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

Residents of Pennsylvania may submit written testimony until July 27.

Written comments may be submitted through DEP’s eComment webpage, by email to: 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)

PA IPL testimony on the proposed repeal of the Clean Power Plan

The EPA has proposed repealing the vetted and passed Clean Power Plan.  The public comment period ends at 11:59 PM on April 26, 2018.  Comments may be submitted online.  PA IPL’s testimony is below, or can be accessed here as a formatted document.

For God has not given us a spirit of timidity,
but of power and love and discipline.
2 Timothy 1:7

Individuals and communities of faith from Philadelphia to Erie, and Scranton to Pittsburgh stand together as Pennsylvania Interfaith Power & Light in support of the Clean Power Plan and other efforts to safeguard our climate, our health, and our Common Home At your invitation, we again stand as citizens in support of the Clean Power Plan, as we have each and every time we have been asked – in 2013 listening sessions, in 2014 hearings, and again in 2017 when Administrator Pruitt asked for comments regarding regulatory reform in response to Executive Order 13777. We have also done so at the state level. We believe loving our neighbors includes behaving in ways that we do not pollute our brothers’ and sisters’ air or water, nor destabilize the climate on which their food depends. Imagine, as you read this, a chorus of us are there with you, praying as you read, and sharing relevant scripture and wisdom from our religious traditions. May these words find their way to your hearts, and from your hearts, to your heads, and hands, and pens.

“The mission of the EPA is to protect human health and the environment.”[1]
This statement may be seen as an obligation; as religious people from many traditions, we affirm obligations to also be invitations to unmeasurable rewards. When we fulfill our obligations with love, treating them as mission, and willingly acknowledging we are our brothers’ and sisters’ keepers – eternally – we knit ourselves into blessed community — caring communities – looking out for one another and being of service. We are at our best when we are of service. You, yourselves, were also so committed to service that your very job description is “civil servant.”

“It really boils down to this: that all life is interrelated. We are all caught in an inescapable network of mutuality, tied into a single garment of destiny. Whatever affects one directly, affects all indirectly. … This is the way our universe is structured, this is its interrelated quality.”
The Rev. Dr. Martin Luther King, Jr.
1967 A Christmas Sermon on Peace,

Faith communities have been commenting and testifying in favor of the Clean Power Plan for years, as a matter of climate justice, and an historic step towards protecting our Common Home – the Earth, and all who live here. We are hurting from turning a willfully-blind eye to the harm we are causing. We are hurting from severing ourselves from our relationship with Creation, from trying to pretend we are somehow separate from the interdependent web of life that sustains us. We are ready to face the painful truth, and to heal.

He raised the heaven and established the balance so that you would not transgress the balance.
Give just weight – do not skimp in the balance.
He laid out the earth for all living creatures.
Qur’an 55: 7-10

You know this is not just a “faith thing” or a “green thing.” The endangerment finding means that our legal system has examined the evidence and determined that unbalancing the cycles (cycles that in turn balance the slim layer of atmosphere that makes Earth our “just right” planet) is a harm to the people of the United States. As such, the EPA is required by mission and by law to take action to limit harm.

Do not exploit the poor because they are poor
    and do not crush the needy in court,
for the Lord will take up their case
    and will exact life for life.
Proverbs 22:22-23

We are now losing ground with every moment we delay. We continue taking incremental action in our own homes, our own communities, our own congregations, and our own state, but we must not delay any further as a country. We certainly must not reject a vetted plan that will do good, allowing us to do even better as smarter technology and know-how emerge.

The way of the sluggard is blocked with thorns,
but the path of the upright is a highway.
Proverbs 15:19

When we intentionally procrastinate, willfully choosing blindness to the impacts of our actions, we fall short of our purpose and potential. Surely this is true of our country as well as its citizens.   We know ourselves to be inventive people, motivated by challenge, and yet in considering this repeal, we are considering walking away from just such a challenge. We already have technology that will generate (and store) electricity without causing the kind of deep harm we experience today, and yet we are failing to use these tools widely.

It is not incumbent upon you to complete the work, but neither are you at liberty to desist from it
Pirke Avot 2:21

We know you have received many, many comments with numbers of asthma attacks from ground-level ozone, fueled by warming and co-pollutants. We know you have seen the models, predicting elders likely to die from complications related to heat stress. We know you have seen medical evidence, people hospitalized with GI issues after torrential storms. We know you have seen the numbers of people who will be displaced – domestic climate change refugees. For us, as for you, those numbers represent stories, and people. Friends told to boil water, for the 5th time in a month. Children who may not play outdoors without risking their lives (though of course inactivity is its own risk). Grandmothers dead before their time. Garbage bags, bleach bottles, a favorite easy chair, and the family photos on the curb after a flood. Historic and blessed religious objects and texts, narrowly evacuated as wildfire threatens houses of worship. Each of these is a snapshot connected by heartstrings to a member of our network.

Faith communities respond to each family, each individual who comes to us, injured, traumatized and displaced, because of climate change. Prudence demands we work to stem the tide. We must, as a country, choose a better path. We are asking again: don’t undecide.

The prudent see danger and take refuge,
but the simple keep going and pay the penalty.
Whoever sows injustice reaps calamity,
Proverbs 22:3,8

Is it not enough for you to feed on the good pasture? Must you also trample the rest of your pasture with your feet? Is it not enough for you to drink clear water? Must you also muddy the rest with your feet? Must my flock feed on what you have trampled and drink what you have muddied with your feet?” (Ezekiel 34:18-19)

[1], accessed 1/11/2018.



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.

[1]. Available at:
[2]. Available at:
Appendix E; Memorandum from Mark Garrison, ERM, 6 December 2016.
[3]. Available at
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 Proverbs 22:3 Are we simpletons?

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 Catholic Social Teachings: methane, morality, and delay

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 Shareholders, stakeholders, and the Common Good