The chapter believes that there is significant scientific evidence to conclude that climate change is occurring, and that is is caused by human activities. The greatest cause of this change is the burning of coal, natural gas and petroleum (fossil fuels), which produce most of the man-made carbon dioxide contributing to global warming. Carbon dioxide is what is called a greenhouse gas, as it allows the earth to retain heat much like the glass of a greenhouse.
In August, 2015, the federal Environmental Protection Agency (EPA) adopted rules that would require reductions in the amount of carbon dioxide emitted by electric power generating facilities. The rule was initially published in early 2014 and was subject to a public participation process, with hearings held across the country. It required new fossil fuel powered electric generating fcilities to severely limit the amount of carbon dioxide they emit into the atmosphere while another part of the rule applied emission standards to existing facilities. The chapter attended the hearing in Pittsburgh and provided the following comments:
Hearings for the Clean Power Plan for Existing Power Plants and the Carbon Pollution Standard for Modified Sources
July 31, 2014
William S. Moorhead Federal Building, Pittsburgh, PA
"My name is Dan Alters, Conservation Chair for the Lycoming Audubon Society. I have a BS in biology and a Masters degree in environmental pollution control. I was employed for 35 years by the Pennsylvania Department of Environmental Protection, completing my career as the water programs manager. I live in rural northcentral Pennsylvania, where I regularly hike, hunt, fish, canoe, bike and bird watch. I am very concerned that these activities, which I enjoy so much, may one day be severely limited due to climate change. Thank you for the opportunity to comment on the proposed carbon rule today.
Audubon and its network of 460 chapters are committed to conserving and restoring natural ecosystems, focusing on birds, other wildlife and their habitats, for the benefit of humanity and the earth’s biological diversity. I want to express our strong support for the U.S. Environmental Protection Agency’s critical efforts to put limits on carbon dioxide and other pollutants from existing power plants. EPA’s proposed carbon reduction targets are a strong start toward reducing emissions. We believe these pollution reductions can be achieved at a reasonable cost, a cost to our nation and the world society we believe is far less than the cost would be if global warming remains unchecked. We believe strongly that worldwide climate change will cause increased floods and drought, rising sea levels, food shortages and famine. These in turn will create huge refugee issues for less-affected countries and likely new wars and other human strife. One only needs to review the climate change contingency plans of our own Department of Defense for a list of these possibilities.
We therefore believe more needs to be done. The proposed goal is too conservative and the plan allows far too much time for compliance. State plans should include automatic provisions to correct any shortfall in emission targets that may occur, and severe penalties for failing to meet goals. A federal review of state programs should occur at least every five years. Finally, it makes no sense to control carbon emissions in this country while we export millions of tons of coal overseas – we need to limit coal sales to countries that have acceptable plans to control carbon emissions.
Lycoming Audubon is greatly concerned about the impacts of climate change on avian species. Birds have long served as key indicator species of ecosystem health. America’s 46 million bird watchers spend roughly 32 billion dollars a year, generating 85 billion dollars in overall economic output and 13 billion dollars in tax revenues. Bird watching, hunting, and other outdoor activities enjoyed by more than 80 million Americans, support over 2.6 million jobs. These jobs are at risk if EPA does not effectively control carbon emissions.
Lycoming Audubon commends the EPA for its leadership on this critical issue. We fully support the proposed rule and would urge EPA to make it even stronger. Thank you for considering these comments."
The National Audubon Society has been working hard to determine the likely impact of climate change policy on birds. Initially, Audubon's "Birds and Climate Change Report" was published in the September/October 2014 issue of Audubon magazine, and thi was followed by an updated report in late 2019, "Survival by Degrees: 389 Bird Species on the Brink". The NAS web site has an enormous amount to information, and is highly recommended.
Federal Agency Climate Change Strategy
The Department of Defense at one time published a comprehensive report called the "Climate Change Adaptation Roadmap", which detailed threats to domestic and foreign bases of our armed forces caused by the impacts of climate change. The current administration either deleted or blocked it.
Fossil fuels have transformed the world. The use of coal energized the industrial revolution, but at a price paid in human lives, disease, land degradation and environmental pollution that remains today. Even now it is a major source of electricity production. The discovery of deep formation crude oil, right here in Pennsylvania, enables the use of nearly every motor vehicle on our roads, construction sites and farms. Natural gas, the latest fossil fuel of significance, is touted as a "clean" fuel, a premise many environmentalists dismiss, primarily due to the routinely unmonitored but well-documented huge volumes of methane released during production and transporattion of natural gas. Methane is a powerful green-house gas. The following are some sites with far more expertise than LAS:
- Union of Concerned Scientists – a scientific organization
- Natural Resources Defense Council links – an environmental group
- Goldman-Sachs analysis – an economic perspective
- Sandia Group – a government think tank
Wind energy deserves a special place among the alternative energy sources. It is suitable for a number of locations across the USA, but installation has been slower than desirable due to significant government subsidies, as compared to current fossil fuel or nuclear energy subsidies. The National Audubon Society thinks wind energy is a viable alternative energy, but must be properly sited to be economically sustainable and to avoid excessive bird mortality.
Marcellus Shale Gas Development
Lycoming Audubon has taken several positions regarding Marcellus gas development in Pennsylvania.
While the chapter does not directly oppose the development of the Marcellus and other shale formations, we believe there is inadequate regulation of the industry, for several reasons. First, the current oil and gas regulations are not strong enough in terms of general water quality protection, soils erosion and sedimentation control, solid waste handling and disposal, the control of radioactive substances encountered during drilling, air emissions control and specifically the release of methane (natural gas) into the atmosphere, wetlands protection, and the consideration of threatened and endangered species. In that the current regulations are based on a law (Act 13) determined to be unconstitutional by the states Supreme Court, new laws and regulations need to be developed that are appropriately protective. Second, the state's primary regulatory agency, the Department of Environmental Protection, is grossly underfunded in almost all program areas, but especially in its Oil and Gas Field Operations. A well may take months to drill and develop fully, but may only receive a few inspections. Critical operations such as the cementing of well casings or the hydraulic fracturing procedure may occur outside of those inspections. Some wells are not inspected at all. Third, there are many exemptions allowed under Federal law that preclude more stringent regulation by the state, such as well operator's ability to not disclose the names of chemicals injected into the ground during hydraulic fracturing.
Pennsylvania is the only major natural gas producing state that does not levy an extraction fee, also called a severance tax. This is a tax based on the actual annual gas production by a company. Although PA does have an impact fee, the revenues produced are less than projected under any of the severance tax legislations proposed a couple of years ago. Lycoming Audubon has testified at a hearing by a committee the Pennsylvania General Assembly supporting the enactment of a fair severance tax.
Loyalsock State Forest
Marcellus gas exploration and development has been proposed in the western portion of the Loyalsock State Forest, which contains the Rock Run watershed, the Old Loggers Path hiking trail, and is a largely intact forest expanse serving as habitat for a number of uncommon bird species, including the threatened yellow-bellied flycatcher. Some of the lands have special deed restrictions - known as the 'Clarence Moore tract' - which allow the Department of Conservation and Natural Resources to exercise greater control over surface activities. Anadarko and Southwest are the two companies with an interest in the forest lands, and Anadarko has produced a management plan for developing the area. DCNR has not been forthcoming about the proposals, taking public comments, or disclosing the proposed plans for the area. Lycoming Audubon is a member of the Save the Loyalsock Coalition, a group of environmental and conservation organizations striving to protect the forest from development.
Like wind power, solar power, and especially photovoltaic electricity generation, deserve special mention. Many entrepreneurs and economists believe solar power use may well be the energy of the future. The amount of energy delivered by sunlight hitting the earth in one hour is more energy the entire world uses in a year. Again, others have far more expertise than LAS:
- National Geographic article – a respected national science magazine
- Wall Street Journal – a leading print news and financial media
- US Department of Energy – US government agency
- Nature – a weekly science journal
The PA General Assembly in mid-2014 proposed a bill called the 'Endangered Species Coordination Act', a bill that would have added layers of bureaucracy to plant and animal species protection laws. Amid a storm of protests the bill never came out of committee. Lycoming Audubon opposed the bill, with the following letter printed in the Sun-Gazette:
After reviewing the draft legislation, reading the hearing testimony, and evaluating some of the arguments both supporting and opposing the proposed Endangered Species Coordination Act, the Lycoming Audubon Society strongly opposes HB1576 and the similar SB1047. We are not alone, as we join the dozens of organizations – representing the many thousands of people that enjoy the living resources of Pennsylvania by hunting, fishing, bird watching and the like – that have gone on record as opposing this questionable proposal.
We believe HB1576 and SB1047 are direct attempts to bring politically-motivated meddling into the scientifically-based protection of Pennsylvania wildlife currently in use by the Fish and Boat Commission and the Pennsylvania Game Commission. Both of these independent Commissions have spoken out against HB1576 and SB1047. There are five good reasons to oppose them. These bills:
- introduce a statutory definition of “acceptable data”, a clear and unnecessary backward step;
- focus on providing protection only to those species that are federally listed, a short-sighted uninformed approach that does not protect all Pennsylvania wildlife;
- add a two-year re-evaluation requirement for threatened and endangered species, an unnecessary requirement that saps resources of both Commissions;
- require second-guessing by the so-called Independent Regulatory Review Committee (IRRC), another wasteful and unnecessary step; and
- eliminate both Commission’s authority to manage data and make recommendations regarding the animal species they protect, transferring it to DCNR, a cabinet-level agency. This clearly represents an attempt to politicize and negate the Pennsylvania Natural Diversity Inventory system, one of the most advanced environmental review systems in the country.
We urge our area legislators to step up and represent the thousands of people that enjoy Pennsylvania wildlife instead of the gas industry and other opportunists that have come out in support of these awful bills. We urge your readers to check out this proposed legislation and take a position, making sure their representatives in Harrisburg know where they stand.