Presbyterian committee submits comments on methane regulations

EPA proposal could negatively impact ‘vulnerable communities,’ letter says

by Darla Carter | Presbyterian News Service

Weakening or eliminating standards for methane, a greenhouse gas, will hurt vulnerable communities, according to a letter by Rob Fohr, director of Faith-Based Investing and Corporate Engagement for the Presbyterian Church (U.S.A.). (Contributed photo)

LOUISVILLE — The Committee on Mission Responsibility through Investment of the Presbyterian Church (U.S.A.) has submitted comments to the Environmental Protection Agency, opposing a plan by the Trump administration to roll back methane gas restrictions on the oil and natural gas industry.

In its Nov. 21 letter, the MRTI committee argues that keeping Obama-era restrictions in place is essential to mitigating climate change risks from methane, a powerful greenhouse gas.

“Weakening or eliminating standards for this greenhouse gas will hurt vulnerable communities living near these oil and gas operations,” according to the letter by Rob Fohr, director of Faith-Based Investing and Corporate Engagement for PC(USA). “It also ignores the EPA’s responsibility to protect human health locally and will diminish progress towards achieving climate commitments globally.”

The administration’s proposal, which was unveiled in August, would eliminate federal requirements that oil and gas companies install technology to detect and repair methane leaks from wells, pipelines and storage facilities, according to The New York Times.

The EPA justified the proposal by saying that updating the national standards would eliminate some regulatory redundancy and save the oil and natural gas industry $17 million to $19 million in compliance costs each year.

This proposal “delivers on President Trump’s executive order and removes unnecessary and duplicative regulatory burdens from the oil and gas industry,” EPA Administrator Andrew Wheeler stated at the time. “The Trump administration recognizes that methane is valuable, and the industry has an incentive to minimize leaks and maximize its use.”

Wheeler also noted that methane emissions across the natural gas industry have fallen by nearly 15%. “Our regulations should not stifle this innovation and progress,” he said.

But health and environmental advocates remain concerned about the proposal’s potential impact.

“Americans need protection from the health effects of unmitigated pollutants, especially the roughly 17.6 million Americans who live near active oil and gas operations and face serious health risks associated with fugitive emissions,” the Nov. 21 letter states.  “A disproportionate number of those impacted by pollutants and devasting environmental disasters are people of color. Our denomination has been called on to promote environmental justice and oppose injustice in all its forms, including these proposed regulation changes.”

The Rev. Dr. J. Herbert Nelson, II, Stated Clerk of the General Assembly of PC(USA), has urged the denomination’s nearly 1.6 million members to take a stand on climate change, noting, “God is still dominant and has a calling for us to protect that which has been given.”

The text of Fohr’s letter:

November 21, 2019

Mr. Andrew Wheeler
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Submitted at http://www.regulations.gov

Re: Comments on Proposed Rule: Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Review
Docket No. EPA-HQ-OAR-2017-0757-0002

Dear Administrator Wheeler:

The Presbyterian Church (U.S.A.) is a major Protestant denomination with nearly 1.6 million members. Our General Assembly believes the church’s investments should promote its mission goals and reflect its ethical values such as caring for the environment. The Committee on Mission Responsibility Through Investment (MRTI) was created almost 50 years ago to implement this policy and has worked on climate change since 1990, calling for the reduction of emissions in our church buildings, international agreements and adoption of reduction targets by corporations.

We are writing to urge you to maintain New Source Performance Standards (NSPS) regulations and appreciate the opportunity to comment on this proposed rule from the Environmental Protection Agency. The Board of Pensions of the Presbyterian Church (U.S.A.) and the Foundation both are long-term investors with holdings in the U.S. oil and gas industry. To ensure the health of our economy and the returns on our long-term investments, these performance standards are essential to meeting commitments to mitigating climate change risks.

Methane is a highly potent greenhouse gas with an overall potency that is ~86x that of CO₂­, when measured over a 20-year period. Weakening or eliminating standards for this greenhouse gas will hurt vulnerable communities living near these oil and gas operations. It also ignores the EPA’s responsibility to protect human health locally and will diminish progress towards achieving climate commitments globally.

Americans need protection from the health effects of unmitigated pollutants, especially the roughly 17.6 million Americans who live near active oil and gas operations and face serious health risks associated with fugitive emissions. With each passing year, the signs from the natural world become more vivid. This past year we have seen devastating storms, floods and fires ravage not only the United States, but also countries globally. A disproportionate number of those impacted by pollutants and devastating environmental disasters are people of color. Our denomination has been called on to promote environmental justice and oppose environmental injustice in all its forms, including these proposed regulation changes.

Dismantling these critical standards, many of which companies have already been, and continue to, comply with, through the proposed rule would harm communities, the climate, weaken our investment portfolios, and ultimately, hurt the economy. It will result in the waste of substantial volumes of saleable natural gas, jeopardize thousands of jobs in the methane mitigation industry, and weaken the United States’ financial and reputational position. These are all measurable harms to investors in the sector, like the Presbyterian Church (U.S.A.). As investors, we join the growing body of concerned stakeholders in opposition to this proposed rule and ask the EPA to maintain NSPS regulations as they stand for the future sustainability of the US economy.

Sincerely,

Rob Fohr

Director of Faith-Based Investing and Corporate Engagement

Presbyterian Church (U.S.A.)

rob.fohr@pcusa.org

Cc:  Joseph Kinard, Chair, Committee on Mission Responsibility Through Investment