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 true 

environmental benefits to burning trash. The EPA made compromises with the wasteburning industry to only count one third of the significant carbon emissions from WTE 

facilities 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 

standardsintended 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,"1but 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/energyefficiency/building code committee finally publishes 

critical council testimon