DEP: Love our people through your work.

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Testimony to the Environmental Quality Board of the DEP
Proposed Rulemaking: Control of VOC Emissions from Oil and Natural Gas Sources (#7-544)

Thank you to those of you who are here to listen and record testimony tonight, to those who figured out how to do the virtual hearings, and to those who have participated in outlining and refining this proposed rulemaking.   I hope that you and your families are well. 

Because this is the last step on a very long path, you already know what Pennsylvania Interfaith Power & Light (PA IPL) has to say about the rule:

  1. We are so glad that the rule for existing sources is finally here.  Existing sources are, after all, the source of 100% of the existing pollution from oil and gas operations in this state.
  2. The rule, as proposed, will do some important work cutting emissions from large operations.  We ask that you amend the rule to close the massive loophole for emissions from smaller operations because neither bodily systems nor ecosystems care about the size of the source.
  3. The rule, as proposed, requires inspections.  That is good.  We ask that you amend the rule to require ongoing inspections even after repeated passing grades.  It is too easy for leaks to go undetected, and many leaks occur unpredictably.  Without regular, required inspections, leaks could go on for far longer, polluting our air and atmosphere much, much more, even when people are trying to do the right thing.
  4. This rule is a good start, but it does not yet limit methane directly.  VOCs are not co-emitted with methane at the same rates across the state.  We agree that we need to limit methane emissions (this rulemaking is specifically named as part of the Methane Reduction Strategy).  When this rule —this good start— is tightened and completed, we need you to move onward to direct methane surveillance and limits.

    You have seen the Pennsylvania Climate Change Impacts Assessments.  You know that climate change is here and now, not theoretical nor eventual.  You know it impacts infrastructure, water systems, and agriculture across the state, as that was the focus of the 2020 report.  You know, too, of increasing heat and humidity in various parts of the state, the impact of which is only compounded in hotspots like Hunting Park, which can be up to 20 degrees hotter than surrounding neighborhoods — where community members don’t have the resources to run air conditioners, and heat is a direct threat to our elders. 

Those points are all specific to this rulemaking.  They are things you know, they are things we have said before, and they are things that others will detail in depth. So this evening, I’d like to take us in a different direction.  I would like to invite you to bring your whole selves into this space.  You are, after all, more than just your expertise. 

Whether or not we identify with a particular faith tradition we know, each of us, foundationally, morally, and in our bones that people are not disposable.  When we stop to think about those things that are most important to us, when we pause for gratitude and Thanksgiving, it is the people who have cared for us, celebrated with us, challenged us, and stuck by us, it is the places where we have laughed, and sung, and healed – these are the “things” for which we give thanks.  These are the “things” that weave us together.  People and places fill us and feed us as profit and stuff never will.  Americans know this.  Pennsylvanians know this.  

We know people are not disposable, and we know that our Common Home is not disposable – we know that the web of life is, in fact, a web of interconnection. 

We know real community. 
I know, and you know. 

Unfortunately, at work, there are a lot of scoresheets, and the way we keep score doesn’t have this knowledge of heart and soul the way you do, and I do, and the way the residents of our Common Wealth do.  So we need rules.  And that rulemaking is your job.  Tonight, I’m asking you to hear it as a calling.

I am asking you to use your expertise, and to bring your whole self.  Write the rules that truly protect what matters.  In doing your work, love our places.  Love our people.  Love our children’s futures, and their grandparents’ longevity.  Write the rules we need.  Here at PA IPL we see that all policy is a covenant with the future. 

I am asking each of you, and each one of your colleagues: on Friday morning, after the last of these hearings, take your whole selves to work and love us all.  Write the covenant we need.  Do it for your family, and for mine, for our Common Home, and all who live here. 

Close the loopholes.  Raise the bar.  Write a good covenant.  Finish this one, and write the next.

Testimony given virtually via WebEx on June 23, 2020
Cricket Eccleston Hunter
Director of Program, Pennsylvania Interfaith Power & Light
paipl.org

Residents of Pennsylvania may submit written testimony until July 27.

Written comments may be submitted through DEP’s eComment webpage, by email to: RegComments@pa.gov or in writing to: Environmental Quality Board, P.O. Box 8477, Harrisburg, PA 17105-8477.  Note that comments must include that they are in response to the Proposed Rulemaking: Control of VOC Emissions from Oil and Natural Gas Sources (#7-544)

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)

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 DEP Hearings: Rev. Alison Cornish

DEP Testimony: Rev. Bill Thwing, Johnstown

31664_10150197269130105_5950125_nThank you Secretary Quigley and  DEP for holding these hearings and encouraging us citizens to exercise our democrat responsibilities to envision the future…together

Good morning, my name is William Thwing.  I am a Pastor at St Paul’s United Church of Christ, here in Johnstown. I’m an active member and former president of Pennsylvania Interfaith Power & Light,  a founding member and former Western PA coordinator of the Pennsylvania Council of Churches , Interfaith Global Climate Change Campaign.   I’m also a former Military Intelligence Officer who served in combat  Vietnam and I’ve been studying Climate Change since I returned from that formative experience – you might say that I’ve been a military intelligence in the servant of the Creator God ever since.    Continue reading DEP Testimony: Rev. Bill Thwing, Johnstown

DEP hearings: Joy Bergey

JoyBergeyJoy Bergey is a former PA IPL board member.  She testified at the PA DEP listening session in Marcus Hook, Philadelphia County on September 30, 2015.  

My name is Joy Bergey, and I speak as director of the Environmental Justice Center of Chestnut Hill United Church. Based in Philadelphia, the Center is a multi-religious program working with congregations to address issues of environmental injustice.

We thank Secretary Quigley and DEP for holding these listening sessions. We you to create a strong plan to meet EPA’s emissions reductions targets under the Clean Power Plan. In fact, we urge DEP to exceed these targets.

In light of DEP’s own startling new report, Pennsylvania’s temperatures are predicted to rise 5 to 6 degrees in mere decades.

Given the deeply inspiring messages delivered by His Holiness Pope Francis just a few miles from here last weekend, we must take strong action to limit carbon pollution. It’s a moral imperative.

We at the Center have recently become aware of a significant source of carbon dioxide that EPA has included as a potential compliance option under the Clean Power Plan: wood-burning Continue reading DEP hearings: Joy Bergey

DEP hearings: Rev. Bill Thwing, Pittburgh

31664_10150197269130105_5950125_nRev. Thwing is a past president of the PA IPL board.  He testified at the PA DEP listening session in Pittsburgh on September 21, 2015.  

Good evening.  My name is William Thwing.  I am a Pastor in Johnstown, PA;  the father of 4 children, grandfather of 5 and a geneaologist – which means that I can trace my family tree back many generations.  My ancestors who worked  so hard and sacrificed so much  enable the emergence of my generation today, would be appalled if they realized that all their prayers and hopes and efforts could be wiped out within a couple of generations by the chaos of the climate changes detailed in part in the most recent “Pennsylvania Climate Change Assessment”.   I fear for my grandchildren  and the generations to come, that we, in our shortsighted self-serving generation, will leave them nothing more than an  ‘immense pile of filth” as Pope Francis puts it in his Encyclical, Laudato Si. Now is the time to act decisively.  Now is the time to make the sacrifices necessary to insure our grandchildren’s survival and the survival of our nation.

I thank the DEP for holding these hearings and giving Pennsylvania citizens an opportunity to envision together a plan to insure our common welfare and survival. I Continue reading DEP hearings: Rev. Bill Thwing, Pittburgh