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E PA-HQ-OAR-2013-0602 

COMMENTS OF THE UTAH PHYSICIANS FOR A HEALTHY 

ENVIRONMENT ON THE EPA'S PROPOSED CLEAN POWER 

PROGRAM 

(July 30, 2014) 

Utah Physicians for a Healthy Environment is a group of nearly 300 

professionals in medical and related sciences. My name is Malin Moench. 

I advise the group on matters of law and economics. 

Many of the illnesses that our physicians treat are either caused by or 

made worse by air pollution. We recognize that air pollution and climate 

change are intimately related. We therefore offer our expertise to inform 

the debate about how society should deal with these hazards to human 

health. 

Our comments summarize recently published scientific reports on the 

causes and consequences of climate change. They focus on the impacts 

predicted for the Mountain West and the Great Basin, and the unique public 

health risks that climate change—driven by the rapid buildup of greenhouse 

gases in the atmosphere—poses to the people of Utah. 

This spring, the Intergovernmental Panel on Climate Change (IPCC) 

released its Fifth Assessment Report and a group of Federal agencies 

released their National Climate Assessment. In 2011, the Bureau of 

Reclamation issued its climate report required by the Secure Water Act. 

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These reports evaluate the causes and the likely impacts of climate change 

at, respectively, the global, the national, and the regional level. 

Each is a landmark, multi-year study that synthesizes the research of 

hundreds of the world's leading geophysical scientists. They all reach the 

same conclusion—the massive buildup of carbon in the atmosphere is 

unsustainable. It is destroying the health of the world's natural systems 

and the health of its human populations that depend of those systems. If 

not mitigated, global warming will result in pathologies, both human and 

ecological, whose costs will far exceed the amount saved by relying on 

dirty rather than clean sources of energy. (See pages 2-13 of our written 

comments). 

Globally, the costs of climate warming take the form of heat, drought, 

floods, super storms, crop failure, and the encroachment of the sea on 

coastal cities. For the Mountain West, and for Utah, in particular, the costs 

of climate warming take the form of dwindling snowpack, shrinking rivers, 

extended summer drought, dust storms, dying forests, and a massive 

increase in forest and range fires and their associated pollution. (See 

pages 28-41 of our written comments). 

These reports identify the maximum amount of further warming of 

the climate that can be regarded as sustainable as 2° Centigrade (3.6° 

Fahrenheit). They observe that to keep further warming within this limit, 

society would have to limit the total amount of carbon burned since the 

industrial revolution began to 800 billion tons, leaving the other 4,200 billion 

tons of fossil carbon reserves in the ground. 

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Mankind has already spent two-thirds of its 800-billion-ton "carbon 

budget." Only one third remains to be burned before climate damage to the 

earth's natural system and the human economy becomes irreversible. At 

current burn rates of 10 billion tons per year, society will spend what 

remains of its carbon budget in less than 30 years. 

These reports note that if society fails to adopt major new carbon 

reduction programs, global warming will exceed 4° Celsius (7.2° 

Fahrenheit) by the year 2100. This is more than double the 2° C cap on 

manageable warming. It will cause so much damage to the world's natural 

systems that society will be unable to adapt to the extreme environment 

that will result. (See pages 4-13 of our written comments). 

Our members are primarily concerned with the damage that local 

climate warming will cause to Utah's natural systems, and, therefore, the 

health of its people which depends on the integrity of those systems. 

Climate change is expected to accelerate the heating and 

desertification of Utah's environment. For example, forest fires are 

expected to expand five-fold by 2100, greatly increasing the exposure of 

Utah's residents to the toxic particulate pollution that such fires generate. 

(See pages 38-43, 63-66 of our written comments). 

Increased heat, drought, and fire caused by climate warming are 

expected to strip the rangelands of the Great Basin of much of their 

vegetation. (See pages 28-36 of our written comments). This effect will be 

magnified if the Southern Nevada Water Authority proceeds with its plans 

to drain the aquifers of the already-parched lands of central Nevada and 

western Utah to supply additional water to Las Vegas. If climate change is 

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unabated, and these acquifers are drained, passing cold fronts could 

release millions of tons of unanchored desert soils to coat Utah's heavily 

populated Wasatch Front. (See pages 65-74 of our written comments). 

Great Basin soils are contaminated with unusually dangerous toxins. 

These include a fibrous material called erionite that is hundreds of times 

more toxic than asbestos, radioactive waste from decades of nuclear 

testing, and mercury from gold mining. Increased heat, drought, and fire 

associated with climate warming is expected to remove much of the 

vegetation that now holds those soils in place. By mid-Century, increased 

exposure to ozone, smoke, dust, and airborne toxins due to local climate 

warming is expected to substantially increase rates of respiratory and 

cardio-vascular disease, cancer, genetic damage, and premature death. It 

is estimated that by mid-Century, 40% of Utahns will be too young, too old, 

or too sick to withstand the effects of the increased air pollution to which 

they will be exposed. (See pages 41-73 of our written comments). 

The value of the earth's natural systems include clean air to breathe, 

clean water to drink, oceans that can support fish, fertile soil to support 

crops, herds, and trees, and a temperate climate. We take these services 

for granted because they are free, but most of them could not be replaced 

at any price. 

The services provided to humanity by the earth's natural systems 

have been calculated to be worth at least $47 trillion annually, and to have 

a capitalized book value well above $500 trillion. A wealth of recent major 

climate studies make it clear. Policy makers who choose to nominally save 

two or three pennies per kilowatt hour by clinging to coal are, by that 

choice, are putting the health of all of the earth's natural systems (and the 

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hundreds of trillions of dollars of value that they represent) in grave peril. 

When the earth's natural systems are in grave peril, the health of its 

inhabitants are put in grave peril as well. (See pages 41-43 of our written 

comments). 

It is time for policy makers to recognize that we are at a crossroads. 

The health of the earth's natural systems, and the health of the public that 

depends on those systems, can no longer be taken for granted. 

Unrestrained carbon emissions are putting the health of the public at risk. 

If the public's health is to be protected, those who make energy policy must 

make decisions that fully reflect the benefits to society of shifting to carbonfree electric power. 

Some argue that the world must continue to rely on burning fossil 

fuels to meet its energy needs on economic grounds. Yet it is economics 

that argues most forcefully for a shift to low-carbon sources of energy. 

Mining coal often destroys watersheds. Strip-mining it permanently 

sterilizes the land. Burning it impairs human health by polluting the air, 

warming the climate, and leaving toxic coal ash to pollute surface and 

ground water. These are some of the indirect, or "social" costs of relying 

on coal to power the country. Those who sell and burn coal do not pay 

these costs—they are borne by society as a whole. 

A recent Harvard study estimated that the social cost of burning coal 

in the United States each year at between one-third and one-half trillion 

dollars. If these costs were included in the price of coal, the price would 

double or triple. The price of coal-generated electricity would increase by 

from 9 to 27 cents per kilowatt hour. Since the average price of electricity 

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is about 11 cents per kilowatt hour, fully accounting for the costs of coalgenerated power would double or triple its price per kilowatt hour relative to 

the price of carbon-free sources of power, such as wind or solar PV. 

By 2020, the cost of carbon-based power will rise substantially above 

its current level of 11 cents per kilowatt hour while the cost of solar is 

expected to fall to 8.8 cents. The cost of wind is on a similar path. By 2020, 

practical storage technologies for distributed power are expected to be 

widely available. By then, solar and wind will not need subsidies, and their 

competitive advantage will only grow thereafter. 

For nearly 100 years, the business model for public utilities has been 

to make its investments in centralized carbon-burning plants as large as 

possible in order to get those investments rolled into the rate base and 

have state regulators approve generous returns on those investments 

almost without effort, and almost forever. But, given technological trends 

and pending EPA carbon restrictions, the old business model is heading for 

a train wreck. As the cost of centralized, dirty power rises, and the market 

for it contracts, utilities will have to raise rates to cover the fixed costs of 

obsolete plants. I was at the recent NARUC convention where state public 

service commissions were in a panic contemplating the implications of this 

downward spiral. 

Our recent participation in state-level electric utility rate proceedings 

has made us realize that states are unlikely to meet EPA's carbon 

reduction targets unless the incentive structure of the industry is reformed 

at the state level. Utilities will have to be allowed higher rates of return on 

their investments in distributed carbon-free power than on their investments 

in black power. They might also need to collect a bounty on each 

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distributed green system that they connect to the grid, or be allowed to 

keep a percentage of the savings for each kilowatt hour that is avoided by 

their end-user efFiciency programs. Such incentive reforms are essential if 

electric utilities are to willingly participate in, rather than fight the EPA's 

proposed Clean Power Program. 

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