Why are carbon standards important?

PA IPL’s written testimony to the EPA’s Office of Air and Radiation.splash

Docket Number: EPA-HQ-OA-2017-0190
originating from Executive Order 13777

The EPA came about as a result of fully bipartisan legislation that still had strong bipartisan support years later when it was renewed. That legislation, the Clean Water Act and the Clean Air Act grew out of experiences across the country, including a tragic and seminal case from our Commonwealth of Pennsylvania – the Donora Smog of 1948 in which 20 people were killed directly during the incident, 700 were rendered critically ill, 50 died within a month, and mortality rates even a decade later were well ahead of nearby communities. U.S. Steel never accepted responsibility, and payouts to the injured and widowed covered little more than legal expenses.   In this country, we know that this is not right.

It is true that sometimes regulations cost corporations some money, and yet we are a people that understands that there are moral standards, moral limits. We limited child labor, no matter how plentiful and nimble the very young might be, and how much more expensive it might be to pay adults to do honest work. We understand that is the right thing to do, and so we do it.

Similarly, we know that we cannot allow industries to use our Common Home in ways that trample the green pastures on which we all feed, or muddy the waters from which we all drink. [Ezekiel 34:18].   Unfortunately, we have also learned that the drumbeat of profit can be deafening, and balance sheets blinding, and so we must, as a people, agree upon standards, limits to poor behavior.

EPA regulations are not promulgated willy-nilly. In fact, they are created over time, in consultation with stakeholders, and with public comment periods for all to take part in. PA Interfaith Power & Light has participated in numerous EPA listening sessions and hearings.  After the rules are in place, many particulars have been vetted by Supreme Court — the necessity of regulating carbon pollution, for one, has been affirmed, and under the Roberts court.

When we stop to think, when we listen to the “still, small voice” we know the right thing to do: care for our planet as our Common Home; care for our neighbors as fellow travelers; choose to seek and nourish hope, abundance, and mercy rather than destruction, scarcity, and fear. This is the legacy we wish to leave, but the clamor of stock market bells and the always-urgent news cycle can lead even the most faithful to moments of doubt, moments of deafness to the still, small voice. Regulations and standards serve as guardrails, helping people find their way back to where they want the world to be for their own families, and for those to come.

Regulation is by no means the only way that we should be doing this work. We need goal setting, too —visionary leadership to leap forward into 21st century (despite our all-too-human aversion to change).   We need morally grounded leadership with moonshot goals to step boldly into to our clean energy future, but we need the guardrails, too – and that is the EPA’s job, as commissioned by the Clean Water Act and the Clean Air Act.

Administrator Pruitt, part of your job is to make sure the right regulations are considered, and made. Make sure that the science of public health is funded, networked, and digested. Make sure that we know the ways our choices are changing the world. And once we know how they are, make sure that the guardrails can keep us on the path.

And part of your job is to make sure that those carefully vetted standards are enforced. Make sure that there are plenty of referees on the field so that those who wish to do business in a way that benefits society will not be undercut by the shortcutters and the cheaters.

Rise to the highest mission of your position, and celebrate standards as the megaphone of our collective conscience, amplifying it above the din of the market. Continue to vet those standards, to make sure they have been considered and crafted by diverse voices, and grounded in the very best knowledge we have. But once they survive that dignified process, celebrate the work that they do!

If you do those things, ingenuity, imagination, courage, and, yes, even faith can forge the rest of the way.

PA Interfaith Power & Light
May 15, 2017