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
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 bodies and distinct behaviors put them at special risk. Methane and its co-pollutants, such as smog-producing volatile organic compounds and carcinogens like benzene, endanger children, harm their health and disrupt their development. Exposures that would occur during a two-year, or even a 90-day delay, would have consequences that would stretch on for years or even lifetimes.
For example, children’s lungs continue to develop not just during childhood but also throughout the teen years. Harmful chemical exposures during this time can permanently scar pulmonary tissues and even trigger life-long asthma. Even when asthma doesn’t lead to hospitalizations or worse, it still disrupts families and keeps kids from attending school. As a parent of a teen who missed weeks of school this year due to health issues, I know first-hand that those missed days cannot easily be made up, but rather have lasting consequences upon learning and achievement.
In addition to its direct health impacts, methane is a potent greenhouse gas, 80 times more powerful than CO2 over the short term. Delays in implementing the Methane Leak Detection and Repair rule, therefore, put children at greater risk for health problems associated with climate change, including vector-borne diseases like Lyme and West Nile virus, heat waves, and code red air days. Doesn’t it seem unethical that future generations should pay the price because we failed to be prudent today? Instead, we should be doing our utmost to protect our children and ensure a better world for their children, as Judaism, Christianity, Islam, and countless other religious traditions instruct us. We are called, in the language of the prophets, to protect the widow, orphan and stranger, those the Gospels call “the least of these.” It is precisely how a society treats its least powerful, most vulnerable members that shows whether or not that society is truly great.
This is my daughter’s final summer as a high school student. Today is my day off, and frankly, I’d rather be spending it with her than taking the whole day to travel back and forth to DC. But I would be ashamed to tell her that I had a chance to speak up against this proposed delay and failed to do so. I hope, as you make your decision, that you will keep her and all the children of our nation in mind. If you do so, you will see that there is only one wise and moral course of action – implement the new source rule without delay.
Thank you for this opportunity to testify.
Rabbi Daniel Swartz