Testimony of Gabriel Poveda before the Environmental Protection Agency 

Good morning to the honorable men and women of the Environmental Protection Agency. My name is Gabriel Poveda,  I’m a student from the University of Texas at Austin and a representative of Environment Texas. The reason I’ve driven up here, on I-35, for three and a half hours, on this Thursday morning, is to express concern and disapproval at a proposed policy amendment that threatens my community's safety and wellbeing. Today, I’d like to convince the members here assembled that the New Source Performance Standards set in 2012 and 2016 are indispensable tools in the fight against air pollution and climate change.

The current methane policy, which regulates performance standards for the transmission and storage of natural gas, has been effective. It cuts 69,000 tons of methane from the atmosphere. It’s even supported by energy leaders at BP, Shell, and Exxon Mobil. Given that this regulation points the industry down the right path, I’m confused why the agency is now turning backwards. Looking at this proposed policy amendment and its effects, I come to one definitive conclusion: deregulation is dangerous. Deregulation will undermine the strength and spirit of the Clean Air Act. Deregulation will damage vital efforts to combat greenhouse gas emissions. Deregulation will dump tens of thousands of tons of methane and hazardous pollutants into the air we breathe; and deregulation will deny young and old alike of a state of health and environment they can never get back. 

In anticipation of this amendment, the agency conducted a regulatory impact analysis which tells us that relative to the current baseline, this amendment will increase volatile organic compound emissions by at least 910 tons per year. The reason that number matters is because chronic exposure to VOCs increase the risk of cancer and the development of asthma in children. That’s not to mention immediate side effects like nausea and coughing. The same holds true Hazardous Air Pollutants, which the analysis says will increase by at least 26 tons per year. They cause neurological, reproductive, and developmental damage which compounds over time. There are already cancer clusters in east Texas and in Houston; there are already high rates of asthma in west Texas and the Permian Basin. In terms of cancer, we have had enough of that. In terms of asthma and developmental disease, we have had enough of that.

This amendment also contributes to climate change. From 2019 to 2025, according to the regulatory impact analysis, deregulation will put 370,000 tons of methane into the atmosphere. Methane is a greenhouse gas at least 30 times as potent as carbon dioxide. It will rise from our land and in our air begin a process that degrades the quality of life of every American, regardless of socioeconomic status. In Texas, according to the National Climate Assessment, sea level rise along the western Gulf of Mexico is likely to be 1 to 4 feet before the century is out. Such a change will cause a change in the shore, costing coastal communities of their land, their roads, their schools, their homes. It will exacerbate the risks and impacts of storm surges and $20.9 billion in coastal property is projected to be flooded at high tide by 2030.  For those away from the coast, the Edwards Aquifer will suffer from a decrease of water supply during droughts, this will result in habitat loss, agricultural loss, and the intersection of these crises will cause economic loss far exceeding that which is gained by this amendment. 

Recognize the science or not, climate change has come to Texas. Recognize the science or not, west Texas has faced unnaturally frequent droughts in the last ten years and has some of the highest levels of asthma of anywhere in the country. Recognize the science or not, east Texas has had five once in five-hundred year floods in the last ten and storms like Harvey, Ike and Imelda bring increasing disaster with each coming season. Recognize the science or not, climate change and air pollution are our shared fierce foe that can permeate and infect our ordinary lives. We cannot afford to aid and abet this enemy, not now, not ever.

I know that tens of thousands of texans make their livelihoods in the oil and gas industry. I believe that they have every right to go about their lives in peace and to provide for their families. This deregulation is not about them. Instead of helping, it threatens the homes they have built, the health of their loved ones, the hope that their children can live happy and whole. The agency says that this deregulation will save the industry $123 million over the next six years. And I as a student say “no, the agency is mistaken.” This amendment is wrong because some things that are worth more than 123 million dollars and what’s at stake, what we stand to lose, is worth much much more.