The following is the written testimony of Rev. Mitchell Hescox from the EPA Oil and Gas Public Hearing held on November 30, 2021:

"Dear Administrator Regan,

I am The Rev. Mitchell C. Hescox, President/C.E.O. of the Evangelical Environmental Network, and I live at 24 East Franklin Street, New Freedom, PA.

As Evangelical Christians, we are people of the book, The Bible. Throughout Scripture, we are called to join God in pursuing justice. In the book of Amos, the prophet cries out: "But let justice roll on like a river, and righteousness like a never-failing stream!" (Amos 5:24 NIV). Additionally, as Jesus states in Matthew 25:40 (NIV), “Truly I tell you, whatever you did for one of the least of these brothers and sisters of mine, you did for me." Our children are especially among those Jesus calls us to care for most. The old Sunday School song says it best:

Jesus loves the little children,
All the children of the world;
Red, brown, yellow, black, and white,
They are precious in His sight,
Jesus loves the little children of the world.

All of us would agree that our children are precious and must be defended from the threats imposed by known cancer-causing toxins like benzene, VOCs that increase ozone levels, and methane that is over 80 times more potent greenhouse gas than CO2 in the first twenty years – increasing temperature which then increases ozone levels another step further. The medical and scientific literature is clear – living within 0.5 miles of a methane extraction or production site harms our children,[i] and newer research suggests that even those living further afield within a 5-mile radius may also be at risk.

Currently 2.9 million American children attend school within 0.5 radius of oil/gas facilities. Within my home state of Pennsylvania at least 310,896 kids face this hazard.[ii] This makes addressing fugitive and leaking methane from both existing and leaking oil/gas facilities a moral responsibility.

As pro-life evangelicals, we have a special concern for the unborn. We want children to be born healthy and unhindered by the ravages of pollution even before they take their first breath. The medical community has long known that unborn children are especially vulnerable to environmental impacts. Of these impacts, it is clear that fossil fuels are the most serious threat to children’s health worldwide.[iii] The once-thought chemical protection a mother gives her developing child is untrue. Studies have shown that smog, VOCs, and air toxics have a disproportionate impact upon life in the womb. Research by Dr. Shaina L. Stacy and others at the University of Pittsburgh found close proximity to unconventional gas wells in Butler County, PA is associated with babies born with lower birthweight.[iv] Dr. Lisa M. McKenzie with the Colorado School of Public Health published peer reviewed research that links birth defects to methane production.[v]  Research by Casey J.A., et al (2019) further describes that living within a half-mile radius of natural gas development leads to increased brain, spine, or spinal cord birth defects.[vi]

We are thankful for EPA’s proposed rules that will defend children’s health. We are especially thankful that the new proposed standards are based on actual methane emissions instead of the amount of oil and gas production. Recent studies clearly prove that many smaller leak-prone wells have disproportionately high emission rates of methane and associated gases.[vii] Under the new emission-based rule, these methane super-emitters will no longer slip through the cracks.

Combined, the two standards will save $6.6 - $9.2 billion in avoided health costs and loss of life. While this indeed is good news, the proposed standards in the rule would be strengthened by incorporating the following:

• A ban on routine flaring except in emergency situations.
• Quarterly inspection via LDAR (Leak Detection and Repair) procedures of all wells with 2 tons per year (tpy) of methane emissions or greater. (This recommendation is based on EPA’s own conclusion in the proposed rule, which states: “…sites with total baseline methane emissions of 2 tpy, we conclude that regular monitoring at semiannual or quarterly frequencies would be cost-effective.”) Based on this conclusion that quarterly inspection of well sites with 2 tpy emissions is cost-effective, we recommend that the 3-tpy-emissions threshold in the currently proposed standard be reduced to 2 tpy emissions and that the frequency of inspections be increased to quarterly.
• Sites below 2 tpy emissions need to be inspected at least annually.
• Require a time limit on the need to replace all pneumatic values and actuators.
• Develop a process for the incorporation of monitoring data from third-parties. The expanded monitoring may result in a major public health benefit.
• We look forward to secondary proposal due in Spring 2022 and hope that new methodologies for monitoring are approved and incorporated.

In the US, oil and gas production is the largest industrial source of methane pollution. Each year, the oil and gas industry releases 16 million metric tons of methane, and without immediate action, methane pollution from the industry will continue to skyrocket. We urge EPA to promulgate these standards in the most expeditious fashion to defend our children and their future.

Sincerely,

The Rev. Mitchell C. Hescox, President/CEO"

Speak out for children's health by submitting your own comment to the EPA here.

[i] Hays J, Shonkoff SBC (2016) Toward an Understanding of the Environmental and Public Health Impacts of Unconventional Natural Gas Development: A Categorical Assessment of the Peer- Reviewed Scientific Literature, 2009-2015. PLoS ONE 11(4): e0154164. doi:10.1371/journal. pone.0154164

[ii] https://oilandgasthreatmap.com/threat-map/

[iii] Perera F. Pollution from Fossil-Fuel Combustion is the Leading Environmental Threat to Global Pediatric Health and Equity: Solutions Exist. Int J Environ Res Public Health. 2017;15(1):16. Published 2017 Dec 23. doi:10.3390/ijerph15010016

[iv] Stacy SL, Brink LL, Larkin JC, Sadovsky Y, Goldstein BD, Pitt BR, et al. (2015) Perinatal Outcomes and Unconventional Natural Gas Operations in Southwest Pennsylvania. PLoS ONE 10(6): e0126425. doi: 10.1371/journal.pone.0126425, downloaded September 28, 2015, http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0126425

[v] Lisa M. McKenzie, Ruixin Guo, Roxana Z. Witter, David A. Savitz, Lee S. Newman, and John

L. Adgate, Birth Outcomes and Maternal Residential Proximity to Natural Gas

Development in Rural Colorado, Environmental Health Perspectives doi:10.1289/ehp.1306722. downloaded September 28, 2015, http://ehp.niehs.nih.gov/1306722/#tab3

[vi] Casey J.A., et al., “The association between natural gas well activity and specific congenital anomalies in Oklahoma, 1997-2009,” Environment International, Volume 122, January 2019, 381-388, https://www.sciencedirect.com/science/article/pii/S0160412018317999?via=ihub

[vii] Zavala-Araiza, et al., (2015) “Toward a Functional Definition of Methane Super-Emitters: Application to Natural Gas Production Sites,” Environ. Sci. Technol. 2015, 49, 13, at 8167−8174 (“Zavala-Araiza (2015)”)