under the Prevention of Significant Deterioration Program to

Sources of Greenhouse Gas Emissions: Federal Implementation

Plan

IntroductionI am Dr. Brenda Ekwurzel, a climate scientist and Assistant Director of Climate

Research and Analysis at the Union of Concerned Scientists. Thank you for hearingmy testimony today. On behalf of our members, UCS supports EPA’s efforts to

ensure state permitting programs comply with the administration’s regulations onindustrial sources of greenhouse gas emissions. Such programs would be in line

with the best available science, which indicates the need for urgent actions to

reduce global warming emissions. Unabated, overloading our atmosphere with

heat-trapping gases poses significant risks to human life, health, and well-being.

Clean Air Act 40th Anniversary

Today is the 40th Anniversary of the Clean Air Act and over the last 40 years thislaw has saved hundreds of thousands of American lives and has allowed the

government to keep up with the best science on air pollution. The Clean Air Act hasbeen one of our country’s most successful pieces of legislation and has saved money

and lives throughout its history. In your report series, The Benefits and Costs of theClean Air Act, the EPA details the lives saved. 1It projects that in 2010 alone, the

Clean Air Act is likely to save on average 23,000 lives and prevent nearly a million toover 2 million asthma attacks, on average 4 million lost work days, and between

23,000 and 144,000 hospitalizations and emergency room visits. In its first two

decades alone, it created benefits valued at over $22 trillion — 42 times greater

than the estimated costs of its regulations.

Climate Change Puts American’s Lives at Risk

Climate Change has the potential to risk countless lives in the US. According to theNational Weather Service, between 2000 and 2009, fatalities from heat, hurricanes,

and floods were the top three dangerous “natural” hazards for US citizens. 2

Excessive heat can kill us. We can overheat if our steady core body temperature of

98.6°F (37°C) rises with sustained skin temperatures above 95°F (35°C). If our—

skin is not sufficiently colder than our core, the body cannot cool itself byconducting metabolic heat to the skin. 3Once that heat is transferred to the skin then

a breeze or low relative humidity are critical for sweat to evaporate and help us cooldown. 3Despite modern technology and emergency response measures, heat waves

EPA-HQ-OAR-2010-0107 Oral Testimony UCS 9/14/2010
nearly 20 percent—almost three times the rate of increase in total precipitationsince 1958.8,5 For some regions of the United States these percentages can go up to

as high as an average 67 percent increase in the amount of rain falling in the

heaviest most extreme precipitation events. 8This is a well known consequence of a

warming planet that has both increased average evaporation rates delivering more

water to a warmer atmosphere that can hold have higher relative humidity. 6In

places where rain or snow occur, light precipitation events are dropping less rain or

snow on average and heavier precipitation events are dropping more rain or snow

on average. Ironically this trend creates conditions that are more likely to produce

both intense drought periods punctuated by floods, often in the same region. 8

A study by Ashley and Ashley in 2008 analyzed flood fatalities between 1959 and

2005 in the contiguous United States, excluding those from Hurricane Katrina. 7

Texas had the largest total number of fatalities from flash floods and river floods

over the study period 7.When standardized for population, South Dakota,

Mississippi, West Virginia and Montana had the largest fatalities per 100,000 people

from flooding. 7Those between the ages of 10 and 29 and over 60 years old were

disproportionately at risk. 7Although human behavior contributed to these flood

statistics, there is strong evidence that the conditions that put people most at risk in

the first place, flash floods, are due in part to the shift in the baseline to more

extreme precipitation events in a warming world. 89

This makes me wonder if it is entirely honest to call these “natural hazards.” This

gives a false impression as it does not acknowledge the growing role of climate

change in shifting the baseline conditions within which weather events spawn.

There can be no doubt that when a storm forms over an ocean or over a valley, the

initial conditions of local sea surface temperature and atmospheric humidity are

intimately linked to a warmer planet compared with conditions a hundred years

ago.

Still, there is a lot more research that needs to be done to improve upon the efforts

already underway at the National Center for Atmospheric Research, NOAA and

NASA among others around the world that are researching the relative

contributions to weather events from natural cycles and climate change. Scientists

will continue to work to reduce the uncertainty in preparing seasonal drought, high

heat risk, and prevailing storm pattern projections for a region.

While we must improve our weather warning systems, emergency response plans,

public health education and so on, it is entirely prudent for the EPA to address the

EPA-HQ-OAR-2010-0107 Oral Testimony UCS 9/14/2010 2
unabated, a heatwave similar to the 2003 event could occur every other year in

Europe by the end of this century and be considered quite an ordinary summer

what is considered quite extraordinary in our current climate. 1011 Remember this

heatwave took between 35,000 and 50,000 lives. 4

State and Federal Implementation Plans

It is extremely important that the EPA comply with the requirements under the

Clean Air Act to take over permitting programs for states that can’t or won’t comply

with greenhouse gas rules. As is stipulated under the Clean Air Act, a state

implementation plan is a collection of the regulations a state will use to clean up

polluted areas. The states are obligated to notify the public of these plans, through

hearings that offer opportunities to comment, in the development of each stateimplementation plan. The SIP becomes the state Tlegal guide for local enforcement

of the Clean Air Act. Under the Clean Air Act, if a state does not submit animplementation plan the federal government is obligated to require the state to

follow the federal plan. States have a duty to protect their citizens fromenvironmental risks and if a state is unwilling to perform this duty the federal

government must step in. EPA must plan to take over permitting programs in

states that do not meet the requirements to start limiting greenhouse gas emissions

by next January, when the agency’s climate rules formally kick in. Some states, such

as Texas and Virginia, have already expressed opposition to EPA’s proposals andhave called this requirement under the Clean Air Act unlawful. This could not be

further from the truth and in fact if EPA doesn’t move forward in the absence of

state action the agency would be out of compliance with the requirements of the

Clean Air Act.

Conclusion

The Clean Air Act has been so successful because, at its heart, it is driven by the best

available science. Historically, the Clean Air Act has been used to respond to

scientific findings about the dangers of exposure to smog, lead, particulate matter

and acid rain. Now, we know that overloading our atmosphere with carbon dioxideis dangerously altering our climate and threatening public health including more

extreme weather events and as a catalyst for the creation of more ground level

ozone or smog, a conventional pollutant, when fossil fuel emissions are present at

similar levels.

Nearly all the studies to date find that more heat-trapping gases in the atmosphere

mean more likely risks of severe events that are most threatening to human life. 89

Knowing that future studies will only refine this general trend implies that as a

EPA-HQ-OAR-2010-0107 Oral Testimony UCS 9/14/2010 3
citizens of the United States and perhaps many people around the world by

implementing sound regulations to swiftly and deeply reduce national global

warming emissions.

1 Environmental Protection Agency. 1999. The Benefits and Costs of the Clean Air Act 1990 to 2010.

United States Environmental Protection Agency Report to Congress, EPA-410-R-99-001.http://www.epa.gov/oar/sect8 12.

2 NOAA. 2009. Natural Hazard Statistics with preliminary 2009 statistics access online September 10,

2010 at http://www.weather.gov/os/hazstats.shtrnl.

Sherwood, S.C. and M. Huber. 2010. An adaptability limit to climate change

due to heat stress, Proceedings of the National Academy of Sciences. Accessible online

www.pnas.org/cgi/doi/l0.1073/pnas.09 13352107.

Stott, P.A., D.A. Stone, and M.R. Allen. 2004. Human contribution to the European heatwave of 2003.

Nature 432, 610-614.

Kunkel, K.E., P.D. Bromirski, H.E. Brooks, T. Cavazos, A.V. Douglas, D.R. Easterling, K.A. Emanuel,

P.Ya. Groisman, G.J. Holland, T.R. Knutson, J.P. Kossin, P.D. Komar, D.Fl. Levinson, and R.L. Smith,

2008: Observed changes in In: Weather and Climate Extremes in a Changing Climate: Regions of

Focus: North America, Hawaii, Caribbean, and U.S. Pacific Islands [Karl, T.R., G.A. Meehl, C.D. Miller,S.J. Hassol, A.M. Waple, and W.L. Murray (eds.)]. Synthesis and Assessment Product 3.3. U.S. Climate

Change Science Program, Washington, DC, pp. 35-80.weather and climate extremes.

6 Trenberth, K.E., P.D. Jones, P. Ambenje, R. Bojariu, D. Easterling, A. Klein Tank, D. Parker, F.

Rahimzadeh, J.A. Renwick, M. Rusticucci, B. Soden and P. Zhai, 2007: Observations: Surface and

Atmospheric Climate Change. In: Climate Change 2007: The Physical Science Basis. Contribution of

Working Group Ito the Fourth Assessment Report of the Intergovernmental Panel on Climate Change

[Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.)1.

Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.

Ashley, S.T. and W.S. Ashley. 2008. Flood fatalities in the United States.JournalofApplied

Meteorology and Climatology, 47:805-8 18.

B U.S. Global Change Research Program. 2009. Global climate change impacts in the United States,

edited by T.R. Karl, J.M. Melillo, and T.C. Peterson. Cambridge University Press.

‘ National Research Council. 2010. America Climate Choices: Panel on Advancing the Science of

Climate Change. The National Academies Press. Washington, D.C. Available at

http://www.nap.edu/catalog/l 2782.html

10 Schär, C., and G. Jendritzky. 2004. Climate change: Hot news from summer 2003. Nature 432, 559-

560

‘ Meehl, G.A., and C. Tebaldi. 2004. More intense, more frequent, and longer lasting heatwaves in the

21st Century. Science 305, 994-997.

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