Comments of
Russell Zerbo Advocacy Coordinator
Clean Air Council

Re: EPA's Proposed Carbon Emissions Guidelines for Existing Stationary Sources: Electric Utility Generating Units Docket ID: EPA-HQ-OAR-2013-0602

July 31, 2014
Hello, my name is Russell Zerbo and I am the advocacy coordinator for the Clean Air Council. The Clean Air Council is a Pennsylvania 501(c)(3) dedicated to protecting the right of everyone to breathe clean air. Thank you for the opportunity to speak today.
The Council supports the U.S. Environmental Protection Agency's (EPA) decision to limit carbon dioxide pollution from existing power plants. Pennsylvanians are already suffering the impacts of climate change and are counting on the EPA to implement requirements that will actually reduce greenhouse gas emissions.
Pennsylvania has already showed that it intends to protect existing carbon emitters to the greatest extent possible. The Council is concerned that the plan Pennsylvania submits to the EPA will not reduce greenhouse gas emissions and may in fact create more carbon dioxide emissions. For instance Pennsylvania has already suggested that it plans to take advantage of the EPA's lax waste-to-energy regulations to comply with the carbon rule. I urge the EPA to reject such an approach and in fact reevaluate the way it treats carbon dioxide emissions from Waste-to-Energy (WTE) power plants.
The EPA proudly states on its "Energy Recovery from Waste" webpage that "No new plants have been built in the US since 1995." Contrary to this, the PA Department of Environmental Protection (DEP) has just permitted a waste incinerator in Allentown, PA and in its white paper on how it proposes to meet carbon dioxide limits cites WTE as its chief example of a "project with unique environmental benefits." There are no trueenvironmental benefits to burning trash. The EPA made compromises with the wasteburning industry to only count one third of the significant carbon emissions from WTEfacilities and allowed the Integrated Waste Services Association to provide industrydriven information on the EPA website. Simply put, encouraging waste burning will encourage waste and increase carbon dioxide emissions.
Pennsylvania's white paper also describes coal waste as "essentially carbon neutral" which could not be further from the truth. Of the 18 coal waste burners in the country, 14 are in Pennsylvania. This is a source of carbon significant in Pennsylvania that the EPA must seriously consider in developing its 111 (d) criteria. At its most efficient coal waste emits as much carbon dioxide as a conventional coal power plant and many plants are not operated at top efficiency.

### Chester, PA, the poster community for environmental injustice, is home to a cluster of

emission sources including a waste incinerator and a coal waste plant, opened in 1992 and 1986, respectively. It took the state until May 6 of this year to hold a public hearing where the Environmental Justice Advisory Board heard the views of concerned Chester residents. At the hearing I pointed out that Pennsylvania's alternative energy portfolio standard s intended to promote low emission electricity production credits as clean energy coal waste and trash incineration. It would be hard for the citizens of Chester to understand how the EPA has allowed the state to comply with carbon dioxide limits by ignoring the true carbon emissions from WTE plants.

Pennsylvania does not positively view saving energy. In Pennsylvania, "energy = jobs". Pennsylvania has good options to lower its carbon footprints. Options that would slow climate change, create good jobs and not negatively impact nearby communities. But Pennsylvania refuses to seriously consider such options. For example, the Uniform Construction Code Review and Advisory Council, is tasked with enforcing, "standards for the protection of life, health, property and environment and for the safety and welfare of the consumer, general public and the owners and occupants of buildings and structures," 1

but has refused to update building codes since 2009. By simply generating and consuming less energy with modern construction codes, Pennsylvania could easily comply with a 32% CO2 reduction from a 2005 baseline. From 2005 to 2011 Pennsylvania reduced CO2 emissions by 12%. A comprehensive construction code that lowers PA energy requirement would spur innovation in construction and provide good jobs that value energy consumers. The state does not see the linkage between energy consumption and health. I urge the EPA to require real reductions of energy generation and consumption in its final carbon rule for existing power plants.

http://www.cleanair.org/program/energy/energy efficiency/building code committee finally publishes critical council testimon