Public Statement

supporting

EPA standards

to cut back on pollution

from existing coal-fired

power plants.
strongly support the EPA's efforts to set strict standards

for global warming

pollution

caused by existing power plants. This agency is in place to protect American

citizens by keeping our air and water clean as well as curbing carboe pollution

which is harming the Earth. As a Christian,

believe we are to care for Creation,.

not abuse it. My father had asthma and my mother died of two types of cancer, so have been personally

impacted

by air quality'. The American

Lung Association lists the Atlanta area as being 18 th in year round particle pollution. have also seen the devastating

effects of mountain-top

removal coal mining, used to power the existing power plants, and know this practice dumps carcinogenic

particles

into rivers and streams, heavily impacting

citizens who live near them. As a long-term

resident of Atlanta,

have experienced

the many years of drought we have had, as well as the excessive

rain this summer.

know that climate volatility

is one of the products

of climate change. My cousins have a home on the East Coast which has been impacted

by rising tides, as the bulkhead water barrier is being washed away. Lastly, have 14 nieces and nephews,

and 8 great nieces and nephews,

and can only shudder to thinkwhat

the world will look like as they mature if we continue on ourcurrent

path. urge the EPA to follow through with its plan to limit carbon pollution

by existing power Plants. Sue Sherrill1436 Woodland

Hills Dr NE Atlanta, Ga 30324404-633-1928sesherrill@pobox.comStatement of Susan

Berryman-Rodriguez On behalf

of Hothers

and Others

for Clean Air, a program

of the American Lung Association

of the Southeast,

Inc, October 23, 2013 Re: Reducing

Carbon

Pollution

from Existing

Power

Plants,

Clean Air Act, Section 111(d),

U,S, Environmental

Protection

Agency

Mothers and Others

for Clean Air, a program

of the American

Lung Association, appreciates the opportunity

to provide

input concerning

the need for reducing carbon pollution

from existing

power plants.
Power plants are the largest

stationary

source of greenhouse

gases in the United States, and the electric

sector represents

38 percent

of all energy-related

carbon dioxide (CO2) emissions.

Yet, there are no national

limits on the amount

of carbon pollution allowed

from power plants.

The science

clearly shows that carbon pollution contributes

to rising temperatures

that will increase

the risk of elevated ozone pollution.
Ozone is a highly reactive

gas. When someone

breathes

in ozone it reacts chemically with the body's internal

tissues

causing

inflammation,

much like sunburn of the lung. EPA scientists,

along with many other experts,

have concluded

that ozone pollution

poses serious

health threats

that include:

• Respiratory

harm (e.g. worsened

asthma,

worsened

COPD, inflammation)

• Premature

death (both short-term

and long-term

exposure)

• Heart attacks,

strokes,

heart disease,

congestive

heart failure

• Harm to the central

nervous

system,

and

• May cause reproductive

and developmental

harm For the first time, the World Health Organization

classified

outdoor

air pollution

as carcinogenic. In fact, in 2010, 223,000

people worldwide

died from lung cancer caused by air pollution

according

to their announcement

last week. Currently in the U.S., millions

of children

have asthma

attacks

every year, and ozone smog pollution

is a well-known

trigger.

Any increases

in smog will mean more childhood

asthma

attacks

and complications

for those with lung disease. Additionally, children

are more susceptible

to the health effects

of air pollution because their lungs are still developing,

and they often spend more time outdoors compared to adults. Carbon pollution

standards

applied

to existing

power plants will further

reduce smog- and soot-forming

pollution.

Researchers

(West et al., Nature

ClimateChange, 2013; 3:885-889)

found that efforts enacted

now to reduce

greenhouse gases (e.g. CO2) from all sources

in the U.S. would prevent

over 16,000

premature deaths by 2030.Americans support

strong limits on pollution

from power plants.

According

to abipartisan sur.vey

conducted

for the American

Lung Association,

an astounding

72 percent of voters surveyed

specifically

want EPA to set limits on power plant carbon pollution.
It is a "false choice"

touted by the industry

that we must choose

between

public health and a strong economy.

And the public agrees

with us. According

to the
same poll conducted

for the American

Lung Association,

nearly three quarters

(73 percent) of voters say that we do not have to choose

between

air quality

and a strong economy

we can achieve

both.
We must protect

the health of our children

and others now. Cleaning

up. carbon pollution from power plants will be essential

to saving those lives. Mothers

and Others for Clean Air strongly

recommends

that the EPA issue strong final standards that limits carbon

pollution

to protect

the health and welfare

of Americans,

improve efficiency, create more jobs through

innovation,

and build a strong economy.

Thank you.

Ebi KL, McGregor

G. Climate Change, Tropospheric

Ozone and Particulate

Matter and Health Impacts. Environ Health Perspect 2008;116:1449-1455;

Bell ML, Goldberg R, Hogrefe C, Kinney PL, Knowlton K, Lynn B, et al. Climate change, ambient ozone, and health in 50 US cities. Clim Change. 2007;82:61-76.

Holloway T,. Spak SN, Barker D, Bretl M, Moberg C, Hayhoe K, Van Dorn J, Wuebbles

D. Change in ozone air pollution over Chicago associated with global climate change. J Geophys Res. 2008; 113:D22306

Chen J, Avise J, Lamb B, Salath• E, Mass C, Guenther A, Wiedinmyer

C, Lamarque.J-F,

O'Neill S, McKenzie

D, Larkin N. The effects of global changes upon regional ozone pollution in the United States. Atmos Chem Phys. 2009; 9:1125-1141,

doi:10.5194/acp-9-1125-2009. U.S. Environmental

Protection

Agency, Integrated

Science Assessment

for Ozone and Related Photochemical Oxidants, 2013. EPA/600/R-10/076F.GEORGIACHAMBER
Good afternoon,

my name is Doug Miell. am representing

the Georgia Chamber

of Commerce. The Chamber

is the largest voice of Georgia's

business

community.

This allows us to understand

that
our members

and all Georgia residents

share one important

requirement

the need for reliable and affordable energy. It is a major key to Georgia's

competitiveness

and success.

It underpins

Georgia's business investment

confidence,

employment

growth and enviable

living standards. The Chamber

supports

the market-based

development

of energy generation

capabilities,

of which coal-fueled generation

is an important

component.

Currently,

the development

and management

of the state's energy generation

and distribution

system is carefully

planned to stimulate

required investment, provide supply certainty

& reliability

and minimize,

to the maximum

extent possible, upward pressure

on consumer

prices. EPA's regulatory

processes

must preserve

these principles.
The Chamber

disagrees

with and is worried by EPA's decision to regulate greenhouse

gas emissions under the Clean AirAct. We are worried because EPA has taken a heavy handed approach

on many of its recent actions, often ignoring the needs of specific regions and states.
We are worried because EPA appears to be rushing to achieve an arbitrary

deadline

of June 2014 to propose guidelines

for existing generation

sources.
We are worried that EPA is not completely

focused on respecting

roles defined by the Law, instead, starting with an end in mind, without regard to the possible damage that may be inflicted to achieve that end.Individual Chamber

members

are worried that EPA's greenhouse

gases regulatory

activities,

focused
on existing and new power plants, will undermine

the reliability

and affordability

of their energy supplies, potentially

impacting

their business

profitability

and competitiveness.
If EPA's activities

are left unchecked,

the Chamber

fears Georgia will bear the brunt of EPA's actions on greenhouse gases for existing power plants that may prevent our state realizing its full potential. Today we have four very simple requests

of EPA: • First, slow down. Decisions

around our energy supply have long-term

investment

and supply implications. They are too important

to be made without thorough

and careful analysis; )• Second, consider

what is best for our country in the long term and realize that not all states are alike. A one-size-fits

all approach

is unlikely to deliver the best outcomes; • Thirdly, EPA's actions must allow the States ample time to perform their rightful roles and rulemaking authorities;

and finally )• EPA should immediately

remove regulatory

barriers to efficiency

improvements

at existing coal-fueled power plants. Efficiency

improvements

are a cost-effective

way to reduce emissions, while maintaining

affordable

and reliable operations.
On behalf of the Georgia Chamber

thank you for this opportunity

to raise these points.
Stephen Green2013 Chair

Chris ClarkPresident and CEO www.gachamber.com Atlanta, Georgia 30303-1240

Phone: 404.223.2264 270 Peachtree

Street NW, Suite 2200 Fax: 404.223.2290We thdnk

you

for your

input. Please use this card if you would like to submit written input on controlling carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk. National Public Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power Plants

We thank

you

for your

input.
Please use this card if you would like to submit written input on controllin9 carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk. National Public Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power Plants _0 •_c __.-V•,•

I._•_ •.. •_._•_•__•

•s• ••/<•_•_.• •_•.•

,• .I-••

•.
.•:__.L_ _<• •

J-..•-•

•-.•

.--• •-

•<'--- •

• , .•¢ /•

.. •. i •7- •:e.•_

•,__•7._•_•__•.__•_•_U•. _•_•_....•_• _.•1• •,••'•

• / n ;•-•-•-.-.•-•-•.-.•-•-•., •. •.• r._•___+.•

•_•

.I-.._...r. • I_*.o•.•

..•--•--.-'

.......................................................................We thank

you

for your

input.
Please use this card if you would like to submit written input on controlling carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk. National Public Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power Plants

Meeting location (city/town)

We

thank

you

for your

input.
Please use this card if you would like to submit written input on controlling carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk. National Public Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power PlantsWe thank

you

for your

input.
Please use this card if you would like to submit written input on controlling carbon pollution

from existing

power plants.. Once c<•mpleted,

kindly return to the r.egistration

desk. National Pubfic Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power Plants

, •._ .y_ y .•i•._•m ¢_._.•.•__•¢n•;_.,

........................................................................................................................Georgia Chemistry

Council

Comments Environmental Protection

Agency

Listening

Session October 23, 2013Atlanta, GA My name is Jet Toney, and I speak on behalf of the Georgia

Chemistry

Council (GCC). The Georgia

Chemistry

Council

is an industry

trade association

for the chemistry and plastics

industry,

and we currently

represent

25 companies

with over 35 major facilities

throughout

the state. GCC was founded

in 2003, and our goal is to work with companies

interested

in chemical,

environmental,

and energy policies

in the state of Georgia.

Georgia

Chemistry

is essential

to the state's economy, producing over $13 Billion in product

value, and providing

about 20,000 direct jobs. GCC members

include Georgia-based

companies

like Kemira

and Axiall as well
as international

companies

like BASF, Chevron,

DuPont,

Olin, and Solvay.

Our industry is energy intense.

We use both natural gas and electricity

as feedstock

for
our products.

We crack the natural

gas molecule

to make products,

and we use ,-r•" electricity to prowde

fuel•6ur

electrolysis

processes.

Any action that will put market pressure on the availabilify/price

of natural gas or cause the cost of electricity

to increase could substantially

negatively

impact our industry.

The proposed Environmental Protection

Agency's

regulation

of greenhouse

gases could produce that harmful

impact.
EPA's recent history with the regulation

of greenhouse

gas emissions

under the Clean Air Act appears,

as a whole, misguided.

We are concerned

about the approach the Agency

is taking in its recent proposal

for new power plants, greatly alarming

us as to what that probably

means for existing

plants. We believe

EPA's actions could reduce the affordability

and reliability

of electricity

in Georgia

and the United States, which will unnecessarily

jeopardize

our economic

strength

in the future. GCC members

are great supporters

of energy efficiency

and conservation

through
our member's

contributions

to producing

better window

construction,

reflective roof coatings,

low resistant

vehicle tires, home insulation,

and by our intensive efforts to reduce energy in manufacturing

operations.

In order to accomplish

all of this, however,

our member

companies

must still use large amounts

of electricity

in their production

processes,

so that anything

that threatens

the reliability

and affordability of electric

power can also threaten

the business

viability

of our operations.
In this case, we are concerned

that EPA will try to force fit a program

around energy efficiency and demand

reductions

for existing

power plants into a Clean Air Act framework that was never meant for this type of regulation.

It is our view that requiring any activities

that are outside

the boundary

of an electric

generating

plant is not legal and is bad economic

policy. Should my members

reduce production domestically to reduce electrical

energy use to meet such a system?

If EPA's actions force such questions

to be answered,

there could be significant

ramifications

forjobs and the economy.

Additionally,

the regulations

could cause fuel switching

for the production

of electricity.

Natural

gas fired plants will replace

coal plants. This
new demand

on our domestic

supplies

of natural gas is likely to cause natural gas prices to increase.

Presently,

chemical

manufacturing

is experiencing

a renaissance in American

due to the new discoveries

of natural gas. We have gone from one of the highest

cost producing

countries

to arguably

one of the lowest cost producing countries.
For the sake of our industry

and the whole economy

of Georgia

and the United States, we ask that EPA reconsider

its approach

to regulating

greenhouse

gases for the electric

sector. Thankyou.

For more information,

contact Mr. Rudy Underwood,

GCC Executive

Director: 1955 North Park Place Suite 240Atlanta, GA 30339 770.421.2991 phoneEPA

Hearing on Regulating

Coal Fired Power Plants Green House Gas Emissions
Sam Nunn Federal Center 61 Forsytl• St. SWAtlanta, GA10/23/2013

am Albert Roesel, Jr., a retired teacher. If you simply want to know whether

or not I'm in favor of the EPA issuing regulations

to reduce the emissions of greenhouse

gasses from coal fired power plants, the answer is that am absolutely

and without hesitation

in favor of EPA taking such action. If explanatory

remarks are desired supporting

my position,

then I'm amazed because you have the facts from the scientists

as to the effects of greenhouse

gas emissions

on earth's climate. You know that the climate is warming

to an alarming

degree and at an increasing

rate. And, you know that the emissions of coal fired power plants play an outsized part in affecting

all of the above. So, I'm honored

to think that you're interested

in my thoughts

on the subject and that you came all the way from Washington

to find out, but I'm curious.

Is it even possible that, if you find that we in Georgia want to burn more coal with less regulatory

interference,

that you'll go back to Washington

with the message that nothing can be done because most of the people you heard from in Georgia are not aware of the science of global warming

and of the awe inspiring

experiment

we're running with the planet and all the life forms it carries? Are you and your children and grandchildren

going to have a better planet to live on than me and mine? If could reduce our emissions

of greenhouse

gasses, would. But, the fact is that we rely on the EPA to help us maintain

a sustainable

environment

that supports

our lives.
I'm not a scientist,

but am 70. In my lifetime, the CO2 content of the atmosphere

has increased

from approximately 300ppm to 390ppm resulting

in warmer winters in Georgia.

Our pine forests have always been subject to attack by the pine bark beetles, but when was a child the winters were cold enough that the beetles could not survive the freezing temperatures.

Now they survive through the winters.

In the 1960's cars had to have snow tires or chains to drive in Atlanta in the winter. We used to be the peach state because peaches were a major crop, but now we don't have the hours of freezing temperatures required.in

the production

cycle. Those temperatures

have moved farther north.
It is a frightening

thought that humankind

could go the way of the dinosaurs.

At least there defenders

can claim that a calamity befell them that was not of their own making. We, on the other hand, are changing the earth, making it less favorable

to the survival of our descendants

and those of all other plants and animals that depend on its having about the same average temperature

it had when arrived in 1942.We

cannot continue

to be the most profligate

emitters of greenhouse

gases on a per capita basis on the planet. We are one of the richest nations on earth. We can afford to lead the way in generating

power sustainablyo We cannot afford to continue

to extract coal and burn it. Such a course is catastrophic. The regulations

you issue torestrict

coal burning power plants and to reduce the emissions

of greenhouse gasses are essential

to the survival of our species.

It has always been the goal of each I•enerati0n to leave the next better situated than itself. If you fail to act, there will be no possibility

of
our success in the realization

of that ambition. The EPA must act to reduce the emissions

of coal fired power plants. Thank you,

AlbertJ. RoeseI, Jr. 2709 Zin•ara Rdo NEConyers, GA 30012Testimony for EPA Listening

Session on Carbon Standards,

10/23/2013. Hello, and thank you for letting me speak today. My name is Anne Mellinger-Birdsong. !
am a pediatrician,

an epidemiologist,

and a parent. I am here today to speak in favor of the proposed EPA standards

for carbon pollution. The most recent report from the Intergovernmental

Panel on Climate

Change states that "Warming of the climate system is unequivocal,

and since the 1950s, many of the observed changes are unprecedented

over decades

to millennia.

The atmosphere

and ocean have warmed, the amounts

of snow and ice have diminished,

sea level has risen, and the concentrations

of greenhouse gases have increased."

It further states that "The atmospheric

concentrations

of carbon dioxide

(CO2), methane,

and nitrous oxide have increased

to levels unprecedented

in at least the last 800,000

years. CO2 concentrations

have increased

by 40% since pre-industrial times, primarily

from fossil fuel emissions

and secondarily

from net land use change emissions." The American

Academy

of Pediatrics

policy statement

on Global Climate

Change and Children's Health notes that "because

of their physical,

physiologic,

and cognitive

immaturity, children are often most vulnerable

to adverse health effects from environmental

hazards.

As the climate changes,

environmental

hazards may shift and possibly

increase,

and children

are likely to suffer disproportionately

from these changes.

Anticipated

direct health consequences

of climate change include injury and death from extreme

weather

events and natural disasters, increases in climate-sensitive

infectious

diseases,

increases

in air pollution-related

illness, and
more heat-related,

potentially

fatal, illness. Within all of these categories,

children

have increased vulnerability

compared

with other groups." Children are dependent

on their parents or adult caregivers

for food, shelter, and physical safety. They cannot choose where they live, where they go to school, or the quality of the air they breathe.

They are dependent

on adult decision

makers to set policies

which provide

the best living conditions

for growth and le•naing. Climate change is anticipated

to cause more droughts,

floods and extreme

weather

events. During these events, children

are more vulnerable

because

they are dependent

on adults aiding and protecting

them, telling them what to do and where to go, how to reach safety or shelter, or to escape.Climate

change is anticipated

to cause an increase

in air pollution,

with increased temperatures allowing

formation

of more ozone. This is due to the nature of the chemical reaction in which ozone is formed, with chemical

precursors

plus heat and sunlight

forming

ozone. More heat means more ozone for any given amount of chemical

precursors.

Children

are
more vulnerable

to air pollution

because

1) they breathe more air per body mass than adults, 2) they spend more time playing outdoors,

and 3) because

their lungs are growing

and developing. Children's lungs develop

all the way through the teenage years. Ozone causes asthma attacks, respiratory symptoms,

hospitalizations,

school absences,

decreased

lung function,

and decreasedlung

growth. There is some evidence

that it may contribute

to causing asthma, but this is not yet conclusive.Climate change is anticipated

to expand the range of vectors which transmit

disease to humans, such as mosquitoes,

ticks, and rodents.

Examples

of vector borne diseases

we have in the U.S. which could be affected

by this include Lyme Disease,

West Nile Virus, Rocky Mountain Spotted Fever, and Hantavirus.

All of these could increase

as the growing

season becomes longer, and the range of the vectors expands.

Examples

of other diseases

which could be imported

to the U.S. as their vector base expands

include malaria,

dengue fever, and yellow fever. Again, children

are more vulnerable

to these diseases

because

they spend more time outdoors, and are less likely to take protective

measures

such as wearing

protective

clothes or using insect repellent.
It is possible

for humans

to adapt to some of the effects of climate change, for example by improving

weather

forecasting,

building

more early warning

systems,

improving

disaster planning and preparedness,

and developing

new vaccines

and medicines.

However,

it is far better to try to do all that we can now to prevent the buildup

of greenhouse

gases, and reduce the impacts of climate change. Therefore

I support the new EPA carbon standards.

ReferencesIntergovernmental Panel on Climate

Change.

Climate

change 2007: the physical

science basis-- summary for policy makers.

Available

at: http://www.climatechange2013.org/images/uploads/WGIAR5-SPM Approved27Sep2013.pdf Accessed October

21, 2013. Katherine M. Shea, MD, MPH, and the Committee

on Environmental

Health. Global Climate Change and Children's

Health. www.pediatrics.org/cgi/doi/10.1542/peds.2007-2646

ContactAnne Mellinger-Birdsong, MD, MpH, FAAP 934 Artwood

Rd NEAtlanta, GA 30307404-377-2407amellbird@yahoo.com• AMERICAN•FORPROSPE ITY GEORGIA

Good evening,

my name is Virginia

Galloway,

State Director

of Americans

for Prosperity GA.
Thank you for the opportunity

to speak today about EPA's

plan to regulate carbon dioxide

emissions

from coal-fired

power plants.

AFPGA is concerned

about EPA's

carbon

regulations

because

of their impact

on the use of coal to produce

affordable

and reliable

electricity.

We are particularly concerned about the impact

this regulation

will have on affordability

for our many hardworking

lower income

families.

This economy

is already

hard enough

on families

without

adding

further

strain.
Coal plays a crucial

role in providing

electricity

to consumers

in virtually

every state in the nation.

For example,

coal provides

more than one quarter

of the electricity in 29 states with a collective

population

of more than 175 million people. Unfortunately,

EPA regulations

have already

contributed

to the closure of 300 existing

coal units in 33 states.

And recently

proposed

regulations

would ban new, efficient

state-of-art

coal plants.

We disagree

with EPA's

decision

to regulate

greenhouse

gas emissions

under the Clean Air Act. EPA regulations

are an ineffective

and economically

harmful way to address

climate

change.

But, since EPA is developing

these regulations anyway, I want to offer AFPGA's

perspective.

EPA is focused

on reducing

carbon

dioxide

emissions

from coal-fired

power plants as a way to address

global

climate

change.

However,

carbon

dioxide emissions from the U.S. coal fleet represent

only 3 percent

of global

greenhousegas

emissions.

Reducing

carbon

dioxide

emissions

from the U.S. coal fleet will increase energy

prices

without

having

any meaningful

effect on global

climate change. Further,

the U.S. electric

sector has already

reduced

its carbon

dioxide emissions more than any other sector of the economy.

U.S. power plants have reduced carbon

dioxide

emissions

by 16 percent

below

2005 levels,

and carbon dioxide emissions

from coal-fired

power

plants

have declined

by almost

24 percent. No matter

what hoops

power

producers

jump through,

you seem to design a more unreasonable

and difficult

hoop.
With that in mind, we believe

EPA should

follow

these principles

in developing carbon regulations:First, EPA's

carbon

regulations

should

do no harm.

Carbon

regulations

should not interfere

with affordable

electricity

prices

and reliable

electricity

supplies, whether states rely on coal or another

source. Second, EPA's

carbon

regulations

should

provide

states with all the flexibility they need in order to develop

plans that suit their unique

circumstances, including continuing

their use ofcoal,

if they choose

that approach.

Also, EPA must give states ample time to develop

and implement

their plans, Third, coal plant owners

are expected

to invest over $30 billion

in the near-term to further

reduce

emissions

of conventional

air pollutants.

EPA must ensure that carbon

regulations

do not cause additional

premature

closures

of coal units and, therefore,

stranded

investments

in emission

controls. Finally, EPA should

remove

regulatory

barriers

to efficiency

improvements

at existing coal-fueled

power plants.

Efficiency

improvements

are a cost-effective way to reduce

emissions,

while maintaining

affordable

and reliable

operations. EPA should

remove

barriers

to these projects.
Thank you for your attention. Virginia Gallowayvgalloway@afphq.orgEPA Hearing

Comment:

Hello, my name is Ragan Davis. I'm a student

at Georgia

State University

and an intern at Environment

Georgia.

Thank you for the opportunity

to speak today.
I've worked

at the Piedmont

Park farmer's

market

the last two summers.

This summer, I heard a message

over and over again: the unusually

massive

amounts

of rain we're experiencing

are threatening

the crop yields of our farmers,

and are therefore threatening

the livelihoods

of our farmers

who make up a vital part of the Georgia economy.

According

to the Environmental

Defense

Fund, "Researchers predict that if climate

change triggers

an additional

crop shortage

of 5%, the economic impacts

could cost nearly $110 million annually."

As an Environment Georgia intern, I recently

traveled

to Macon for a press conference

at the Ocmulgee River, where flooding

this past spring caused serious damage

to countless

roads, bridges, and homes. Erratic weather

events like these that hurt Georgia

businesses and individuals

will only become

more frequent

as global warming

emissions

are left unchecked.

As a young person,

I will be one of the many people in the future left to bear the weight of problems

associated

with changing

weather

patterns,

declining air quality,

and rising temperature•

ifjglo•?al

warming

emissions

are not controlled now. Power plants make up aboutJ•l•J•

these emissions

in the United States, so if the U.S. is looking

to abate carbon pollution,

it needs to start with this industry

and start soon.1691 Halsema

Road N Jacksonville FL 32220October 7, 2013 United States Environmental

Protection

Agency Region 4 Sam Nunn Atlanta Federal Center 61 Forsyth St. SWAtlanta GA 30303

RE: Docket ID No. EPA-HQ-OAR-2013-0495

Dear Administrator

McCarthy,

I'm a member

of my local not-for-profit

electric cooperative

and this rule has me really concerned.

In uncertain economic

times, urge the Administration

to stick by its "all-of-the-above"

promise. Administrator McCarthy,

please withdraw

this proposal

and work with electric cooperatives

on a common sense solution that balances

energy needs and environmental

concerns. Thank you.Sincerely,

Tina Frady1691 Halsema

Road N Jacksonville FL 32220October 7, 2013 United States Environmental

Protection

Agency Region 4 Sam Nunn Atlanta Federal Center 61 Forsyth St. SWAtlanta GA 30303

RE: Docket ID No. EPA-HQ-OAR-2013-0495

Dear Administrator

McCarthy,

I'm a member

of my local not-for-profit

electric cooperative

and this rule has me really concerned.

In uncertain economic

times, urge the Administration

to stick by its "all-of-the-above"

promise. Administrator McCarthy,

please withdraw

this proposal

and work with electric cooperatives

on a common sense solution that balances

energy needs and environmental

concerns. Thank you.Sincerely,

Anne MorabitoTESTIMONEY BEFORE

THE ENVIRONMENTAL PROTECTION

AGENCY ON PUBLIC

LISTENING

SESSIONS

ON REDUCING

CARBON

POLLUTION FROM EXISTING

POWER

PLANTS,

OCTOBER

23, 2013
Dr. James H. Rust, Policy Advisor

The Heartland

Institute J'accuse the Environmental

Protection

Agency

(EPA) of proposing

rules to abolish use of coal for stationary

power plants that unnecessarily

increases

costs of electric power generation

with harm to health and economy

of our country. J'accuse the EPA of implementing

rules to abolish use of coal for future electric power plants with unnecessary

harmful

increased

cost for electricity.
J'accuse the EPA of implementing

Mercury

and Air Toxic Standards

(MATS)

on coal-fired electric power plants that added unnecessary

expenses

to their operation

with forced plant shutdowns and increased

electricity

costs. For five years the EPA has waged war on fossil fuels due to misguided

views carbon dioxide from burning

fossil fuels causes catastrophic

global warming.

The EPA is substituting

words carbon pollution

for carbon dioxide in order to mislead

the public about its aims. To the public, the words carbon pollution

means soot that conjures

up images of blacked

snow in the winter and soot-covered cars prevalent

before the 1960s--a

time when coal was burned without environmental controls.

This is the same misrepresentation

applied to global warming

alleged due to burning

fossil fuels. When global warming

stopped in 2000 in spite of increased

use of fossil fuels, climate change was substituted

for global warming

as key words for predicted cataclysmic planet future. In a sense alarmist

views can't miss with this label because

climate change is continuous

over the 4 billion-year

planet history. Fossil fuel use has annually

increased

in an energy-starved

planet due to demands

of poorer inhabitants for a decent living standard.

This caused an increase

in atmospheric

carbon dioxide from 310 parts per million (ppm) in 1950 to 400 ppm in 2013. For more than a century it has been hypothesized

atmospheric

carbon dioxide absorbs

infrared

radiation

and re-emits

the radiation back to the atmosphere

causing planet warming

labeled the greenhouse

effect. Water vapor, with an average atmosphere

concentration

of 10,000 ppm, produces

the same effect. Concerns about global warming

caused by increased

fossil fuel use resulted

in creation

of the United Nations

organization

Intergovernmental

Panel on Climate

Change

(UNIPCC)

in 1988 to study effects of increasing

atmospheric

carbon dioxide.

Since 1990, the IPCC has published

a series of five reports (1990, 1995, 2001, 2007, and 2013) stating their beliefs in the role of carbon dioxide on climate and made projections

of future global temperatures

based on computer generated data from global climate models. The EPA has used IPCC reports as their sole source of information

about the role of increasing atmospheric carbon dioxide from increasing

fossil fuel use. The IPCC reports estimate

increasedglobal warming

so the EPA embarked

on a path to reduce fossil fuel-use

starting with coal, oil, and, natural gas.The UNIPPC

was an international

organization

predicting

future climate change without oversight. To balance their reporting,

the Nongovernmental

International

Panel on Climate Change (NIPCC)

was created in 2003. The 2007 IPCC report stirred up controversy

over errors and the NIPCC issued a countering report Nature, Not Human Activity,

Rules the Climate

in 2008. To highlight

more details about
errors in the 2007 IPCC report, the NIPCC produced

an 856-page

report Climate

Change Reconsidered: The 2009 Report of the Nongovernmental

International

Panel on Climate Change. The Heartland

Institute

assisted

in preparation

and publication

of these reports. Anticipating science to be overlooked

by the 2013 IPCC report, the NIPCC produced

Climate Change Reconsidered:

The 2011 Interim Report of the Nongovernmental

International

Panel on Climate Change.

The report featured

new scientific

evidence

and information

overlooked

by the 2009 report and is found on the Internet at < ww•v.nipccreport.org >. With much media attention

and leaking of portions

of its report, the UNIPCC

announced publication, of its fifth report September

27, 2013. In anticipation

of the IPCC report, the NIPCC released its first of two reports the 1000-page

Climate

Change Reconsidered

11: Physical Science and 20-page

Summary

for Policymakers

September

17, 2013. The key takeaway messages are (1) the human impact on climate is very small and (2) any change in temperatures that might be occurring

or will occur in the future is so small that it will not be noticed against the climate's

entirely natural variability.

These reports are available

on the Internet at <http:/) www.climatcchangereconsidered.org >.
In order to compare

information

from the NIPCC with that of the IPCC, the 2013 IPCC Summary for Policymakers

issued September

27, 2013 is found at <•ttp:, www. c/imatechange2013,

or,• images. uploads,

W( •L4 R5-SPM

Approved27Sep2013. The IPCC report glosses over no global warming

for 15 years and failure of all global climate models to match experimental

global temperature

data.
The EPA refuses to examine

information

that counters

global warming

is produced

by increased
use of fossil fuels and any benefits

achieved

by global warming.

There are thousands

of papers and books showing

benefits

of global warming

and increased

carbon dioxide on the planet. A good summary

of benefits

is the paper in the October

19, 2013 Spectator

"Why Climate

Change is Good For The World" by Matt Ridley found at <http://www.spectator.co. uk/features/9057

51/carrv-on-warmi

n,,•. :¢. Warming saves lives while cold kills. It is estimated

29,000 Britons died in the United Kingdom the past winter due to cold. Increasing

atmospheric

carbon dioxide increases

plant growth andmakes plants more resistant

to drought due to larger root systems.

We are able to produce enough food to feed 7 billion on the planet due to the 40 percent increase

in atmospheric

carbon dioxide concentrations

since the start of the Industrial

Revolution.
It is suspected

the EPA will issue rules involving

carbon dioxide emissions

for current power plants similar to rules applying

to future power plants--1000

pounds of carbon dioxide emissions per megawatt-hour

(MW-hr.)

for natural gas-fueled

power plants and 1100 pounds of carbon dioxide emissions

per MW-hr.

for coal-fired

power plants. The rules for future power plants were issued September

2013 which prompted

lnvestor's

Business

Daily to write an editorial September

20, 2013 "New Rules On Power Plants Will Kill Coal Industry"

found at < http://news.investors.com/ibd-editorials/092013-671984-epa-rules-will-send-ener•,5,-costs-up_ sharplv.htm

>. The editorial

stated, "Far from being a plan to clean up the environment,

it is in fact a road map to de-industrialization

and poverty."

Examples

were given of power plant shutdowns and the threat of businesses

to leave the country because

of escalating

electricity prices.
Gas turbine combined

cycle (GTCC)

power plants can meet the requirement

of 1000 pounds of carbon dioxide emissions

per MW-hr.

High performance

coal-fired

power plants typically

emit 1800 pounds of carbon dioxide per MW-hr.

and can't meet these standards

without carbon dioxide capture and sequestration

(CDCS) of at least 40 percent of carbon dioxide emissions. CDCS has not been demonstrated

for large power plants. It is a very costly process that requires one-third the power output of plants and needs safe places for underground

storage of enormous amounts of high-pressure

carbon dioxide.

Widespread

application

of CDCS would require annual storage of billions of tons of carbon dioxide. Underground storage of high-pressure

carbon dioxide presents

safety problems

never .encountered in the United States. Carbon dioxide is denser than air and large leaks from underground storage would produce

situations

where leaking gas spreading

along the earth's surface would suffocate

all encountering

the gas. In 1986, carbon dioxide emerging

from Lake Nyos in the Cameroon

suffocated

1700 people and thousands

of head of cattle. Similar situations have occurred

elsewhere

in Africa.
It is ironic the EPA charged

with safety of American

citizens is taking a non-existent

hazard of carbon dioxide emissions

from burning coal and creating

situations

of enormous

waste of money on CDCS that kills unsuspecting

citizens.

This debacle applies to controlling

carbon dioxide emissions from current and future coal-fired

power plants.

A critique of EPA's Mercury

and Air Toxic Standards

(MATS)

by Prof. James H. Rust "Do New EPA Regulations

on Power Plant Mercury

Effluents

Make Sense?'?

is published

May 3, 2011 byThe Heartland

Institute

< •ttp://biog.

heartland.or•'2011/05/do-new-cpa-regulations-on-powerplant-mcrcurv-c/tluents-make-sense/ >. These rules reduce mercury

emissions,

that are not problems, from coal-fired

power plants at great costs and shut downs of operating

power plants. At the same time EPA endorses

use of compact

fluorescent

light bulbs (CFL) because

they use less .electricity.

CFLs contain about 4 milligrams

of mercury

and when you factor in over one billion CFLs in use today and fast growing,

you have a vast potential

for mercury

contamination directly inside homes from bulb breakage

and improper

disposal.

When the four billion light sockets in homes are filled with CFLs (18 tons of mercury),

considerations

of mercury contamination from coal-burning

power plants may look silly. Humans

occupy less thanonetenth percent of the United States' land area for living space; so inside mercury

contaminations per square foot can be large.

In summary,

using poor science and a lack ofjudgrnent,

the EPA has promulgated

rules pertaining to fossil fuel use that are aimed at eliminating

use of the nation's

vast reservoir

of fossil fuels. Once these rules are implemented,

more onerous

rules must follow.

Great economic damage is done that leads to poverty

for the nation. On top of these problems,

the rules that are issued in the name of promoting

health Create health problems

far more damaging.
The EPA is succeeding

in these objective

due to lack of realistic

media attention

and public apathy. At the end of WWII, Pastor Martin Niemoller

was asked how this destructive

Nazis Party could take over the country in the 1930s. He said apathy and produced

a four-sentence
verse that described

his failure to sound alarm about impending

events.
In our present time Pastor Niemoller

might have said the following

about EPA pollution

rules: First they closed the coal mines, and I didn't speak out because

I was not a miner. Then they stopped

oil and gas drilling,

and I didn't speak out becaus'e

I didn't work in oil fields. Then they shut down nuclear power plants, and I didn't speak out because

I didn't work at nuclear power plants. Then they shut off all my electricity

and there was no one left to speak out for me. Heed these words; the EPA is set upon a path to destroy the Unites States economy

and impoverish most of our citizens.

Poverty

kills as surely as d•sease. Dr. James H. Rust has a B. Sc. Chemical

Eng., M. Sc. Nuclear

Eng., and Ph.D. Eng. Awarded 1958 Purdue U. Outstanding

Chemist;

Awarded

national

competitive

Fellowships--National Science Foundation

(2) and Atomic Energy Special (2); Awarded

Georgia

Society of Professional Engineers

1977 Engineer

of the Year in Education

and 1982 Engineer

of the Year: Awarded Engineers

of Greater Atlanta

1977 Engineer

of the Year in Education

and 1982 Engineer of the Year; Nominated

Purdue University

2006 Outstanding

Chemical

Engineer. Performed research

and taught at Purdue University,

The University

of Virginia

(Assistant Prof.), Georgia

Institute

of Technology

(Assistant,

Associate,

and Full Professor).Testimony of Frank Bove, Tucker

GA at the EPA Reducing

Carbon

Pollution Listening Session,

Atlanta

GA, October

23, 2013

Good Evening.

I am the board president

of Environmental

Community

Action, ECO-Action. ECO-Action

is a grassroots

environmental

organization

that serves the state of Georgia.

The most efficient

way to reduce

carbon

pollution

from existing

power plants is to reduce or eliminate

the need for these power plants in the first place.

This can be achieved through

a robust program

of energy

efficiency

measures

and the promotion of solar and wind power.

The American

Council

for anEnergyEfficient Economy

(ACEEE)

in a recent study concluded

that the best system

of emission reduction

would be achieved

through

end-use

energy

efficiency

and renewable generation

(August

13, 2013 report # E 131). End-use

energy

efficiency alone could reduce

electricity

demand

by 15 % by 2020 with the reduction

of 463 million tons of green house gases.

By 2030, about 27% of total forecasted electricity consumption

could be saved by end-use

energy

efficiency

measures. These measures

are cost-effective

and can be quickly

implemented.

Moreover, they can result in the creation

of hundreds

of thousands

of new jobs. Every $1 million invested

in energy

efficiency

retrofits

not only saves energy

but creates about 25 construction

trade and manufacturing

jobs. A program

to install energy efficient appliances,

heating

and air conditioning

systems,

hot water heaters, insulation and energy-efficient

windows

in homes

across GA would create many tens of thousands

of new construction

trade and other jobs in our local communities. These retrofits

would not only improve

home values but would also provide a strong economic

boost to our communities,

supporting

additional

job growth.

The U.S. has a long way to go in the area of energy

efficiency.

One study ranked the U.S. 9 th out of the 12 largest

world economies

in energy

efficiency.

Twenty five states now have adopted

energy

efficiency

resource

standards,

but it is time for
a national

standard

with mandatory

targets

for energy

efficiency.

Certainly

the other 25 states need to be encouraged

to adopt an energy

efficiency

resource standard.The

promotion

of solar and wind power is also crucial

for the reduction

of green house gases.

Most states now have renewable

portfolio

standards

setting

targets for solar capacity,

but most of the southern

states in the U.S. have not adopted

an RPS. The importance

of solar electric

energy

for reducing

green house gas emissions should

not be ignored.

Every 1,000 kWh generated

by a solar PV system avoids 1,102 pounds

of green house gas emissions

as well as other hazardous

air pollutants. The state of Massachusetts

has a model program

for solar energy

and energy efficiency.

Today,

there are about 80,000

clean energy

workers

in the state. Last year, about 8,500 new clean energy

jobs were created

in MA, a growth

of 11.8%. Over the last 7 years, the state has achieved

157% growth

in electric energy savings

from energy

efficiency

measures.

The state now has 311 MW of solar energy

capacity,

sufficient

to provide

power to over 50,000

homes.

Its solar rebate program

to help residences

to install solar PV systems

and heat/hot

water systems is a model that should be adopted

nationwide.
ECO-Action urges the EPA to consider

including

in its program

for reducing

green house gas emissions

from existing

and new power plants,,

a robust,

national program for end-use

energy

efficiency

and renewable

energy.

It should

encourage states to adopt model programs

such as the one in MA. It should provide

funding to local community

organizations

so that they can implement

energy

efficiency

and renewable energy

programs,

especially

in low-income

neighborhoods

where home retrofits and resulting

new jobs to neighborhood

residents

can be a boost to the local economy

as well as make an important

contribution

to reducing

green house gas emissions.
Thank you.

Environmental Community

Action (ECO-Action) 250 Georgia

Ave, Suite 309 Atlanta, GA 30312(404) 584-6499Michael Wall, Georgia

Organics

Director

of Programs,

7 th Generation

Georgia

Farmer. 404-374-9676, 401 Florida Ave. SE, Atlanta,

GA 30316. michawal!@gmail.com "Agriculture is highly sensitive

to climate

variability

and weather

extremes,

such as droughts, floods and severe storms.

The forces that shape our climate

are also critical to farm productivity.

Human

activity

has already

changed

atmospheric

characteristics such as temperature,

rainfall,

levels of carbon dioxide

(CO) and ground

level ozone. The scientific

community

expects

such trends to continue.

While food production

may benefit from a warmer

climate,

the increased

potential

for droughts,

floods and heat waves will pose challenges

for farmers.

Additionally,

the enduring

changes

in climate, water supply and soil moisture

could make it less feasible

to continue

crop production

in certain regions."U.S. Environmental

Protection

Agency. http://www.epa.gov/climatechanqe/impacts-adaptation/agricu•ture.html Georgia's state climatologist

told me, "It may be a situation

where we have fewer rain events, but each rain event would be heavier,

which will have a tendency

to increase flash flooding.University of Maryland

study, "Ecomonic

Impacts

of Climate

Change

on Georgia"

says, "there has already

been a 2-4 % increase

in the frequency

of heavy precipitation

events influencing among

other things, erosion,

water quality,

and agricultural

productivity. Another study, by the American

Security

Project,

estimates

that temperatures

in Georgia could rise by 4.5 degrees

Farenheit

in winter and 5.4 degrees

in summer, accompanied by a 5 percent

increase

in annual precipitation. Farmers are used to uncertainty

and worrying

about the weather.

It comes with the job. But we're getting to a point where the state's No. 1 industry,

agriculture,

won't be able to adapt to the new world that climate

change

is creating. Doing nothing

is worse than irresponsible.

It's suicidal.
The EPA should propose

a strong carbon pollution

standard

for existing

power plants, so they are no longer allowed

to dump unlimited

amounts

of dangerous

carbon pollution into the air.Addressing climate

change

is our obligation

to our children

and future generations,

and the EPA can take the largest step our country

has ever taken in that effort by limiting carbon pollution

from power plants.Janet Callum1069 Berne

Street

SEAtlanta, GA 30316EPA Carbon

Pollution

Protections

Testimony October 23, 2013

am a retired

Atlanta

Public

Schools

teacher

and long-time

resident

of the city of Atlanta.

As a resident

of a metropolitan

area that for many years has suffered

from some of the poorest

air quality

in the country,

am very concerned

about

the issue of carbon

pollution.

As a teacher in the inner city, was astonished

and distressed

by the number

of asthmatic six and seven

year-olds

in my classes

over the years. Inhalers were routine

school

supplies

alongside

pencils

and notebooks. Absenteeism

among

children

with asthma

was rampant and it affected

their academic

outcomes.

Asthmatic

children

who
come to school

not feeling

good have a very difficult

time participating fully in classroom

activities.

We know that low-income children are affected

disproportionately by environmental pollution.

Besides the need to improve

our air quality,

we need to address

the effects of climate

change.

This may be the most important

thing that
our generation

can do on behalf

of future

generations,

including

the children of the Atlanta

Public

Schools.

The many

effects

of rising temperatures have been documented

by scientists.

Families

who already experience

food insecurity

may suffer

more as crop yields drop in the Southeastern

United

States

(A study by William

Clinepredicts an 18 percent

decrease

in crop yields

by 2100)

and food prices rise accordingly.

Warmer

temperatures

could adversely

affect children's health

by increasing

smog levels,

the spread

of certain diseases, and the level of harmful

chemicals

in groundwater.

Water,

our most precious

natural

resource,

may be at a premium

in a world of uncontrolled

climate

change.

According

to the Natural

Resources Defense Council,

87% of counties

in Georgia

face the risk of water shortages due to climate

change.

What will our children

and grandchildren

think about

us if we ignore scientific evidence

concerning

climate

change

and pollution?

What will they say about

us if we negligently

and recklessly

change

their environment in drastic

ways for the worse? Addressing climate

change

is our obligation

to our children

and future generations, and the EPA can take the largest

step our country

has
ever taken

in that effort

by limiting

carbon

pollution

from power plants.CEA Southeast

Statement

EPA Public Listening

Session

Atlanta My name is Adam Waldeck,

and serve as the Executive

Director

of the Southeastern

chapter of Consumer

Energy Alliance

(CEA), covering

Georgia,

North and South Carolina,

Tennessee and Virginia.

CEA is a nationwide

trade association

made up of both energy consumers

and producers working

to advance

an all-of-the-above

energy policy that will lower energy costs for every American.Historically, the Southeast

has had the most affordable

and reliable power in the country,

which has served as a magnet for jobs and economic

development.

This is of particular

importance

for middle and lower-income

Americans,

because

every dollar spent on energy is a dollar not being put towards

savings,

groceries,

or next year's family vacation. At a time when electricity

consumption

is projected

to grow, it is important

that all available energy resources

remain available

to help avoid supply disruptions

or unnecessary

price increases. With America's

energy technology

and diversity

of resources,

we are now in a time of energy abundance,

meaning

downward

pressure

on prices, new job creation

in industries

that rely on safe, affordable

energy, and the hope of long-term

economic

growth. These new rules are designed

to require coal-fired

power plants to significantly

reduce their carbon emissions,

raising concerns

that directly impact those energy prices, new jobs and overall economic

well-being.

Under the best case scenario,

the regulations

could mean that facilities will face the difficult choice to either upgrade

or shut down. If the regulations

are set a level that is unachievable,

upgrading

will not be an option. Both options mean higher electricity prices for consumers

in Georgia

and the broader

Southeast. To understand

the real-life ramifications

of power facilities

closing quickly or unexpectedly,

one needs only to look to the West. When the San On.ofre nuclear facility in southern

California retired prematurely,

electricity

prices rose 59% and California

regulators

were left scrambling

to bring online additional

sources

of electricity

to avert rolling brownouts. As EPA considers

how to move forward with regulations

governing

GHG emissions

from existing units, we urge the Agency to keep electricity

consumers

in mind and not set the standards in a manner

that will force the premature

shutdown

of coal-fired

units which will drive up electricity

costs and reduce grid reliability.

We also believe that EPA ought to give the states maximum

flexibility

to develop

and implement

plans that fit their unique circumstances. Such flexibility

is particularly

critical to states including

Georgia

where coal-fired

power accounts for a significant

percentage

of electricity

generation. If these regulations

hamper

our ability to utilize American

coal, we must also consider how electric utilities will fill the gap and provide affordable,

reliable power utilizing non-coal feedstocks, such as natural gas, nuclear,

wind and solar all of which face their own unique challenges.This debate should not just be about "clean energy"

versus "dirty energy,"

but about affordable, reliable energy versus unreliable

and expensive

energy.

As a nation, we should strive to have more energy, not presenting

false choices

that pit one energy resource

against another.

CEA hopes EPA considers

deeply the potential

economic

impacts

on consumers

across Georgia

and the broader

region.Riddell,

Dorothy/
From:Sent:To:Subject:

Kate McGregor

Mosley [kate@gipl.org] Wednesday, October 23, 2013 12:04 PM Riddell, Dorothy; Group A-AND-R-DOCKET Docket ID: EPA-HQ-OAR-2013-0495

To Whom It May Concern:
I wish to comment

on the EPA's proposed

new regulations

to reduce carbon emissions

from power plants. I am a Presbyterian

minister

in Atlanta and work closely with congregations

across the state of Georgia

to become energy efficient

as a witness to their faith. I am part of Georgia

Interfaith

Power & Light, a faith-based environmental organization

that encourages

faith communities

to embrace

sustainability

as part of their congregation's programs

and ministries.

GIPL has helped to cut 10 million pounds of CO2 emissions

as our partner congregations

have cut their energy usage in significant

ways. In the process we have raised awareness among people of faith here in Georgia

about our call to action to care for the environment

and support efforts of the EPA, such as the proposed

new regulations

for power plants.
I am very concerned

about the significant

impact carbon pollution

has on our quality of life how it contributes to rising rates of asthma and asthma-related

illnesses

among children

and the elderly especially.

I am greatly troubled by how this pollution

is impacting

changes

in climate and weather,

contributing

to more erratic weather patterns

and affecting

entire eco-systems.

The regulations

being proposed

by the EPA are an essential part of our overall response

to climate change as a country.

We need the EPA to enforce these standards

across state lines so that together

we can curb this pervasive

problem

of carbon pollution

that comes from our region's power plants.Until more renewable

sources of energy are generated

for public use, more aggressive

regulation

is needed so that our impact on the environment

is reduced.

We need enforceable

carbon reduction

standards

so that we can make real progress

towards

stemming

the tide of climate change for the sake of our health and generations

to
come. We can also be a beacon of hope for the world and show that the U.S is serious about reducing

our carbon pollution

by committing

real resources

to this issue, and no longer just talking about it. We have a moral obligation to act as a nation on this issue and strengthening

the regulation

of power-generation

is a good start.
As you continue

to determine

a way forward,

know that GIPL is working

on the ground to help individual churches, synagogues,

temples,

religious

schools and prayer centers across Georgia

to reduce their energy consumption and ultimately

lessen their carbon footprint.

Thank you for your time and consideration

of my comments.

In peace,Rev. Kate McGregor

Mosley Director of Congregational

Support Georgia Interfaith

Power

& Light
o. 404-377-5552PUBLIC COMMENTS

REGARDING

THE ENVIRONMENTAL PROTECTION

AGENCY'S GREENHOUSE GAS EMISSIONS ATLANTA, GEORGIAOctober 23, 2013
Good afternoon.

My name is Seandra

Rawls Pope and I am the Diversity

and Community Partnerships

Manager

for the Southern

Alliance

for Clean Energy, based here in Atlanta, GA. We are a regional

organization,

representing

citizens across the heavily coal dependent states of the Southeast.

We welcome

and support EPA,s decision

to move forward with designing

strong Carbon Pollution

Standards

for greenhouse

gases (GHG) to protect our climate and to develop new cuRing-edge

energy generation

technologies

that will allow the retirement of older, inefficient,

dirty coal units. These carbon regulations,

for both new sources and existing

sources,

are also an important

step towards

increased

protection

of low-income communities and communities

of color who not only currently

suffer from the negative

effects of coal-fired generation

but who will be disproportionately

affected by the negative

impacts of climate change.Nationwide,

existing coal-fired

power plants account for 30% of our nation's greenhouse gas emissions.

Here in the Southeast,

we have over 180 units at 58 coal plants from Kentucky to Mississippi

1, and while the average age of most U.S. coal plants is 40, the average age of plants in the SE is 47 years old. Many of these facilities

live far beyond their original intended lifespan

and tend to be inefficient,

emitting

even more GHGs than their equivalent

newer counterparts.

Southeast

coal plants emitted over 374 million tons 2 of CO2 in 2011. EPA regulations to control carbon emissions

from existing plants will push utilities to develop .and

NC, SC, FL, AL, GA, MS, KY (TVA plants only) and TN 374,092, 092 tonsimplement technologies

that will significantly

lower GHG emissions

and to develop more carbon neutral forms of electricity

generation,

such as solar or wind generated

power.

Not only are the Southeast's

old, dirty coal plants disproportionately

contributing

to the carbon load in the atmosphere

about 80 percent of all US counties

that experience

persistent poverty lie in the Southeast.

This pervasive

poverty makes our region's

.communities

some of the nation's

most vulnerable

to climate change impacts.

Additionally,

16 million people in the Southeast make their home along more than 2,000 miles of low-lying

coastline,

making them particularly susceptible

to sea level rise, stronger

storms, drought,

salt water intrusion,

and loss of ecosystems

and coastal community

resources.

Our coastline

is one of the nation's most valuable features,

with 2.2 trillion dollars worth of property

located along it. Our coastline

is home to important

cultural,

historic and economic

resources,

such as our shipping

ports, as well

as some of our prized national

infrastructure

such as our nation's

space exploration

facilities. Carbon pollution

is also directly linked to other life-threatening

pollution

fromcoalfired power plants like mercury,

soot and smog, which cause illnesses

such as asthma and developmental problems

in children.

As our urban cities.warm

with rising global temperatures,

ozone smog and corresponding

asthma attacks will occur more frequently.

Minoriti6s

and economically disadvantaged

communities

are more likely to live closer to more polluted, industrial areas and are disproportionately

impacted

by these toxic air pollutants.

Regulating carbon pollution

under Section 11 l(d) of the Clean Air Act offers a critical new juncture

in protecting human health from theeffects

of coal-fired

power plant pollution,

particularly

.lowincome and minority

communities'

health.We urge EPA to hold the utility induslzy

accountable

for the negative

impacts of their operations. Strict regulations

to reduce carbon pollution

will likely lead to the retirement

of older, inefficient,

dirty coal units and will force development

of new, efficient,

and clean technologies that will help the nation improve

not only its public health but also its economic health. We do caution the EPA to fully investigate

new carbon reduction

technologies,

such as carbon capture and sequestration

and biomass,

to ensure life-cycle

carbon neutrality

and a marked reduction

in emissions.

I would like to thank EPA for the.opportunity

to provide input on this important

issue. We will continue

to support EPA in moving forward with regulating

carbon pollution

under the Clean Air Act and proactively

addressing

our generation's

most significant

threat- climate change. Thank you.SOUTH CAROLINA

PUBLIC

SERVICE

AUTHORITY (SANTEE COOPER) STATEMENT FOR EPA LISTENING

SESSION CARBON POLLUTION

STANDARDS

-EXISTING

UNITS OCTOBER 23, 2013 My name is Jay Hudson

and I lead Santee Cooper's

Environmental

Management department. Santee Cooper

is South Carolina's

state-owned

electric

and water utility and the state's largest power producer.

Approximately

2 million

South Carolinians receive their power directly

or indirectly

from Santee Cooper.

Santee Cooper

owns and operates fossil-fueled

electric

utility generating

units that will be directly

affected

by EPA's CO2 rulemaking.

Over the last 8 years, Santee Cooper

has been at the forefront

of emissions-free energy development

in South Carolina.

Santee Cooper

has developed

a diverse portfolio of renewable

energy,

offers a demand-side

management

program,

and is jointly constructing

two new nuclear

units. These new nuclear

units were noted by President Obama

in his June 25, 2013, remarks

on Climate

Change.

Santee Cooper

does not support

the regulation

of CO2 and other greenhouse gases under the current

provisions

of the Clean Air Act. The Act is poorly designed

to regulate greenhouse

gases and any effort for EPA to do so could potentially

damage

the American economy.
However, since the President

has directed

EPA to move forward

with CO2 regulations for power plants, we are offering

the following

general

principles

that should guide the development

of the EPA regulations.First, EPA should respect

the primacy

of the states. The Act provides

each state with wide latitude

to develop

performance

standards

that fit the needs and circumstances of the state. EPA's role is limited

to developing

"a procedure"

for states to follow in setting these standards.
Second, EPA's regulations

should do no harm to the U.S. economy.

Climate change is a global issue that requires

a global solution.

Because

reducing

CO2 emissions from the existing

coal fleet will alone have minimal

climate

change benefits.

EPA should factor in its rulemaking

that CO2 emissions

from the American

electric power sector have already

been reduced

to 16% below 2005 levels and there is more to come without CO2 regulations.

Santee Cooper

is already

11% below our 2005 CO2 emissions. Third, EPA should avoid the waste of stranded

investments

that could result from the premature

shutdown

of the existing

fleet of power plants.

Current

surveys indicate that electric

utilities

have publically

announced

the retirement

of just over 50 GW of existing

coal generation

and my company,

Santee Cooper,

retired 552 MW of coal generation

in the last year. Regarding

the remaining

coal generation,

industry

is

now investing

over $100 billion to comply

with MATS and other new EPA rules. These capital investments

are in addition

to the $110 billion that has been invested

in pollution control equipment

over the last 40 years. Fourth, the CO2 performance

standards

should be based only on those technologies and control

measures

that are financially

viable, have been adequately demonstrated and can be applied

or implemented

within the "fence-line"

of the affected power plants.

2And fifth, EPA should provide

maximum

flexibility

for state implementation

of the CO2 compliance mechanisms

to be imposed

under the new EPA mlemaking.

EPA, for example, should allow states to provide

affected

utilities,

like Santee Cooper,

with credit for the CO2 reductions

resulting

from power plant shutdowns,

renewable development, nuclear

generation

and energy efficiency

programs.

Contact Information:Jay Hudson,

P.E.Manager, Environmental

Management Santee CooperOne Riverwood

Drive Moncks Comer,

South Carolina

29461 (843) 761-8000jay.hudson@santeecooper.comSTATEMENT OF ELIZABETH

POYTHRESS,

President,

League

of Women

Voters

of Georgia TO the EPA LISTENING

SESSION,

October

23, 2013, Atlanta,

Georgia

Thank you for this opportunity

to speak on the Carbon

Pollution

Standard

for Existing Power Plants.

It is the position

of the League

of Women

Voters

of Georgia,

that we, as responsible Americans,

owe a profound

moral obligation

to our children

and to future generations

to act now to protect

them from the effects

of climate

change, which we know is caused

in part by carbon

pollution

from power plants.

We have

a moral obligation

to protect

our children

and future generations.

am here today to ask the EPA to provide

our population

with protection

by adopting standards for the 40% of carbon

pollution

from existing

power plants.

These emissions cause climate

change

and thousands

of deaths

every year. Recently it was reported

that more than 120 health organizations,

including

the American Medical

Association,

the American

Lung Association,

the American Nurses Association,

the American

Academy

of Pediatrics,

and the American

Public health Association

went on record

stating

that: "Climate change

is a serious

public health issue. As temperatures

rise, more Americans will be exposed

to conditions

that can result in illness and death due to respiratory illness,

heat- and weather-related

stress and disease

carried

by insects. These health issues are likely to have the greatest

impact

on our most vulnerable communities,

including

children,

older adults,

those with serious health conditions

and the most economically

disadvantaged." (New Jersey Star Ledger 5/15/12)And the American

Lung Association,

in its State of the Air Report,

states that millions of Americans,

including

children

and the elderly,

live in areas that receive
an "F" rating for at least one air quality

measure.

In Georgia,

the four major metropolitan counties,

Fulton,

Cobb, DeKalb

and Gwinnett,

have over 800, 000children that are in these "F" rated areas. This is unacceptable

and must be changed.Today we protect

public health with limits on arsenic,

lead, mercury,

soot and other pollutants

from power plants,

but there are no public health safeguards against carbon

pollution.

The EPA can and must supply those safeguards.
On behalf of the children,

and unborn

generations

of children,

the League

of Women Voters

of Georgia

urges the EPA to adopt strong carbon

pollution standards for existing

power plants,

to address

one of the main causes

of climate change and to protect

the health of all Americans

from its devastating

impact. Thank you, again, for providing

the opportunity

for this public hearing

to allow the public to express

their comments

on this vital public health issue.

###AMERIGa, N COALITION

FOR CLEAN COAL ELECTRICITY

EPA Listening

Sessions
Good morning/afternoon, my name

is Randy

Eminge!•

! am the South Region VP for the American

Coalition

for Clean Coal Electricity.

Thank you for the opportunity

to speak

today:abo•t

'•EPA's

plan to regulate carbon

dioxide

emissions

from co.!

p•er

plants.

ACCCE is concerned

about re•lations

because

of their impact on the use of coal to pro

:affordable

and reliable

electricity. Coal plays a crucial

role in p•oviding•Ie•}ricity to consumers

in virtually every state in the m coal provides

more than one quarter of the electricit

in 2• •ta}:•s with a collective

population

of more than 175 million UnfOrtunately,

EPA regulations

have already contributed to the et.0-•ur•-of

300 existing

coal units in 33 states.

And recently roposed

regulations

would

ban new, efficient

state-of-art

coal plants.

To begin

with, we disagree

with EPA's

decision

to regulate

greenhouse gas emissions

under

the Clean Air Act. EPA regulations

are an ineffective and economically

harmful

way to address

climate

change.

But, since EPA is developing

these

regulations

anyway,

I want

to offer ACCCE's perspective.

EPA is focused

on reducing

carbon

dioxide

emissions

from coal-fired power plants

as a way to address

global

climate

change.

However,carbon dioxide

emissions

from the U.S. coal fleet represent

only 3 percent of global

greenhouse

gas emissions.

Reducing

carbon

dioxide

emissions from the U.S. coal fleet will increase

energy

prices

without

having

any meaningful effect

on global

climate

change.

Further,

the U.S. electric sector has already

reduced

its carbon

dioxide

emissions

more than any other sector

of the economy.

U.S. power

plants

have reduced

carbon dioxide emissions

by 16 percent

below

2005 levels,

and carbon

dioxide emissions from coal-fired

power

plants

have declined

by almost

24 percent.

With that in mind,

we believe

EPA should

fo••e•principles in developing carbon

regulations: First, EPA s carbon

regulations

mus•t•

c'•u•l•

retirement

of any coal plants, under

any circumstances•vor of natural

gas or renewable electricity generation. Second, electricity

improves••of life. Requiring

less electricity

use is a form of energy••ng•tI•will hurt people,

reduce

life expectancy, and reduce

overal•f living. Third, EPA•'••

'•""'regulations

should

do no harm.

Carbon

regulations should no•re

with affordable

electricity

prices

and reliable electricity "•sup•s,

especially

in states that rely on coal. Fourth, EPA's

carbon

regulations

should

provide

states

with all the flexibility they need in order

to develop

plans

that suit their unique circumstances, including

continuing

their reliance

on coal if they choose that approach.

Also, EPA must give states

ample

time to develop

and implement their plans.Fifth, coal plant

owners

are expected

to invest

over $30 billion

in the near-term to further

reduce

emissions

of conventional

air pollutants.

EPA must ensure

that carbon

regulations

do not cause

additional

premature closures of coal units and, therefore,

stranded

investments

in emission controls.Finally, EPA

should

remove

regulatory

barriers

to efficiency improvements at existing

coal-fueled

power

plants.

Efficiency improvements are a cost-effective

way to reduc•lsslons, while maintaining affordable

and reliable

operations••A•ld remove barriers to these projects. •

•
Thank you for your attention. •GEORGIA COAL-FIRED POWER

PLANT

FACTS Generation1. Roughly

96 percent of in-state power generation

in 2012 was from natural gas (34.9%),

coalfired (33.4%)

and nuclear

(27.7%)

power plants.

Remaining

Georgia

power generation

was from biomass

(2.7%) and hydroelectric

(1.2%).

As illustrated

below, natural

gas fired generation market share has increased

significantly

since 2005. Georgia Net Generation

by Fuel Source 2012

(Other)

• Coa•NuclearNatura• GasHydro

• Renewable

•:• Other 27.7% 33.4%

Note: "Other" includes petcoke, pet liquids, othergas, and pumped storage 2005 23.6% .6%2.5%

(Other)

65.6% According to the US Department

of Energy,

Georgia

utility rates averaged

9.25C/kWh=

in 2012, 6.3 percent

lower than the national

average

power rate of 9.87C/kWh.

These utility rates are higher than other southeastern

states except for Florida and Tennessee.

States with traditionally

Source: Electric Power Monthly- Feb 2013 (US-DOE) Source: Electric Power Monthly- Feb 2013 (US-DOE)much higher coal market generation

shares consistently

rank among the states with the lowest average retail power prices (WV- 95.9%-

8.13c/kWh,

KY- 93.5%- 7.20c/kWh,

WY-87.6%- 7.19c/kWh, IN- 81.9%- 8.23c/kWh)Comparison of Gc.0rgia'

s 2_0!2 Elect•_icity

Rates.

12.0010.00 Average

2012

Retail

Power

Rates (All sectors)

GA AL FL SC MS NC VA TN US Avg Historically, coal played a large role in state power generation

because

of its low competitive delivered costs. However,

with shale gas fracking

technology

improvements,

natural gas prices have decreased

and now are comparable

to delivered

coal prices in Georgia.

With its diversified generation

mix, the utilities are well position

to handle future fuel market changes, including anticipated

rises in natural gas prices.2.012_•o..•gi_a.Average Delivered

Fuel Price for Power Production- 2012 sso.oo$25.00 $24.22

• $10.00

Coal Gas Oil
Emissions Reductions4. The Clean Air Act has been successful

in improving

state ambient

air quality.

Georgia

is in attainment with the national

ambient

air quality

standards

for 5 criteria

pollutants-

carbon monoxide, lead, nitrogen

dioxide,

large particulate

matter and sulfur dioxide.

It remains

out of