Comments in support of the EPA's Clean Power Plan 

Docket No. EPA-HQ-OAR-2013-0602 

EPA-HQ-OAR-2013-0630 

I wanted to start by 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 beautiful Washington, DC, and I'm commenting on behalf of the DC 

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Chapter of the Sierra Club. As I'm sure this agency is aware, the United States 1s rapidly running 

out of time 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 of the 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 a brief moment to address a few key points. Regardless of what some on 

the right would have us believe, there is no longer a "debate" over the role of carbon emissions 

in climate change. It's now a near-universally accepted scientific fact that, in the words of 

NASA, "increased atmospheric C02 concentration is the most important long-lived 'forcing' of 

climate change." 

In its recently released Fourth Assessment Report, the Intergovernmental Panel on 

Climate Change, a group of 1,300 independent scientific experts from countries across the world, 

concluded there's a more than 90% probability that human-produced greenhouse gases, the 

principle of which is carbon dioxide, are responsible for much of the observed increase in the 

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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 economy billions per year. Finally, carbon pollution is also a 

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significant threat to public health. According to the American Lung Association, nearly half of 

all Americans live in areas where the air is unsafe to breathe. 

In light of all this information about the negative externalities and destructive power of 

carbon emissions pollution, the single most important fact remains that power plants account for 

40% of all carbon pollution in the United States. Clearly, the nation is in desperate need of a 

common-sense, environmentally sound solution. 

And that's exactly what the EPA's proposed Clean Power Plan is. The best part of the 

Clean Power Plan is that it achieves multiple goals from a holistic perspective. First and 

foremost, the Plan will drastically reduce one of the most pressing threats to humanity: carbon 

pollution from power plants fueling climate change. Second, the Plan will have far-reaching and 

concrete impacts on public health by preventing up to 150,000 asthma attacks and 6,600 

premature deaths annually by 2030 and by combating and reducing the over 12,000 visits to the 

emergency room and more than $100 billion in 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 creating jobs - two goals that 

transcend sides of the political aisle. Finally, the Plan will lead to public benefits in terms of 

health and climate estimated at over $60 billion per year in 2030, far outweighing the costs of 

implementing the Plan. 

Those costs associated with implementing the Clean Power Plan are likely to provoke 

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passionate discussion in the coming months. However, numerous independent studies have I I 

reached the conclusion that: "[l]mpacts on electricity rates ... will be modest ... and can be 

accompanied by long-term benefits." 

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The Clean Power Plan recognizes that every state is different. While certainly requiring 

significant reductions in C02 emissions, the Clean Power Plan is unique in allowing each state 

the flexibility to determine its preferred method of complying 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 of compliance. In the end, the states are in 

control. Thankfully, states have a long and demonstrated track record of using various regulatory 

tools (whether those are tax, reliability, labor, or environmental in nature) to encourage utilities 

and investments that minimize the cost of electric service. 

The Clean Power Plan 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 Power Plan both will allow states the flexibility they need to develop 

customizable plans to keep American energy affordable, reliable, and sustainable, and will 

ensure every person has clean air to breathe. 

I applaud and support the agency's intent to establish strong national limits on carbon 

pollution from existing coal-fired power plants, 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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