Monday, December 1, 2014

PC(USA) Comments on EPA Clean Power Plan Proposed Rule

NOTE: If you have not submitted comments on the EPA's proposed Carbon rule, you may still do so by the end of the day on Monday, Dec. 1, at our Action Center.

December 1, 2014

Environmental Protection Agency
Clean Power Plan Proposed Rule
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Docket ID No. EPA-HQ-OAR-2013-0602

Dear Administrator McCarthy:

First, let me begin by thanking you for meeting with my colleagues and me the week before Thanksgiving in the Faith Leader meeting at which we delivered thousands of comments on the EPA’s Clean Power Plan Proposed Rule from concerned people of faith. I am truly grateful for your leadership of the Environmental Protection Agency and your proactive approach to protecting the Creation with which God has blessed us.

Adding to that cloud of witnesses and representing the General Assembly of the Presbyterian Church (U.S.A.), the highest deliberative body in this denomination, I am writing to support strongly the EPA’s Clean Power Plan Proposed Rule, which will limit carbon dioxide emissions from existing power plants.  Knowing that carbon pollution is the leading cause factor in global climate change, that the U.S. economy has historically been the largest greenhouse gas emitter, and that power plants are the single largest contributor of such pollution in the U.S. economy, we believe that this rule is essential for addressing global climate change. Climate change is one of the most pressing moral issues of our time, endangering the well-being of current and future generations and all of God’s creation.

In 2008, the 218th General Assembly wrote:

With our Lord, we stand with the ‘least of these’ and advocate for the poor and oppressed in present and future generations who are often the victims of environmental injustice and who are least able to mitigate the impact of global warming that [is falling] disproportionately on them.

As citizens of the U.S., which has historically produced more greenhouse gases than any other country, and which is currently responsible for over a fifth of the world’s annual emissions, we implore our nation to accept its moral responsibility to address global warming [through public policy, as well as through our own actions individually and as communities]…

As advocates for justice, we reject the claim that all nations should shoulder an equal measure of the burden associated with mitigating climate change. Industrialized nations like the U.S. have produced most of the emissions over the last three centuries and deserve to shoulder the majority of the burden… (The Power to Change: U.S. Energy Policy and Global Warming, approved by the 218th General Assembly of the PC(USA))

This policy statement went on to outline numerous policies that could and hopefully will yet be employed to achieve the goal of reducing U.S. greenhouse gas emissions (many requiring an act of Congress). At the time, we called for a national response to climate change that would be based on the best available science, would mitigate the worst impacts of increased prices on people living in poverty in the U.S., and would provide ample adaptation support for the poorest and most affected communities around the globe.  While it is not in the EPA’s jurisdiction to accomplish all this, the Clean Power Plan is an important step in the right direction.

Further, our most recent General Assembly “affirm[ed] the vital importance of sustainable development through faithful stewardship of natural resources and the Precautionary Principle. Such methods of preventing irreversible ecological impacts are part of the basis for a responsible, moral, and scientifically-informed human flourishing, affirming the sacred in societal and creation care, and protecting the earth for future generations.” Clearly, a Clean Power Plan is vital to the principle of sustainable development and future energy decisions should be strongly advised by the Precautionary Principle.  

We know from our global church partners that climate change is already changing life on earth, as we know it. Multi-year droughts in some areas, sea-level rise and extreme flooding in others, are impacting communities and people around the world, particularly those who are most vulnerable, lacking the financial and technological resources required to adapt to a changing climate. Climate change is also already impacting global agriculture, both food supplies and prices. Reducing hunger and alleviating poverty are key concerns for the Church. Yet, we know that climate change is increasing the need and reducing our capacity to respond to it effectively.

By setting limits on the single largest source of carbon dioxide emissions in our economy, the proposed rule will not only begin to reduce the U.S. economy’s contribution to this overwhelming problem, but also will improve public health by decreasing the number of unhealthy air days.  Too often, the people that bear the burden of harmful emissions are communities of color and low-income families.  By reducing our emissions from existing power plants, we will be cleaning up the air that was gifted by God, so that all may breathe freely.

If we hope to prevent the worst impacts of climate change and protect communities around the world, reducing carbon emissions from power plants must be a top priority for our country.  The proposed rule will make important progress towards that goal while still allowing states the flexibility to implement standards in ways that make the most sense for their economies and power needs.

Climate change is already affecting all of us.  But mostly, it will affect our children, our grandchildren, and our most vulnerable neighbors, if we fail to take bold action now to curb its worst impacts.  As Presbyterian Christians, we believe that we have a moral obligation to leave our children a healthy and safe world and to care for our neighbors.  This proposed rule is an important step on the path to meeting that obligation.

Thank you for taking this bold step to protect our future.


The Reverend Dr. J. Herbert Nelson, II
Director for Public Witness

Presbyterian Church (U.S.A.)