May 24, 2012 NewSource 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 representthe Northern Virginia Climate Action Network, a coalition of 10 non-profitgroups based here in Northern Virginia with atotal membership ofover25,000 Northern Virginians. Each ofthe groups has a different mission, butwe have united out ofasense of urgencyto reduce green house gases and reduce the consequences of climate change.

We are delighted that EPA has proposed this NewSource Performance Standard. It takes an importantfirst step toward reducing green house gases, while atthe same time protectingthe power industryfrom undue hardship.
By beginningthe process of reducing emissions from electric utilitygenerating units, EPA is reducing the impacts and risks articulated in the Endangerment Finding. I'll mention two impactsthat directly affect public health: higheraverage temperatures and more heatwaves, which are associated with increased death and illness. Heat is alreadythe leading cause ofweather-related deaths in the US. Increased temperatures react with nitrous oxide and volatile organic compoundsto raise ozone levels, which have been linked to asthma and premature death. Asthma levels aretoo high now and will increase as temperatures increase. Children are especially vulnerable because their lungs are developing. A pediatrician friend of mine reports atelling statistic- at Inova Fairfax, where she works, 285 children were admitted for severe asthma attacks in 2010 and 237 children in 2011.

This standard is notexpected to result in any disruption to our power supply. It merely reflects the ongoingtrend started by utilitiesthemselves 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 impactsthat may result from meetingthe new standard. This process ensures thatthe 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 motherof innovation, and the catalytic converterwas born. A whole
new industry ofair pollution control equipmentwas 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 peryear, 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 millionjobs. This standard will encourage research into moreAmerican pollution control technology, such as 

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So yes, we applaud EPA fortakingthis first limited step to protect our public health and encouragethe current trend towards cleanergeneration. It is high timeforthis standard to be adopted, and we look forward to seeing limits on carbon dioxidefrom existing EGUs and other high emitters.