Docket ID No. EPA-HQ-OAR-2013-0495. 

February 6, 2014 

lohn Cartmill 

Director of Fairfax Climate Watch** 

My message today is simple: The US needs to reduce carbon emissions drastically starting now. 

And aithough this reguiation is a step in the right direction, it does not go neariy far enough in restricting 

CO2 emissions. COZ is a long lived ciimate pollutant. The emissions of today will adversely impact the 

ciimate for centuries to come. If the EPA is to fulfill its mission of protecting human heaith and the 

environment, then this agency will need to act quickly and forcefully. 

President Obama in last week's state of the union said, "And when our chiidren's chiidren look us in the 

eye and ask if we did all we couid to leave them a safer, more stable world, with new sources of energy, I 

want us to be abie to say yes, we did:' 

Back in 1992 the US signed the UN Framework Convention on Climate Change. Seventeen years later in 

2009 the EPA finally issues an endangerment finding. Five years after that we are here commenting on a 

proposed ruie that the EPA projects "...will resuit in negligibie CO 2 emission changes and benefits ... by 

2022:' Will our grandchiidren be proud of us for that? 

The NRC assessments in the science section of the reguiation detail a number of horrific perils: dramatic 

sea level rise, a doubiing of wiidfires, and ocean acidification to name just a few. They use terms like 

"disruptions," "massive cor-al reef die off," and "mass extinction:' All of which scream that we must end 

our CO2 emissions. And we must do it as rapidiy as possibie because the impacts are proportional to the 

cumuiative emissions. 

W inston Churchill said it best: "The era of procrastination, of haif-measures, of soothing and baffling 

expedients, of delays, is coming to its ciose. In its piace we are entering a period of consequences:' 

We are aiready witnessing these consequences. Oyster fisheries on both coasts are imperiied by ocean 

acidification, and I shudder to think of the cost if California doesn't get rain soon. In 2011, barge trraffic 

on the Mississippi River was stopped due to record high water caused by flooding, and in 2012 it was 

stopped by record low water due to drought. What will happen to the insurance industry when we get 

another Katrina or Sandy, or both? 

This reguiation aiso ignores secondary emissions as a resuit of extracting and transporting these fossil 

fuels. A 2011 Analysis* found that "Each stage in the life cycle of coal--extraction, transport, processing, 

and combustion—generates a waste stream ...that is costing the U.S. pubiic ...haif of a trillion dollars 

annually." 
Natural gas extraction has its own set of probiems. Methane leaks occur in drilling, as we saw just last 

week in the Gulf of Mexico, and in pipeiines, like the one that expioded in Canada two weeks ago. Then 

there's the frack-quakes and ground water contamination with a witches brew of "proprietary" chemicais 

that are have lead states and municipaiities, the one's that care about the environment and the heaith 

of their citizens, to ban fracking. 

Along with the dangers to the environment and to the ciimate, this reguiation is aiso a faiiure 

economically. By allowing coal and natural gas power piants to continue to freeiy spew their waste 

gasses into the atmosphere, it gives them an unfair advantage over zero emission technoiogies like wind 

and soiar. Instead of embracing the future, this reguiation heips perpetuate fossil fuel technoiogies that 

need to go the way of the vacuum tube and typewriter. 

One day soon there will be a price on carbon. Maybe imposed as a resuit of ciimate negotiations. Maybe 

imposed as a carbon tax by congress. Maybe it will be the cost of adaptation, like the billions we spent 

on the levees in New Orleans to repiace the levees we spent billions on before. But my greatest fear is 

that it will be paid in lives lost and dismal futures for our chiidren and grandchiidren. 

I reaiize this reguiation is probabiy the best you can do. I understand how the polrtical cllmate works. But 

I aiso understand how the physical climate works. And as Dr. Wally Broeker once said "it is an angry 

beast, and we are poking at it with sticks." 

It's ciear we must have urgent action to put a cap on the cumuiative total of greenhouse gas emissions. 

Considering the ciimate consequences we're facing if we procrastinate, does the EPA really think this 

reguiation truiy fuifills its mission of protecting human heaith and the environment? 

*Paul R. Epstein, Jonathan J. Buonocore, Kevin Eckerle, Michael Hendryx, Benjamin M. Stout III, Richard 

Heinberg, Richard W. Clapp, Beverly May, Nancy L. Reinhart, Melissa M. Ahern, Samir K. Doshi, and Leslie 

Glustrom. 2011. Full cost accountine for the life cvcle of coal in "Ecoiogical Economics Reviews:' Robert 

Costanza, Karin Limburg & Ida Kubiszewski, Eds. Ann. N Y Acad. Sci.1219: 73-98. 

**Fairfax Climate Watch is a non-profit organization, with the mission to honestiy communicate ciimate 

science and reiated information in a productive context. It was founded by our executive director Matt 

Owens in 2012.