US EPA Carbon Pollution Guidelines PublicHearing Testimony by The Rev. Dr. Leah D. Schade, PhD Pastor,United in Christ Lutheran Church, Lewisburg, PA Member, TaskForce on SlickwaterHydraulic Fracturing,Upper

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# L:·/· '! l·L '"4-., July31, 2014 a ic7 First, I want to thank the EPA and AdministratorMcCarthy for paying serious attention to this issue of carbon emissions and their deleterious effecton ourplanet's atmosphere. I commend you for giving citizens the opportunity to be heard on this important issue. The proposed rule is well-researched, with solid background in science regarding greenhouse gases, their effect on the planet, and their negative impact on public health. Itoffers a wide range ofoptions for states and power generators to meetthe new requirements to reduce greenhouse gases. As a pastorwho has particular concern for '"the least ofthese," Iwas especially pleased to see attention given to the health ofchildren when weighingthe input of stakeholders, I come today on behalfofmyself, my husband and two young children, my congregation, United in Christ Lutheran Church in Lewisburg, the Upper Susquehanna Synod

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.....'! However, as a member ofmy synod'stask force on slickwaterhydraulic fracturing which spent two years studying the ethical and moral issues surrounding fracking; and as a member ofseveral environmental groups that study and bear witnessto the harmful effects ofthe shale gas industry in our state and across the country, I must raise concerns that are not addressed in the EPA's proposed rules. Three years ago I gave testimony in support ofthe EPA's Mercury and Air Toxins Rule which, atthe time, was a strong
measure for reducing poisons from the coal industry. An unexpected and harmful effect ofthis rule, however, was that it helped to pave the way for the shale gas industryto establish itselfin our state and commit untold damage to our air, water, state and private lands, and public health. Ifear thatthis new rule on carbon emissions would only further enable the shale gas and oil industry to secure its hold in Pennsylvania and do still more damage to ecological and human health. Yes, the new EPA rules will force Pennsylvania to reduce its airpollution and burn less coal. But how we adjustto less coal will make all the difference. Ifwe build more renewable enerh'Y infrastructure and increase energy efficiency, our air will be cleaner and greenhouse gases will be reduced. But ifwe replace coal with fracked gas, we will only be making our air and atmosphere worse. These rules, as written, only codifY the transition from coal to gas that is already underway. As well, the rule gives implicit consentto burn more trash, tires, coal sludge, and other forms oftoxic waste for electricity. So while I believe the proposal is a good first step, it is not only inadequate, it will have the unintended consequence ofreplacing one source ofdirty fuel with many others.Methane is a greenhouse gas even more potentthan carbon. The rule does not address totallifecycle emissions from methane-gas-fired power plants, including leakage during production, processing, and transmission, emissions flaring at gas wells, and energy consumed in the production and transport of liquefied natural gas. Researchers found methane leak rates ofI00 to I,000 times greater than EPA estimates at well pads in Pennsylvania. And the EPA's Office ofthe Inspector Generaljustissued a report citingthe agency's failures to manage methane leaks from pipelines. Instead ofpromoting a strategy that perpetuates fossil fuels and fracking (and make no mistake- shale gas is a fossil fuel), the proposed rule should include an aggressive pursuit ofrenewables, energy efficiency, and conservation. Shale gas and oil are not the solution to-., carbon pollution in the United States. They are, in fact, an even worse enemy. The rule should set absolute reduction targets for total greenhouse gas emissions for each state. Otherwise emissions will continue to grow as more energy is consumed.
I urge for the rule to be substantially amended with policies that expressly favor stringent conservation standards, as well as increased sourcing ofelectricity from renewable energy, which is emission free. This would be faster, cleaner and more economical than investing in natural gas, waste product incineration, and nuclear power. Renewables and efficiency can produce more reductions ofC02 per megawatt hour than natural gas. I am committed to helpingpeople offaith learn howto do theirpartto care for God's Creation and support eco-justice issues. I call for the EPA to not only stand its ground with this rule, butto actually strengthen and expand it in orderto put in place the strongest protections possible to defend public health, the fragile atmosphere ofourplanet, and the communities that will bearthe costs and suffering from our addiction to fossil fuels and greenhouse gases. Thankyou.