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 Sherrill 

1436 Woodland Hills Dr NE 

Atlanta, Ga 30324 

404-633-1928 

sesherrill@pobox.com 
Statement 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 Climate 
Change, 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 a bipartisan 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 Green 

2013 Chair 

Chris Clark 

President and CEO 

www.gachamber.com 

270 Peachtree Street NW, Suite 2200 Atlanta, Georgia 30303-1240 Phone: 404.223.2264 Fax: 404.223.2290 
We 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 

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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 Plants 
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 c<•mpleted, kindly return to the r.egistration desk. 

National Pubfic Listening Sessions on Reducing Carbon Pollution from Existing Power Plants 

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Georgia Chemistry Council Comments 

Environmental Protection Agency Listening Session 

October 23, 2013 

Atlanta, 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 

electricity ,-r•" 

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 for 
jobs 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 240 

Atlanta, GA 30339 

770.421.2991 phone 
EPA Hearing on Regulating Coal Fired Power Plants Green House Gas Emissions 

Sam Nunn Federal Center 

61 Forsytl• St. SW 

Atlanta, GA 

10/23/2013 

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 NE 

Conyers, GA 30012 
Testimony 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 decreased 
lung 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. 

References 

Intergovernmental 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 

Contact 

Anne Mellinger-Birdsong, MD, MpH, FAAP 

934 Artwood Rd NE 

Atlanta, GA 30307 

404-377-2407 

amellbird@yahoo.com 
• AMERICAN•FOR PROSPE 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 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. 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 Galloway 

vgalloway@afphq.org 
EPA 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 32220 

October 7, 2013 

United States Environmental Protection Agency Region 4 

Sam Nunn Atlanta Federal Center 

61 Forsyth St. SW 

Atlanta 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 Frady 
1691 Halsema Road N 

Jacksonville FL 32220 

October 7, 2013 

United States Environmental Protection Agency Region 4 

Sam Nunn Atlanta Federal Center 

61 Forsyth St. SW 

Atlanta 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 Morabito 
TESTIMONEY 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 increased 
global 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 and 
makes 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 by 
The 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 than onetenth 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 an EnergyEfficient 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) 584-6499 
Michael 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 Callum 

1069 Berne Street SE 

Atlanta, GA 30316 

EPA 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 Cline 
predicts 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. 404-377-5552 
PUBLIC COMMENTS REGARDING THE ENVIRONMENTAL PROTECTION AGENCY'S 

GREENHOUSE GAS EMISSIONS 

ATLANTA, GEORGIA 

October 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 tons 
implement 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 from coalfired 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. 

2 
And 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 Cooper 

One Riverwood Drive 

Moncks Comer, South Carolina 29461 

(843) 761-8000 

jay.hudson@santeecooper.com 
STATEMENT 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, 000 
children 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 

Generation 

1. 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• 

Nuclear 

Natura• Gas 

Hydro 

• 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. 

12.00 

10.00 

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 Reductions 

4. 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