MESA’s public comment to the EPA

By Ty Markham

In early November 2018, MESA gave comment at the Environmental Protection Agency’s public hearing (held in Denver, CO) on its new rules regarding methane leak detection and repair.  The EPA’s new rules are a direct result of the Trump administration’s charge to rollback regulations on methane capture (previously set forth during the Obama administration in 2014) that have required quarterly inspections of any areas of drilling, extraction, storage or piping where leaks might occur.  The stated purpose of the rollback is to facilitate the process of energy production and increase the profitability of oil and gas industries in the U.S.

The new rules propose (1) a reduction of the quarterly requirement down to once yearly, and (2) to remove a requirement that an engineer be onsite to supervise repairs. MESA was among hundreds of organizations and individuals who signed up to give public comment on the proposed new rules. 

MESA was among scores of other non-profit grassroots organizations who provided comment in person before the EPA panel. Nearly all public comments protested the proposed rollback of protections from escaped methane into the environment.  I personally heard at least 30 comments out of likely over 200 that day. The EPA panel placed a 5-minute time limit on all verbal comments, but allowed additional comment and information to be submitted in writing. They also announced that written comments submitted prior to the end of November would be considered with the same weight as verbal comments presented in person that day. The following words are the verbal comments delivered on behalf of MESA:

“My name is Ty Markham, here today from Utah to represent a grassroots nonprofit organization known as “MESA” — the Mormon Environmental Stewardship Alliance. We were organized in 2013 by a group of Brigham Young University alumni, educators, and parents who share a common faith and a sense of responsibility that we should be doing more to create a healthy future for our children than just recycling, carpooling, and walking or biking more. We are activists in shaping public policy through a perspective founded on the powerful influence of our faith and values. 

“Our prophet says we are to ‘be good stewards of the Earth and preserve it for future generations.’ Members of The Church of Jesus Christ of Latter-day Saints are busy raising families, working jobs, and meeting our church responsibilities. Most of us rarely have time or inclination to attend or hold up a sign at a political rally. But we do sign petitions and write our elected leaders about important legislation or policies that concern us.

“Believe it or not, Latter-day Saints are as diverse as the general population.  We span the gamut of political views just as the rest of the country does. We are ethnically and racially diverse. We are rich and poor. We live in cities and in the countryside. We are multi-generational and multi-national. I personally have lived in a rural community for the past 20 years, after having grown up and reared a family mostly in suburbs of large cities. My kids (now in their 40’s) and grandkids (in their teens) see the world from a different perspective than most of us “baby boomers” do. And that’s a good thing in many ways. Their generations are more focused on the future, as well they should be. They are more open to change and to new ideas, new technology, and creative new solutions to world challenges. They are driving hybrid cars and getting solar panels on their rooftops. My teenage grandson just got his Environmental merit badge in pursuit of his Eagle Scout award. Our grandchildren understand what they are up against, and they are looking for solutions that have long term benefit.

“Rural communities have fewer options, and tend to be less secure economically. They are more insular, suspicious of new ideas, fearful of change, and less hopeful of the future. In my community, we struggle to find permanent year-round jobs with benefits that provide security for our families. This outlook pits old against new. Some are willing to sacrifice the future to meet their day-to-day needs, even if it means they breathe coal dust in the mines, ozone near wells and storage facilities. But they’re not ignorant. They know what they sacrifice. They don’t like it, but for them it is basic survival. 

“Where all groups come together (especially as Latter-day Saints) is in our belief that there is a right and a wrong way to do things. We ALL believe that win-win solutions exist and should be promoted. We really don’t like the fact that high ozone levels from drilling and well sites in and around Vernal, Utah, were found in 2013 to have likely caused a spike in miscarriages, stillbirths and birth defects in that community. It made national news. But those living there, even while suffering the ill health effects, were afraid to complain out of a fear that the offending industries might leave the area and take much needed jobs with them. SUCH A DILEMMA! These folks were not aware that both technology and man-power exists to create a win-win solution to the ozone problem surrounding their community.

“That brings us here at this moment.  To address why and how a positive, win-win solution can be implemented for the benefit of the industry itself AND benefit the health of our planet, and all those who live and work near extraction, pumping and storage sites. The oil and gas corporations benefit when leaks are detected and repaired because they have captured more precious energy to sell on the market. Company expenditures for detection and repair are offset not only by the captured methane, but also by reduced healthcare costs of field employees who no longer have to work around dangerous levels of methane-derived ozone.  The win for nearby communities is two-fold: THERE ARE NOW NEW INDUSTRY JOBS available in leak detection and repair.  AND these folks no longer have to breathe ozone-laden air everyday of their lives and suffer the bad health effects.

“This is obviously a simplistic outline of the situation. But a mutually beneficial solution does exist, and people do understand these basics. They also understand there EXISTS A MORAL IMPERATIVE to implement the solution. Imperative for the health of our communities. Imperative for the health of our children, and for future generations yet to be born. Imperative for the health of our entire planet, as methane is far more potent as a greenhouse gas than CO2. 

“Surely, you already know this. And you probably agree, but feel you cannot implement it now due to new goals and guidelines set forth by the Trump administration. We understand that President Trump is demanding the standards be lowered to save the industry money. He claims it’s about ‘MAGA’. But let’s be real. We know these industries’ profits don’t get spent in our communities. Nor, by-in-large, in ANY community.  Whatever profits might escape being hidden in offshore accounts to avoid taxes are most likely to be funneled into lobbying for continued subsidies and avoidance of external costs. Whatever dividends these corporations might pay out to shareholders likely go primarily to their big foreign investors; and maybe, if we are lucky, some dividends end up in a pension fund.   

“What actually makes America “great” is her people–her workforce, their wellbeing, their skills, their ability to live productive lives and contribute to society.  We are ALL called to advance this cause. Why? Because we love our nation, our people, and our world — the very earth that gives us life.  We love this more than we love money or power.

“Please harken to your own inner source of wisdom. Please communicate your enlightened understanding up the chain of command until it reaches the top. Please promote and advance a higher standard.

“And to you, industry leaders: please step up and do your part.  You know that, ultimately, ALL OUR LIVES… AND ALL OF CREATION depends upon the right action that you take.   “Thank you for your time.”

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