise occurring in Miami, the current deluge of flooding in Houston, insect-borne diseases, and wild fires which are documented to be hotter than fires in past history.

The benefits of natural gas are usually argued in terms of cost benefit analysis, and lower carbon emissions when compared to coal. Unfortunately, fossil fuels are already creating havoc around the world.

In view of the scientific warnings about the urgency of climate change and about the dangers of continued use of fossil fuels, PA Interfaith Power and Light recently approved a resolution favoring a moratorium on new gas drilling leases and new drilling infrastructure. However, recognizing that we are not yet positioned for an immediate or fast transition to renewable energy, it is more than obvious that informed and appropriate regulations are first and basic steps essential to protect our air and water, and consequently the health and well-being of people and ecosystems.

Of course, we should be protecting our homes and schools. At the same time, we should be thinking long-term rather than short-term, and considering consequences in the world around us. Natural gas is a fossil fuel. We need to stop. If we are unable to stop now, we need to regulate as if our future depends upon it.

DEP Hearings: Rev. Alison Cornish

Rev. Cornish is the Executive Director of PA IPL.  She testified at the PA DEP listening session in Philadelphia County on September 30, 2015.  Alison headshot

Good Afternoon.  I am the Reverend Alison Cornish, and I serve as the Executive Director of Pennsylvania Interfaith Power & Light, a community of congregations, faith-based organizations and individuals of faith responding to climate change as a moral issue.  Through advocacy, energy conservation, energy efficiency and the use of clean, renewable energy, we help people of faith be model stewards of Creation.  We are the Pennsylvania affiliate of Interfaith Power & Light, a national religious response to the threat of climate change.  We see climate change as a moral issue.

We recognize that the Clean Power Plan is the single biggest and most ambitious action the U.S. has ever taken to tackle climate change. It sets the first-ever limits on Continue reading

Methane Testimony: Dan Scheid

IMG_1844I want to thank the EPA for proposing this standard on methane emissions, which is crucial to slow climate change, to improve public health, and to protect our children’s future. I also thank you for inviting public discussion on this issue: it is not a special interest or partisan issue, but is of vital concern to every person now living on the planet, and especially to every resident of Pennsylvania and to every American.

I speak today not only as a resident of Pittsburgh but also as a person of faith, as a Catholic who is inspired by the recent visit of Pope Francis. As some of you may know, Pope Francis issued a major document called Laudato Si’ in June of this year. In Laudato Si’, Pope Francis continues the Catholic Church’s longstanding teaching on climate change, affirming that it is real, that it is a moral issue, and that prudence demands immediate and urgent action.

The encyclical follows a familiar format for Catholic teaching: See-Judge-Act. The first element is to see what is happening, to rely on the “best scientific research available” (§11) today. And science is telling us that methane pollution persists for decades; that Continue reading

Methane Testimony: Joy Bergey

JoyBergeyMy name is Joy Bergey, and I speak in my role as Director of the Environmental Justice Center of Chestnut Hill United Church. Based in Philadelphia, the Center is an inter-religious program working with congregations and individuals to address problems of environmental injustice.

The Environmental Justice Center thanks the EPA for proposing this rule. We urge that it be implemented quickly and not weakened in any way. In fact, we urge that it be strengthened.

I traveled to Pittsburgh from the city that just hosted His Holiness Pope Francis over the weekend.

Given the deeply inspiring message of the Pope, can there be doubt in anyone’s mind at this point that taking strong national action to limit climate change pollution is an urgent moral imperative?

Every major faith tradition calls on its followers to protect those at the margins of society who cannot defend themselves: the young, the old, the sick, the poor. And it is exactly these persons who are being hurt first and worst by climate change.

With no national standards in place to address methane from oil and gas wells, and with the Continue reading