### Comments in support ofthe EPA's Clean Power Plan Docket No. EPA-HQ-OAR-2013-0602 EPA-HQ-OAR-2013-0630 I wanted to startby thanking the EPA for allowing the public the opportunity to comment and testify on such a vitally important issue. My name is Logan Hollers- I'm an environmental attorney that lives in beautifulWashington,DC, and I'mcommenting on behalfofthe DC

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### Chapter ofthe Sierra Club. As I'msure this agency is aware, the United States 1s rapidly running out oftime to address climate change and, more specifically, to address the problem of greenhouse gas emissions from existing fossil fuel power plants. We need a solution that ensures the power generation our country needs and

### purges us ofthe unnecessary pollution and toxins
our country most certainly does not need
.The EPA's proposed Clean Power Plan is about achieving precisely that balance. I wanted to take abriefmoment to address a few key points. Regardless ofwhat some on the right would have us believe, there is no longer a "debate" over the role ofcarbon emissions in climate change. It's now anear-universally accepted scientific fact that, in the words of NASA, "increased atmospheric C02concentration is the most important long-lived 'forcing' of climate change." In its recentlyreleased Fourth Assessment Report, the Intergovernmental Panel on Climate Change, a group of 1,300independent scientific experts from countries across the world, concluded there's a more than 90% probability that human-produced greenhouse gases, the principle ofwhich is carbon dioxide, are responsible for much ofthe observed increase in the I 

### planet's temperature over the past 50 years. This carbon pollution exacerbates climate disruption I I 

### and contributes to more frequent and more violent extreme weather that costs local communities, the federal government, and our economybillions per year. Finally, carbon pollution is also a
1significant threat to public health. According to the American Lung Association, nearly halfof all Americans live in areas where the air is unsafe to breathe. In light ofall this information about the negative externalities and destructive power of carbon emissions pollution, the single most important fact remains that powerplants account for 40% ofall carbon pollution in the United States. Clearly, the nation is in desperate need ofa common-sense, environmentally sound solution. And that's exactly what the EPA'sproposed Clean Power Plan is. Thebestpart ofthe Clean Power Plan is that it achieves multiple goals from a holistic perspective. First and foremost, the Plan will drastically reduce one ofthe mostpressing threats to humanity: carbon pollution from powerplants fueling climate change. Second, the Plan will have far-reaching and concrete impacts on public healthbypreventing up to 150,000 asthma attacks and 6,600 premature deaths annuallyby2030 and bycombating and reducing the over 12,000visits to the emergencyroom and more than $100billionin health costs per year resulting from coal pollution. Third, the Plan will drive innovation in developing and building clean energy sources that will power the 21st century, growing the nation's economy and creatingjobs

- two goals that transcend sides ofthe political aisle. Finally, the Plan will lead to public benefits in terms of health and climate estimated at over $60billionperyear in 2030, far outweighing the costs of implementing the Plan. Those costs associated with implementing the Clean PowerPlan are likely to provoke 

### I I passionate discussionin the coming months. However, numerous independent studies have I I reached the conclusion that: "[l]mpacts on electricityrates ... will be modest
... and canbe accompaniedbylong-termbenefits."

2The Clean Power Planrecognizes that every state is different. While certainlyrequiring significantreductions in C02 emissions, the Clean Power Plan is unique in allowing each state the flexibility to determine its preferred method ofcomplying with the new requirements. And that flexibility is key- it ensures that states will be able to prepare and implement State Plans that fit their circumstances, minimizing the cost ofcompliance. In the end, the states are in control. Thankfully, states have a long and demonstrated track record ofusing various regulatory tools (whether those are tax, reliability, labor, or environmental in nature) to encourage utilities and investments that minimize the cost ofelectric service. The Clean PowerPlan is long overdue and vitally important, and must be implemented nationwide and without further delay. This administration, with its promises of"strong action"
on climate change, has a moral obligation to address climate change. This agency, with its stated mission to "protect human health and the environment," has a moral obligation to address climate change. The Clean PowerPlan both will allow states the flexibility they need to develop customizableplans to keep American energy affordable, reliable, and sustainable, and will
ensure everyperson has clean air to breathe. I applaud and support the agency's intent to establish strong national limits on carbon pollution from existing coal-firedpowerplants, and I thank you for your leadership and action on this important issue.
Respectfully submitted, Logan L. Hollers, J.D., LL.M. logan.hollers@gmail.com

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