Tag Archives: testimony

We know which way the wind blows. Testimony on air quality

Atlantic Sunrise Pipeline
Air Quality Permit Application
statement to the Pennsylvania Department of Environmental Protection
by William A Lochstet, Ph.D.
Board Member, Pennsylvania Interfaith Power & Light

Bill was Speaker 31 at the DEP hearing in Lancaster on August 14, 2017, and was quoted in Lancaster Online’s article about the hearing.

The Transcontinental Gas Pipeline Company (Transco) is expecting to release 105.4 to 133.5 tons of NOx during the construction of the Atlantic Sunrise Pipeline in Lancaster County. Since this is a non-attainment area for the ozone National Ambient Air Quality Standards (NAAQS), such emissions would exacerbate already excessive ozone concentrations. As a person of faith, I find that many traditions proclaim some form of the rule that we should all do unto others as we would like to be treated. And so, Transco is proposing to offset the impact of these emissions by transferring 106 tons of NOx Emission Reduction Credits (ERC) from Harford County MD.

Because of activity in Harford County, the air contains less NOx, and when it comes here, it can cancel the ozone creating effect of the emissions from the pipeline construction activity. This cleaner air is carried by the wind, whose average directions can be determined by a wind rose from Millersville University for Harrisburg International Airport (attached)[1]. This diagram divides the circle into 16 segments with 3 segments from the more or less proper southwest directions to bring air from Harford County to Lancaster County. Each of these segments represents about a 3% probability, so that we could expect the clean air to arrive about 9 or 10% of the time. Thus we would expect that of the 106 tons of ERC that only 11 tons would arrive in Lancaster County.

Another approach would be to examine the data in the Atlantic Sunrise Plan Approval Application[2]. Environmental Resources Management found 60 days for which the ozone concentrations at the Lancaster monitor exceeded NAAQS. They were able to identify 14 days for which the air quality at the Lancaster monitor was affected by air parcels that passed through the Baltimore area. Then the probability of air moving from Harford County to Lancaster County is 14/60, or 23%, so that we would expect 23% of 106 tons, or 25 tons of ERC to reach Lancaster County.

These calculations predict that Lancaster County will benefit from an offset of eleven (11) to twenty five (25) tons of the ECRs which would   not offset 105 tons of NOx. It does not meet the rule of “Do unto others as we would like to be treated.” A statement in the Air Quality Technical Report[3] is:

Transco’s approach to use ERCs to offset the complete, conservatively estimated                   amount of NOx emissions from Lancaster County will present a net benefit to air quality environment in the local area.

This statement cannot be true. Furthermore, the Code of Federal Regulations requires that the offset have the result “that there is no net increase in emissions of that pollutant.”[4] This requirement is not met. Thus this Air Quality Plan cannot be approved.

Notes
[1]. Available at: http://www.atmos.millersville.edu/~wic/climo/local_WindRose_MDT.jpg
[2]. Available at:     http://files.dep.state.pa.us/ProgramIntegration/PA%20Pipeline%20Portal/AtlanticSunrise/ASR%20GC%20Plan%20Approval%20Application%202017%200711.pdf
Appendix E; Memorandum from Mark Garrison, ERM, 6 December 2016.
[3]. Available at http://files.dep.state.pa.us/ProgramIntegration/PA%20Pipeline%20Portal/AtlanticSunrise/ASR%20GC%20Plan%20Approval%20Application%202017%200711.pdf
Attachment C; Atlantic Sunrise Air Quality Technical Report, P. 9, bottom of page
[4]. At 40 CFR § 93.158(a)(2), and also 40 CFR § 93.158(b)(2)

Proverbs 22:3 Are we simpletons?

On July 10, several Pennsylvania religious leaders traveled to Washington DC to offer in-person testimony to the EPA regarding delay of implementation of New Source Performance Standards for Methane emissions from oil and gas operations.  EPA-HQ-OAR-2010-0505Daniel Swartz at EPA

Good afternoon.  I am Rabbi Daniel Swartz of Temple Hesed of Scranton.  I’m also Board President of Pennsylvania Interfaith Power & Light, which works with congregations and people of faith across Pennsylvania to address the moral dimensions of climate change.  In addition, I have a background in children’s environmental health, including serving for several years on EPA’s Children’s Health Protection Advisory Committee.

The Book of Proverbs gives us blunt advice about how to distinguish between wise and foolish decisions.  In Proverbs 22:3, we read: “the prudent see danger and take cover, but the simpleton keeps going and pays the penalty.”  In the case of the new source rule we are discussing today, we know that there is danger.  We know the solution, one that has already been applied under multiple state-level standards and has been shown to be both practical and affordable. To simply keep going, to put off taking cover by delaying the implementation of this rule, is, by this biblical standard, clearly foolish.

And worse than foolish.  EPA has officially stated that the health and safety risk posed by any delay “may have a disproportionate effect on children.”  To recognize that and yet still call for delay is not just foolish but immoral.

Since 1995, all of EPA regulations and rules are supposed to take into account that children aren’t just little adults when it comes to environmental health and safety.  Their developing Continue reading

Catholic Social Teachings: methane, morality, and delay

Sister Mary Elizabeth ClarkOn July 10, several Pennsylvania religious leaders traveled to Washington DC to offer in-person testimony to the EPA regarding delay of implementation of New Source Performance Standards for Methane emissions from oil and gas operations.  EPA-HQ-OAR-2010-0505

My name is Sister Mary Elizabeth Clark, a Sister of St. Joseph of Philadelphia, special assistant for sustainability to the President of Chestnut Hill College. I am also an Ambassador of the U.S. Catholic Bishops’ Catholic Climate Covenant. Speaking from a faith perspective and the moral imperative of doing no harm to God’s creation, I support what Pope Francis has said in his call to us all, “Whenever human beings fail to live up to environmental responsibility, whenever we fail to care for creation and for our brothers and sisters, the way is opened to destruction and hearts are hardened.  “Let us be protectors of creation.”

The tradition of Catholic social teaching offers a developing and distinctive perspective on environmental issues. We believe that the following themes drawn from the Catholic Social Justice tradition are integral dimensions of ecological responsibility:

  • A consistent respect for human life which extends to respect for all creation;
  • A world view affirming the ethical significance of global interdependence and the common good.

When considering the regulation of emissions of methane gas, which is Continue reading

Shareholders, stakeholders, and the Common Good

On July 10, several Pennsylvania religious leaders traveled to Washington DC to offer in-person testimony to the EPA regarding delay of implementation of New Source Performance Standards for Methane emissions from oil and gas operations.  EPA-HQ-OAR-2010-0505

Sr. Nora Nash at EPA (1)

I am Sr. Nora Nash of the Sisters of St. Francis of Philadelphia. I thank you for the opportunity to publicly recommend that the EPA implement the methane New Source Standards without delay.

I represent my congregation, a community of over four hundred Franciscan women, whose charism calls us to be strong proponents of climate justice, care for creation, and sustainability. I also speak for the Interfaith Center on Corporate Responsibility, and the Investor Environmental Health Network — two organizations who continue to have positive interaction with corporations on their social and environmental responsibilities and policies. Members work with corporations to build a more just and sustainable world by integrating social and environmental values into investor actions. We accept our moral responsibility to protect our environment, speak for the human rights of communities, human health and the over-all “common good” of society.

As responsible shareholders and stakeholders, we have consistently engaged major oil and gas companies on the need for monitoring and disclosure of methane leakage, on the grounds that what “gets measured gets managed.” Many of these companies have already established performance standards and Continue reading

Mom’s values and methane

Joy at EPAOn July 10, several Pennsylvania religious leaders traveled to Washington DC to offer in-person testimony to the EPA regarding delay of implementation of New Source Performance Standards for Methane emissions from oil and gas operations.  EPA-HQ-OAR-2010-0505

My name is Joy Bergey, and I testify today as the director of the Environmental Justice Center at Chestnut Hill United Church. We are based in Philadelphia, PA.

As I was preparing this testimony, I heard clearly in my mind the life lessons my mother taught me decades ago:

  • Clean up after yourself.
  •  Spend your money wisely.
  • Leave things better than you found them.
  •  Don’t procrastinate.
  • And most of all, always be fair.

These simple messages embody our testimony on delaying the proposed rule.

Let’s start with the most important: Always be fair. This is at the heart of our work at the Environmental Justice Center. We are particularly concerned about environmental racism, which occurs when communities of color are hurt disproportionately by pollution. That’s not fair, or just.

Refusing to regulate methane pollution exacerbates climate change. And this hurts first and worst our most vulnerable populations: the very young, the very old, those living in poverty, those in fragile health, and almost invariably, communities of color.

In Philadelphia, the asthma rate is 21.5 percent, more than twice the national average[1]. In the Continue reading

Speaking the Truth in Love, within and beyond the walls

Alison CornishOn July 10, several Pennsylvania religious leaders traveled to Washington DC to offer in-person testimony to the EPA regarding delay of implementation of New Source Performance Standards for Methane emissions from oil and gas operations.  EPA-HQ-OAR-2010-0505

I am Rev. Alison Cornish. I serve as the Executive Director of Pennsylvania Interfaith Power& Light. We are 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.  I am ordained minister in the Unitarian Universalist tradition.

When I accepted my call to ministry, I made a commitment to always speak the truth in love.  I also accepted the charge to remember the needs of those beyond any one congregation’s walls.  It is this charge and commitment that have compelled me to travel to Washington DC today to be here.

I am here to speak this truth: there is abundant documentation that methane, including the methane that is released by the oil and natural gas industry, is a danger to public health.  In recent years, researchers, industrialists, citizens and governments have learned a great deal about the extent of emissions from oil and gas operations.   The New Source rule, the subject of today’s hearing, would cover 836 wells in PA, which is Continue reading