Attention, not just intention: lower overall emissions may not be more just.

Tom McCaney represents the Sisters of St. Francis of Philadelphia and the Interfaith Center on Corporate Responsibility (ICCR).  ICCR is a coalition of faith-based and mission-driven institutional investors with over $100 billion in invested capital, who view the management of our investments as a powerful catalyst for social change.  For over forty years, ICCR has engaged with corporations on climate change, human rights and sustainability issues which are impacted by this proposed rule.  His testimony appears here alongside PA IPL’s remarks.18556_279719210725_3464351_n

I am here today to comment on the Clean Power Plan for three reasons: First, because decisive national action to address climate change is needed; we have a moral obligation to act.  Second, to underscore the importance of ensuring that the rule has positive impacts on the health and well-being of vulnerable populations, in the United States and around the world.  And, third, to stress that we believe that this rule will have a net positive impact for business in providing economic certainty and incentives for innovation, and promoting the creation of new jobs. Across the sectors in which ICCR members invest, climate change is a material issue presenting significant risks for the long-term value of their investments, whether from water scarcity, supply chain shifts, or physical risk related to extreme weather events.

The Sisters of St. Francis of Philadelphia join other Pennsylvanians in their concerns of the effects climate change has already had on our state; including more frequent flooding and droughts, worsening air quality, extreme heat, and the spread of infectious diseases.

At ICCR we consider climate change within the context of its economic, social and environmental impacts. We acknowledge the sacredness of creation and are concerned with the impacts of global climate change on all species, particularly the most vulnerable on our planet.  With congregations throughout the United States and across the globe bearing witness to the devastating impacts of climate change, ICCR members are acutely aware that the economically disadvantaged will suffer disproportionately. These individuals are less able to adapt and are often more dependent on climate-sensitive resources such as local water and food supplies.

We support the proposed rule for a number of reasons:

  • The United States must be a global leader in addressing climate change.
    The 30% emissions reduction that the rule entails sends a clear signal to other major emitters that the U.S. is prepared to act decisively to address climate change.
  • The rule will provide important public health benefits.
    Analysis predicts that the proposed reductions in emissions will significantly reduce asthma attacks and respiratory disease throughout the U.S, which is especially important because particulate-emitting production facilities are disproportionately located in low-income communities and communities of color.[1] 
  • In reducing climate risk and increasing green energy innovation, the country will see broad economic benefits.
    Energy efficiency reduces costs and is good for the bottom line.  In addition, the development of new technology and infrastructure to facilitate our transition to a low carbon economy will spur innovation and create new jobs in a variety of sectors.
  • We support the flexibility that the rule provides.
    Each state may alone, or with other states in the region, craft the strategy that will most efficiently and effectively lower the carbon intensity of its energy production.

We do have a few concerns.

  • We are troubled by the environmental justice analysis that indicates there may be certain electricity generating units that will be used more intensively after they are made more efficient.  This will lead to increased pollution in areas close to those facilities. We encourage a thorough environmental justice analysis of these impacts to ensure that low-income communities and communities of color are not disproportionately impacted.
  • We are also concerned about the increased deployment of plants powered by natural gas contemplated by the rule.  There are risks to both communities and the environment associated with the development of this resource, and we recommend careful attention to mitigate these impacts.

Finally, we offer a few comments on the state plans.

  • We encourage even broader community participation in the creation of the state plans and recommend the inclusion of representatives from the environmental justice community.
  • We are hopeful that in the development of state plans, Pennsylvania will encourage the robust use of renewable energy and that it will develop comprehensive systems to improve energy efficiency.
  • We urge each state to undertake an environmental justice analysis of its plan. Each state must be mindful of the equitable implementation of this rule in order to maximize its health benefits among those who have suffered the long-term impacts of living near high-polluting facilities.

As institutional investors that have engaged the companies in our portfolios to advance sustainable and just climate solutions, we would like to reiterate our support for the EPA’s proposed Clean Power Plan. We look forward to working with the EPA and Pennsylvania in the development of inclusive and effective implementation plans that will protect the health and well-being of climate-vulnerable communities, secure a better economic future for Pennsylvania and position our nation as a leader in addressing the global threat of climate change.

The EPA hearings on the (finally) proposed Carbon Pollution Standards for Existing Power Plants took place the last week in July in Pittsburgh, Washington, D.C., Atlanta, and Denver.  PA IPL members offered testimony both in Pittsburgh and Washington.  Testimony posted here is shared by permission of the authors.  Remarks by PA IPL supporters are published on this blog alongside PA IPL’s official remarks. When you’re inspired, submit a written comment of your own.