2021 EPA Oil and Natural Gas Listening Sessions
EPA-HQ-OAR-2021-0295
Hello, my name is Susannah Tuttle. I am Director of the NC Interfaith Power & Light and serve as the Director of the Eco-Justice Connection at the NC Council of Churches.
I am grateful for the opportunity to share my strong support for EPA’s proposed methane rules and urge EPA to strengthen the rules to maximize the benefits for public health and the environment.
In 2004 I received my Masters in Divinity after studying at the Graduate Theological Union with a focus on ecological ethics. As a faith leader I have spent my entire career working to address the causes and consequences of global warming as a moral imperative.
There is no doubt that Methane pollution is a profound threat to our health and our climate. The oil and gas industry is the largest source of methane pollution in the United States. Addressing this pollution, in the form of leaks from new and existing operations, is the low hanging fruit of climate solutions.
People of faith see climate change as the greatest ethical and moral concern of our time. Not only do frontline communities, communities of color, the young and old suffer the most from climate change, they are affected most from methane pollution which is linked to our warming climate. We must work for strong methane rules. We must act now for life.
As people of faith and conscience, with a shared commitment for stewardship of our common home, Interfaith Power & Light’s congregational network supports strong and effective methane pollution safeguards. Using currently available technology, the U.S. can do its part to meet a global imperative, achieving a 65% reduction of methane from oil and gas by 2025 and more by the end of the decade. As the largest historic emitter of climate warming pollution, the U.S. must do its fair share and dramatically reduce its methane pollution.
As you have already heard from so many experts across this country, EPA must strengthen the monitoring requirement. EPA should require regular monitoring at smaller, high polluting wells. Hundreds of thousands of wells across the country generate just a trickle of usable product but are large and disproportionate emitters of methane. EPA has recognized in the proposal that a “low production” exemption is not appropriate. However, under EPA’s current proposal operators that calculate lower potential emissions could still escape regular leak monitoring. This is a big problem since operators wouldn’t be required to factor in super-emitters or equipment failures.
I echo all those who have already stated how flaring is another wasteful and avoidable practice that is rampant in the oil and gas production sector. When companies rush to extract oil, some forgo investments necessary to capture and sell gas and instead burn it as a waste product, emitting a host of climate and health-harming pollutants. Flares also commonly malfunction and spew methane directly into the atmosphere. Therefore EPA must move to end routine flaring.
All of these additions must be included before the proposal is finalized to ensure EPA is fully protecting our health and addressing the climate crisis.
We are pointed in the right direction, but we are running out of time to tackle the climate crisis, and we cannot miss out on this opportunity to protect public health and the environment. These proposed safeguards must be strengthened before they are finalized to ensure EPA is using the full force of the Clean Air Act to and truly meet this moment.
Finally I urge EPA to finalize this rulemaking as quickly as possible, climate change is an emergency and our planet cannot afford further delay.
On behalf of my family, our communities, and the congregational networks I serve… I thank you for this opportunity to provide comments and I send prayers of peace & blessings to you all.
Susannah Tuttle, M.Div
NC Interfaith Power & Light
NC Council of Churches
November 30, 2021
Link to EPA process: https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/epa-proposes-new-source-performance
