May 24, 2012 

New Source Performance Standard for New Power Plants 

Testimony of Linda Burchfiel 

Northern Virginia Climate Action Network 

1605 Maddux Lane, Mclean, VA 22101 

Good morning. My name is Linda Burchfiel and I represent the Northern Virginia Climate Action Network, a 

coalition of 10 non-profit groups based here in Northern Virginia with a total membership of over 25,000 Northern 

Virginians. Each of the groups has a different mission, but we have united out of a sense of urgency to reduce 

green house gases and reduce the consequences of climate change. 

We are delighted that EPA has proposed this New Source Performance Standard. It takes an important first step 

toward reducing green house gases, while at the same time protecting the power industry from undue hardship. 

By beginning the process of reducing emissions from electric utility generating units, EPA is reducing the impacts 

and risks articulated in the Endangerment Finding. I'll mention two impacts that directly affect public health: 

higher average temperatures and more heat waves, which are associated with increased death and illness. Heat is 

already the leading cause of weather-related deaths in the US. Increased temperatures react with nitrous oxide 

and volatile organic compounds to raise ozone levels, which have been linked to asthma and premature death. 

Asthma levels are too high now and will increase as temperatures increase. Children are especially vulnerable 

because their lungs are developing. A pediatrician friend of mine reports a telling statistic- at I nova Fairfax, 

where she works, 285 children were admitted for severe asthma attacks in 2010 and 237 children in 2011. 

This standard is not expected to result in any disruption to our power supply. It merely reflects the ongoing trend 

started by utilities themselves when they chose to fuel with natural gas for economic reasons. And for fossil fuel 

EGUs that are being proposed, technologies are available that have been adequately demonstrated. In proposing 

the standard, EPA has considered both the energy and economic impacts that may result from meeting the new 

standard. This process ensures that the new standard will not be an undue hardship on our economy. 

Instead, this standard will lead to innovation. Look for example at EPA standards for nitrous oxides in auto 

emissions. In that case, regulation was the mother of innovation, and the catalytic converter was born. A whole 

new industry of air pollution control equipment was created. A 2010 study by the Department of Commerce found 

that in here in the US, air pollution control equipment alone generated revenues of $18 billion per year, including 

exports of more than $3 billion. Approximately 119,000 companies are engaged in the environmental technology 

business, which generated approximately $300 billion in revenues, $43.8 billion in exports, and supported close to 

1.7 million jobs. This standard will encourage research into more American pollution control technology, such as 

ccs. 

So yes, we applaud EPA for taking this first limited step to protect our public health and encourage the current 

trend towards cleaner generation. It is high time for this standard to be adopted, and we look forward to seeing 

limits on carbon dioxide from existing EGUs and other high emitters.