COMMITTEE ON ENVIRONMENT

AND PUBLIC VVORK;S Novemb• 6, 2013 Administrator G:_na McCarthy Environmental Protection

Agency 1200 Pennsylvania

Ave., NWWa.•hington, r)c, 20460 Dear Administrator

McCarthy:
want to commcnd

the U.S. Enviromnental

Protection

Agency

(EPA) for moving forward under the Clean Air Act to control carbon pollution

l'toxn our n•tion's

power plants

lhe country'•

single biggest
source of such pollution.

Our landmark

environmenta[

laws, including

the Clean Air Act, have provided major public health mad economic

benefits,

and EPA's actions to reduce carbon pollution

will safbguard the ,-•aericar.

people. The need to address carbon pollution

is clear, and the Clean A2r Act provides

common-sense

tools to achieve this vilal goal. The U.S Suprerae

Court has co.afirmed

twice., including

in .•las.•'achusetts

v. EPA, that EPA has dear authority

to control climate pollution

under the Act. Using the best availabie information.from America's

leading scientists

and public health experts, EPA formally

found in 2009 that climate pollution

threatens

public health. Since then, evidence

ofclimate

change h•s only grown stronger.Scientists now tell us they are as certain of man-made

climate change as they are that cigarettes

are deadly, and only slightly less than scientists'

agreement

that gravity exists. We have. seen the dangerous iml;aCt• of climate chm•ge all •ound us from record high temperatures

in •he U.S., to severe wildfires

in California

and other western states, 1o flooding

of biblical

•rinking Arctic sea •ce and rising sea levels. We must take serious actton now to reduce carbon pollution.

I fully supt•a the EPA in its ef[brts.t¢>

address this dangerous

air pollution

which •uses climate disruption.

am proud to say that the State of C;aiifornia

has been a leader in reducing

carbon pol!utioa.

Under the state's AB 32 program,

carbon pollution

from power plants, cars and other sources will be reduced by. over 6% by 2020, and a third of the state's electricity

will come from renewable

sources by 2020. A 2006 California

law alst• requires

that any power plant providing

energy to the state must be designed to sig•fifieantly

limit its carbon pollution

at levels equivalent

to the agency's

new power plant proposal. The Clean Air Act has a long record of success, and this landmark

environmenlal

law ensures lhat EPA can continue

Io protect public health and the nation's

economy

fi'om the dangers of climate change. EPA's actions today to reduce power plant pollution

arc needed to help protect the health and s•fety of future generations,

and to promote

economic

opportunities

in den. ur]•rgy tculmulogy.

C]mirmanPoll'

RichSubject:

EPA Carbon Rule Listening

Session,

Tue Nov 5, 2013
Thank you for this opportunity

to speak.

am the founder and manager

of a fledgling

national

campaign

called, Transition

Express, focused on helping our fellow Americans

to find affordable

ways to downshift

to low carbon lifestyles,

by 2020. There is a reason for this date: we don't have much time left as a civilization,

to wean ourselves

off fossil fuel, to guarantee that global warming

doesn't go beyqqd 2 @grees, celsius, as agreed upon•by world I.eadej:sja

C_openl•agen, in December

2009. • •-/•

• • "•.••

• •,,^ •,.•• Thi•i• why it i• imperative,

that polluters

do their fair share a•well: HOWEVER,

strong standards_that

limit pollution from coal and natural gas-fired

power plants has a better remedy:

shutting

these power plants down one by one, as power gets accelerated

from renewables,

like solar, wind, hydropower

and geothermal

energy. Our campaign

strongly supports

the effort being made by Jacobson

et al, a team of 4 professors

from Stanford,

Cornell and UC Davis, offering blueprints

state by state to go 100% renewable

between

2030 and 2050.--• Renewables professionals

indicate this is doable, that technically

the various microgrids

and form• of storage are available. We simply need to start the process. •1•1, •)•)OY•cl Let's start b closln down these ossi•ased-ower

"ants to be ,n•h•iJ•oce•.now

Let's ho y g

•

•, pJ•

el" i$ p

• w real world •,

Priscilla Rich, founder Express Campaign

•Jwards

Danville

•'A www. TransitionExpress.

vpweb.com

an advocacy

group, promoting

low carbon lifestyles

by 2020 founder of 350 Contra Costa/Tri-Valley,

with focus on 100% Renewables

movement,

building

Climate Teams city by city- CONTACT:

o[[ice(•TransitionExpress, vpweb.com for inspiring

our new Be TheExample

campaign-within-a-campaign, an Einstein

quote: 'Setting an example

is not the main means of infiuencing

others, it is the only means.' announcing 2 new websites

www.AtlasAwards,

vpweb.com

and www.Be TheExample.

vpweb, corn presenting climate heroes yearly, and building

climate teams locally www.LowCarbonPledge.vpweb.com how all Americans

can move towards clean energy

16 ways www.Rethinkl'ngEnergl•, vpweb.com

affordable

way to do energy retrofits on homes www.SolvingClimateThreat.vpweb.com national

action see the latest/ www.SustainableDesign, vpweb.com

resources

on energy efficiency

energy

change

www. WorkingGreen.vpweb.com ideas for creating a unique career in the new green economy www.gol OOpercent.org-

campaign

effort of Renewables

100 Policy Institute,

Santa Monica CA www.renewablesl OO.org main website of instffute listed immediately

above www.theSolutionsProiect, org Stanford

U. Environment

Engineering

Professor

Mark Z Jaeobson's

upcoming

website, based on his team's study for state by state blueprints

to go 100% sign up for updates http://•vww.huffingtonpost.corr•stac•'-clark/mark-z-iaeobson-renewable-energv b

the back2859518.h,tml story on the •lacobson

et al studi •, state by statea to g• 100% renewable

•

••

•K• I • • • I ,•Poll•/RichSubject: EPA Carbon Rule Listening

Session,

Tue Nov 5, 2013
Thank you for this opportunity

to speak.

am the founder and manager

of a fledgling

national

campaign

called, Transition

Express, focused on helping our fellow Americans

to find affordable

ways to downshi•t

to low carbon lifestyles,

by 2020. There is a reason for this date: we don't have much time le•t as a civilization,

to wean ourselves

off fossil fuel, to guarantee that global warming

doesn't go beyond 2 degrees celsius, as agreed upon by world leaders in Copenhagen, in December

2009.This is why it is imperative,

that polluters

do their fair share as well. HOWEVER,

strong standards

that limit pollution from coal and natural gas-fired

power plants has a better remedy:

shutting

these power plants down one by one, as power gets accelerated

from renewables,

like solar, wind, hydropower

and geothermal

energy.
Our campaign

strongly supports

the effort being made by Jacobson

et al, a team of 4 professors

from Stanford,

Cornell and UC Davis, offering blueprints

state by state to go 100% renewable

between

2030 and 2050. Renewables professionals

indicate this is doable, that technically

the various microgrids

and forms of storage are available. We simply need to start the process. Let's start by closing down these fossil-based

power plants to begin this process, now. Let's show real world leadership by proving it can be done. Thank you.Priscilla Rich, founder/partner&•manager/Transition Express Campaign

Awards-

Danville

CA www.TransitionExpress.vpweb.com an advocacy

group, promoting

low carbon lifestyles

by 2020 founder of 350 Contra Costa/Tri-Valley,

with focus on 100% Renewables

movement,

building

Climate Teams city by ci•_ CONTACT:

oflTce(&TransitionExpress, vpweb.com for inspiring

our new BeTheExample

campaign-within-a-campaign, an Einstein

quote: 'Setting an example

is not the main means of influencing

others, it is the only means.' announcing 2 new websites

www.AtlasA

wards', vpweb.com

and www.Be TheExample.

vpweb.com presenting climate heroes yearly, and building

climate teams locally www.LowCarbonPledge, vpweb.com

how all Americans

can move towards clean energy 16 ways www.RethinkingEnerg•,, vpweb.com

affordable

way to do energy retrofits on homes www.SolvingClimate Threat. vpweb.com

national

action see the latest, www.SustainableDesign, vpweb.com

resources

on energy efficiency

energy

change

www. WorkingGreen.vpweb.com ideas for creating a unique career in the new green economy www.go 100percent.

org campaign

effort of Renewables

100 Policy Institute,

Santa Monica CA www.renewablesl OO.org main website of institute listed immediately

above www.theSolutionsProiect, org Stanford

U. Environment

Engineering

Professor

Mark Z Jacobson's

upcoming

website, based on his team's stu@ for state by state blueprints

to go 100% sign up for updates http://www.huflTngtonpost.comZstacv-clark/mark-z-•acobson-renewable-energ v b 2859518.html

the back story on the Jacobson

et al studies, state by state, to go 100% renewableUnionof o oConcerned Scientists Science for a Healthy Planet and Safer World

Testimony of Dr. Melanie

Fitzpatrick

at EPA's listening

Session to solicit input on the power plant carbon standards,

on behalf of the Union of Concerned

Scientists

November 5, 2013

Thank you for the opportunity

to testify today in support of strong power plant carbon standards. My name is Melanie

Fitzpatrick

and I am a climate scientist

at the Union of Concerned Scientists

(UCS). UCS is the nation's

leading science-based

nonprofit

working for a healthy environment

and a safer world. On behalf of UCS's more than 350,000

supporters,

and network

of more than 18,000 scientists, I want to say today that we strongly

support the Environmental

Protection Agency's (EPA's)

efforts to limit carbon emissions

from fossil fuel-fired

power plants under the Clean Air Act.I have been working

as a climate scientist

and educator

for the past two decades

in many parts of the world, and I would like to remind you why we urgently

need to curb ourheattrapping emissions.It is ,past time to act on this. Levels of carbon dioxide in the atmosphere

are higher now than at any time since humans

walked the planet. In the United States, power plants account

for 40% of the carbon pollution

that causes global warming. Climate change is not something

happening

in the future. We are living with the impacts of a warming climate right now. And over the last half century,

humans

have been the dominant
cause of this warming.Globally, last year was the 35 th year in a row warmer

than the global average.

That means every young person in this room today has never lived through

an average year. Young people are simply not living in the same climate that their parents grew up in. We are truly in
a new global climate regime.
In the United States, high temperature

records are being broken at twice the rate of low temperature records.

For the last three decades,

each decade has been warmer than the last.

www.ucsusa.org Two Brattle Square. Cambridge,

MA O21.38-3780

TEL: 61.7.547.5552

FAX: 61.7.864.9405 1825 K Street NW. Suite 800. Washington,

PC 20oo6-•.232

TEL: 202.223.61.33

FAX: 202.223.61.62 2397 Shattuck Avenue Suite 203 Berkeley, CA 94704-1.567

TEL: 510.843.1.872"

FAX: 51.O.843.3785 One North LaSa[[e Street. Suite 1.9o4" Chicago, IL 60602-4064

TEL: 31.2.578.1.750"

FAX: 312,578.1.751. Printed on 1.oo% Post-Consumer

Recycled PaperUnionof • oConcerned Scientists Science for a Healthy Planet and Safer World

The impacts we see from climate change are wide ranging in this country

from extreme heat waves, drought

and wildfires

to sea level rise, more heavy downpours

and an increase

in hurricane intensity.

All of these affect human health and wellbeing. You probably

heard that Australia,

the country I am originally

from, had terrifying

fires on the edge of a major urban area last week. Fire season isnow occurring

earlier in the spring and extending

later in the fall. The same is happening

here. California

and most of the western

United. States is also experiencing a lengthening

of the fire season, which is now two months longer than it was just 40 years ago. Fire experts from around the world say the fire behaviors

they are seeing
are unprecedented.This summer,

Yosemite

had the largest fire ever in the Sierras. To date, it has burned an area almost the size of metropolitan

Los Angeles.

After more than ten weeks, the Yosemite

Rim Fire is now under control, but it's still burning.

That fire won't be completely

extinguished until it rains or snows.And last week the nation remembered

the anniversary

of the most damaging

hurricane

in U.S. history. Hurricane

Sandy is another example

that we are already living •vith the impacts of a warming

world. The science shows that a warmer

ocean in the Gulf of Mexico is leading to an increase

in the intensity

of hurricanes

in the North Atlantic. The task of the EPA in reducing

emissions

from power plants is critical as we face our responsibility to reduce the impacts of global warming

on ourselves,

on our children

and on future generations.Thank you.

www.ucsusa.org Two Brattle Square. Cambridge,

MA O21.38-3780

TEL: 61-7.547.5552.

FAX: 61.7.864.9405 1.825 K Street NW. Suite 800. Washington,

PC 20006-1.232

TEL: 202.223.6t33

FAX: 202.223.61.62 2397 Shattuck Avenue. Suite 203 Berkeley, CA 94704-1.567

TEL: 51.O.843.1.872

FAX: 51.O.843.3785 One North LaSa[[e Street. Suite 1.9o4" Chicago, IL 60602-4064

TEL: 31.2.578.1.750"

FAX: 31.2.578A751. Printed on 1-oo% Post-Consumer

Recycled PaperI'm

here with my son and because

of him. He expects

me, expects

all of us, to take care of him and protect

him.My son loves picking

the ripe juicy plums and crunchy

apples

from the trees near our house. He keeps track of the details.

He tells me, "Mama,

in june we eat plums,

in september, apples."

He wants to know where the plums are now. tell him they will be back in June. He believes

me, assured

that fruits, like seasons,

go in cycles.

That the trees and plants we depend

on, the earth itself, is secure,

will take care of us. That loss is manageable,

because

it is part of a sustainable

cycle.
pray that am not lying to him. know that here, we are suspension,

still thinking,

most likely, that next year the plums will ripen again in June. But what is the difference between me and a mother

in Sudan,

whose

plum tree is part of the 2% loss of productivity expected

each decade?

What is the difference

between

me and a mother

in Bangledesh, driven from her farm by floods?

Or a mother

in New Orleans,

Queens, Oklahoma, or the Sierras,

whose

trees have been destroyed

by "extreme

weather" whose cause we all know. But this is also about this very child here: What is the difference between

now, and 10 years, in 20 years, in 30 years from now, will be able to assure

this child that the plums wilt come back? feel the seasons

heat pressing

harder

now, and feel the same dull fear felt when my son had a fever as a baby. The same dull fear as all mothers.

hear the oceans

lapping at our edges,

smell all of us bristling

more and more with the tension

of droughts, wildfires, crop failures,

storms. And so can't just reassure

him and sit idly under the plum tree, hoping

that somehow

it will turn out ok•opip•hat

despite

a near consensus

among

scientists,

somehow,

we don't REALLY

have to act, that somehow,

we won't leave our children

a world more tumultuous, barren,

and suffering,

than any we have endured. We all, in our hearts,

and in reading

the facts, know what is needed:

to reprioritize

and reduce, right now. But how much will we stand up to the status quo, the representatives of industry,

the protection

of profits?

How much will we stand up to our own feeling

of powerlessness, our enormous

inertia that is leading

us steadily

towards

destruction.

Wilt we fight harder,

more urgently,

than we thought

possible,

to know that we are not lying to our children

when we tell them that it will be ok? urge you, as representatives

of the government,

to step up, to go out on a limb, to do what is right. To set tough limits on existing

as well as new factories.

To stop protecting the profits of polluters.

To refuse dangerous

stop-gap

solutions

like fracking

and nuclear and fight for real structural

changes.

To move quickly

towards

law that stops ongoing carbon pollution

and acts boldly to protect

our kids, my kid. can only imagine

what you are up against,

what it would take to really do this. But ask you to consider

what we wilt eventually have to tell our children:

the truth about the reality (•f our worl•l,•and

our role in it. We don't have time to wait. -•:•,. •" 6 •,•-• I'• ["Jf• • f'-or Carbon tax? Which one works.•best?
•

. A Pollution

Tax taxes

.all fo.rms

of pollution

including.nukes. A carbon

tax doeS-n0t-tax nuclear

power,

because

nukes don,t. gi.ve oO ca:rbon:-The nUClear

industrycame up with the carbon

Tax as a distraction, totrick

pebple

into foCuSing

On coal.

Our response is to call for a Pollution

Tax to make

require

Atomic Corporations to deposit

a bond

to pay.for

future

meltdowns

& make Tepco

pay for the meltdown

at Fukushima. Youtube: paul8kangas SolarOne

(100%

Solar).Help Fukushima Response Network-SF adopt one refugee

family

from

Fukushima to move

to a solar

powered

home

in Lancaster,

Ca. Green Festival.

FRN-SF

is meeting

Sat 11-9-13

at the Green Festival

to discuss

how to help

one family

move. 3pm at a food

court

table.

Also

Sun 3pm.

Join

FRN. We plan

to asked

Tepco

to pay for the air fare and buy them

a solar

home

in Lancaster. www. fu ku shi maresponse, org Paul Kangas

415-368-8581 d r8kangas

@ gmail,

comWe thank

you

for your

input. Please use this card if you would like to submit written input on controlling carbon pollution

from existing

power plants. Onc• completed,

kindly return to the registration

desk. National Pubfic Listening

Sessions

on Redudng

Carbon Pollution

from Existing

Power Plants

Meeting location (city/town)•.OXa_We thank

you

for your

input. Please use this card if you would like to submit written input on controlling carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk. National Public Listening

Sessions

on Reducing

Carbon P, ollution

from Existing

Power Plants

Meeting location (city/town)

•._"•e.•aank••or your

input. Please use this card if you would lik.e to submit written input on controlling carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk. National Public Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power plants

-. o I <. .•

• •;-;

•We thank

you

for your

input. Pleaseuse this card if you would like to submit written input on controlling carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk. National Public Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power Plants

•exhartkGo•f•rZyour input. Please use this card if you would like to submit written input on controllin9 carbon pollution

from existin•

power plants. Once completed,

kindly return to the registration

desk. National Public Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power PlantsWe thank

you

for your

input. Please use this card if you would like to submit written input on controlling carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk.

Meeting locationNational Public Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power Plants

:.•;

-•<,.. k•_

C '"" •'

•

'1

W gmtdoLyour input. Please use this card if you would like to submit written input on controlling carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk. National Public Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power Plants

ti •

If T>i O ) /')

Meetincl location (city/town)

•._•!¢ "j-•1¢6•$

O0We-thank you

for your

input. Please use this card if you would like to submit written input on controlling carbon pollution

from existing

power plants. Once completed,

kindly return to the registration

desk. National Pubfic Listening

Sessions

on Reducing

Carbon Pollution

from Existing

Power Plants

t• you

ofofofof• your

input.

se use this card if you would like to submit written input on controlling

on pollution

from existing

power plants.

e completed,

kindly return to the registration

desk. National Public Listening

Sessigns

on Reducing

Carbon Pollution

from Existing

Power PlantsNovember22,2013

SharonEnclosed for agency records is the written input received

during Region 9's Public Listening

Session on Reducing Carbon Pollution

from Existing Power Plants. Our session was held in San Francisco

on November 5, 20:•3. We received written inputfrom

3:• individuals. Sincerely,

RaySaracinosaracino.ra•@e•a.•ov4•5-972-3•6•bOAKLAND CITY COUNCILMEMBER DAN KALB

TESTIMONY EPA LISTENING

SESSION

ON CARBON

POLLUTION

RULE FOR EXISTING

POWER

PLANTS SAN FRANCISCO,

CA • NOVEMBER

5, 2013 Regional Administrator

Blumenfeld

and EPA officials.

My name is Dan Kalb. am here today as an individual

member

of the Oakland

City Council. Thank you for the opportunity

to testify today. The City of Oakland

has a comprehensive

and far-reaching

Energy

& Climate

Action Plan (ECAP) with a goal of reducing

our emissions

to 36% below our 2005 baseline levels by 2020, and 83% below 2005 levels by the year 2050. But we know that our actions

alone cannot be enough

to curb the expected devastating impacts

of global warming.

We know that we need other cities, states, and the federal government

to step up. And since power plants are the largest
source of carbon pollution

in the country,

responsible

for approximately

40% of all our heat-trapping

carbon emissions,

the carbon pollution

rule for existing

power plants under discussion

today is an essential

part of the solution--that

is, if we're serious about our country

getting

a head of the curve on rasing temperatures. There are currently

no national

carbon limits for power plants.

urge the U.S. Environmental Protection

Agency

to move forward

with smart emission

reduction requirements for existing

power plants so that we can reduce carbon pollution

as quickly as possible

to address

climate

change

for the residents

of Oakland

and every city and town in the United States. The costs of inaction

are already

apparent:

worsening

air quality,

increased transmission of infectious

diseases,

and increased

risk of wildfires. Cities across the country--including Oakland--are

doing what we can to show leadership and address

the climate

crisis, but we need federal

leadership

like this rule to address

the most significant

source of carbon pollution

that is causing

climate change--namely fossil fuel power plants, This rule is a critical step in reducing

the effects of global warming

and protecting public health, and will contribute

to a much-needed

transition

to a cleaner

electricity system for all of us, with an emphasis

on renewable

energy. We have a collective

obligation

to protect

future generations

from the effects of climate change by addressing

its causes and its impacts.

The carbon pollution

rule for existing

power plants puts us on a pathway

to doing just that. Thank you again for the opportunity

to share my remarks.Good morning.

My name is Greg Bedard.

I'm the Program

Director

for California Interfaith

•Power

& Light. CIPL's

mission

is a religious

response to global warming,

and we are the flagship

affiliate

of the national organization..We now have over 600 member

congregations

throughout the state that reach a quarter

of a million

Californians.

In my position,

I'm blessed

to work with people

from many different backgrounds and faith traditions.

work with community

builders

who care deeply about their congregations,

their nation and the wodd.

work with people who believe

they are called upon by the Bible, the Quran,

the Torah--by many sacred

documents--to

love their neighbor.

This translates into not polluting

our neighbors',

air, water or earth because

it is our moral responsibility to care for Creation,

which has been entrusted

to us.

One of our member

congregations--the Church

of the Brethren

in Modesto, California--went

live with a 57kWh

solar system

(consisting

of 200 285 watt panels)

in September

2012. As of this morning,

their total CO2 offset equals

1,970 trees. The total energy

generated

from their system is equivalent

to 8,867 gallons

of.gasoline

saved.What makes,

a congregation

take action to help protect

Creation?

In the words of this-faith

community

because,

"We are excited

by this work of stewardship of the earth, our resources,

and the ministry

God has given US."

Fossil fuel power plants are the single, largest

source

of climate

pollution

in the United

States.

The fact that there •are currently

no national

carbon

limits for existing

power plants is unacceptable.

CIPL and our members

that have done extraordinary

things to reduce

their own carbon

footprints, support common

sense standards

that will help .reduce

carbon

pollution from existing

fossil fuel power plants throughout

the nation,

CIPL supports

the EPA's efforts

to curb carbon

pollution

as it will also protect human

health,

improve

air quality,

and reduce

the rates of asthma for our children.

Please

adopt common

sense regulations

to protect Creation from the increased

impacts

of climate

change.

Thank you for the opportunity

to share my testimony

with you today.Intcrfi ith Powcr

& Light

A Religious Response to Global Warming

US EPA Region 975 Hawthorne

St., San Francisco,

CA 94105
Dear Administrator

McCarthy, My name is Bill Bradlee and work for a nonprofit

called Interfaith

Power & Light. We work with people of faith clergy, congregations

and individuals

to address

climate change. currently work with our state Interfaith

Power & Light leaders all over the country

including

states like Arizona, Kentucky

and Kansas. The people running

these nonprofits

are working

hard to help congregations address climate change by becoming

more energy efficient

and using renewable

energy. In Arkansas, they've provided

energy efficient

light-bulbs

to low income congregations.

In Maine, volunteers

come together to build homemade

storm windows

that can be sold at a low price for needy families.

They have saved energy and money, but alone they can't change how much pollution

is being spewed

out of power plants.Power plants are one of the largest sources of greenhouse

gas emissions.

And we know that burning fossil fuels like coal and oil is the cause of global warming.

Coal would not be so cheap if we accounted

for all of the damage

it does to public health and its contributions

to climate disruption.

Yet we don't account

for these things -we allow profits to be privatized

while costs get carried by all of the public including

future generations.Each of our state Interfaith

Power & Light leaders see some people struggle

to pay their energy bills and put food on the table. They live in communities

with these people. They call them sister, brother,

uncle and neighbor. They care what happens

to each and every one of them. They also see the big picture of what's happemng •n their community

with pollution-related•isease, boom and bust industry,

and the changing climate creating

extreme

weather

events. They have to weigh these costs and benefits

every day and they get up and work with Interfaith

Power & Light and fight to change rules and policies so we can begin to address the climate crisis. They don't do it for the paycheck;

they do it because

climate change is a moral issue that must be addressed

now. I've heard said that it's not how many times we fall, but how many times we get back up. We've fallen by not putting carbon pollution

safeguards

in place long ago. Now it's time to get back up. We all need to be concerned about the people who are impacted

by this rule. But we also need to the show national, international and intergenerational

concern

for all of creation

impacted

by unlimited

dumping

of carbon pollution into the public commons

our air. The EPA needs to allow for innovation

to make the necessary changes that will reduce carbon pollution

as quickly and efficiently

as possible.

But we can't wait any longer to address

carbon pollution

and we can't do it in half measures.-I

urge the EPA to move quickly with the rule on existing power plants so that the US can begin to address this urgent problem.
It all comes down to making sure that we're leaving our children

a safer, stable, healthier

environment. Thankyou.Interfaith Power

& Light

A Religious

Response

to Global

Warming

Comments by Susan Stephenson,

Executive

Director,

Interfaith

Power & Light EPA Listening

Session

on Existing

Power Plant Rule November S, 2013 Thank you for being here to take our comments

today. Interfaith

Power & Light is strongly

in support of limiting carbon from existing

power plants. Interfaith Power & Light is a network

of people of faith who believe global warming

is the moral crisis of our time. IPL has 40 state affiliates,

reaching

15,000 congregations,

over 5 million people. We are headquartered

here in San Francisco. We believe that the United States has a responsibility

to lead the world in responding

to this crisis. As the world's

largest historical

polluter,

and the world's

richest nation with the most innovative technology,

we need to develop,

implement

and demonstrate

clean energy solutions. The first step is putting an end to unlimited,

unchecked

pollution

from power plants. Interfaith Power & Light (IPL) is helping congregations

become

models of energy stewardship. We've reduced

our carbon pollution

while saving money for other critical needs. We've shown that it can be done. But we know that our actions alone will not be enough as power plants are responsible for about 40% of carbon pollution

in the U.S. We stand in support

of strong carbon P ollution£tandardsc•r•ower•la nts. The costs of inaction

are already apparent:

worsened

air quality and more asthma attacks; increased transmission

of infectious

diseases

from insects; and more extreme

weather including floods, storm surges, and wildfires.

And in every instance,

it is the most vulnerable the poor, the children,

the very old, the sick, who suffer the most. This is an issue of justice.
As people of faith, we are called to be stewards

of Creation.

Climate

change threatens

the very balance of nature, which sustains

life. As President

Obama said, knowing

what we know, not to act on climate change would be to "betray our children

and future generations." There are currently

no national

carbon limits for power plants. Wouldn't

we all agree that unlimited pollution

is bad for everyone?

IPL stands ready to support

the EPA and the President's

Climate

Action Plan. We are already reducing emissions

in our facilities,

thousands

of which have made energy

efficiency improvements and are using renewable

energy where possible.

But we can't do it alone. We need coordinated

federal action to effectively

address

power plant pollution.

Thank you.

A Campaign

of The Regeneration

Project 369 Pine Street, Suite 700, San Francisco,

CA 94104 Phone 415-561-4891

Fax 415-561-4892.

Web www.lnterfaithPowerandLight.orgLEAGUE OF WOMEN

VOTERS

OF CALIFORNIA
LWVC Guidance--EPA Listening

Session Climate change is now. Heat records are being broken, glaciers

are melting,

the seas are rising and we have a moral obligation

to protect are children

and future generations

from the even greater impacts of climate change that will occur if we don't do something today.The League of Women

Voters of Califomia

is nearly 100 years old. We have a long history of protecting

the environment

and promoting

public health and we strongly believe that U.S. EPA must create a strong carbon pollution

standard

for existing power plants to address the main cause of climate change and to protect the world's population from its devastating

impacts.
In the United States, power plants account

for 40% of the carbon pollution

that causes climate change. While we currently

protect public health with limits on arsenic, lead, mercury,

soot and other pollution

from power plants, there are no existing national

limits on carbon pollution.

That must change. Carbon pollution

that causes climate change is responsible

for increase

air pollution that can cause thousands

of death every year, yet it remains

unchecked. That must change.According to researchers

at Stanford

University,

unchecked

carbon pollution could lead to 21,000 climate change-related

deaths. And today, millions

of children live in areas that receive an "F" rating for at least one air quality measure_ based on th•unmA•ociatio •,• •,•" •h• • ;• o • That must change.Today, in California's

San Joaquin Valley asthma has reached

epidemic proportions, where some counties

report rates of over 20% for childhood

asthma. With climate change it can only get worse. That must change.

1107 9 th StreetSuite 300Sacramento, CA95814-3608916 442.7215888 870.8683916 442.7362 faxlwvc @lwvc.orgW•,•V.IWVC.O rg•,vw.smartvotel:.orgwww.easyvoter.o rg As citizens of Califomia

we have seen our future in the ruinous fires and floods, the destructive diseases

that our killing our forests, and through the shocking

collapse

of our salmon stocks. Left unchecked,

we know that climate change will have an overwhelmingly destructive

impact on our state and that must change. U.S. EPA pass a standard

that will help turn the tide against climate change and usher in a future that protects

our children

and their children's

children

from man-made climate change.

November 5, 2013••ql.JAC) HO "•.q•TOV

I••OV•

q•O •lJDA•j

•'O•.26,2013 Written Testimony

of Terry Oldberg,

Engineer-Scientist 27250 Julietta LnLos Altos Hills, CA 94022 650-941-0533 terry@knowledgetothemax.com Submitted to the EPA's Public Listening

Session

on 11 l(d) Carbon Pollution

Standards

For Existing Power Plants scheduled

for November

5, 2013 in San Francisco,

California Consideration by the EPA of carbon pollution

standards

for existing

power plants is based upon an argument

whose conclusion

is that an intolerable

level of global warming

would result from continued emissions

of carbon dioxide into the atmosphere

from combustion

of fossil fuels. Earlier this year, published

a peer-reviewed

article which proves this conclusion

to be scientifically and logically

unfounded.

The title of this article is "A Common

Fallacy in Global Warming Arguments";

the article is available

on the World Wide Web at http://wmbriq.qs.com/blo.q/?p=7923. In brief, the above referenced

conclusion

is drawn from an "equivocation,"

that is, an argument in which a term changes

meaning

in the midst of this argument.

By logical rule, to draw a conclusion from an equivocation

is logically

improper.

To draw such a conclusion

is the "equivocation fallacy."The equivocation

fallacy is the source of the conclusion

that an intolerable

level of global warming would result from continued

emissions

of carbon dioxide into the atmosphere

from combustion of fossil fuels. Scientific

research

is not the source of this conclusion

though this is commonly•med.Currently, there is neither a logical nor a scientific

basis for regulation

of greenhouse

gas emissions by the EPA. The EPA's staff can and should learn the logical basis for this conclusion by reading the article at http://wmbri.q.qs.com/blo.q/?p=7923 and carefully

digesting

its content. Then it should reverse regulations

already on the books. It should halt efforts toward promulgating new regulations

until a basis in science

and in logic exists for them. The federal government

has spent 100 billion dollars on global warming

research

without producing a product that is useable

for its intended

purpose.

Federally

supported

researchers have, however,

made it seem to political

leaders,

journalists

and members

of the general

public
as though there is a useable

product;

they have done this through

applications

of the equivocation fallacy. Massive

amounts

of money have been spent on the assumption

that the basis for federal,

state and local regulation

of greenhouse

gas emissions

is both scientific

and logical. This state of affairs suggests

the need for changes

among the ranks of those individuals who plan and manage

global warming

research

for the federal government.•a•tn•-'•l•nitgn•l ,•lt)lO

y'neT to ,(non'•eT

ne•hW nJ •z•l•eilut, Oi•£'ISThese are not just statistics---

at the regional

offices at the Lung Association,

we would receive

calls from people who lived in surrounding

areas close to power plants, usually people of low-income

who live on the frontlines,

and on certain occasions, during accidents

or flaring, these folks would tell us in no uncertain

terms that they simply could not breathe,

because

of too much pollution

from the plants.

/ T,his is heartbrt•aking,

especially.b•c,

ause it is preventable../•ff

¢7•'/'•7•q

d•.fl/•

With overwhelming

hi-partisan

support,

Congress

granted

EPA the authority

to reduce air pollution

to protect

public health decades

ago, with the passage

of the The Clean Air Act, one of the nation's

most important

public health laws, with a long history of success.

This authority

extends

to carbon pollution

and the Supreme Court has affirmed

this authority

multiple

times. This is particularly

important since Congress

is at a stalemate

concerning

the issue of global warming

and AQ legislation- the only way to stem the pernicious

effect of carbon pollution

is to look to regulatory

action by the EPA.

We have the knowledge

to reduce emissions:

from renewable

energy portfolio standards, from end-use

energy efficiency

rt•t•ttrrta

¢•'and-•,-A,-

t: budget trading programs,

resource

planning

requirements,

and other such programs.

In conclusion

EPA has a history of cutting other dangerous

power plant pollutants such as soot, smog, mercury,

arsenic,

lead and other toxics

certainly

we can do the same for carbon pollution.

For the sake of both the planet and all of us who live here, and to future generations,

there is a compelling

and moral rationale

for the strongest possible

standards

to reduce carbon pollution.
Thank you.Reducing Carbon

Pollution

from Existing

Power

Plants Linda Weiner Testimony:

EPA Hearing,

November

5, 2013
My name is Linda Weiner:

am the former Director

of Air Quality Advocacy

for the American Lung Association

in California,

and current

member

of the Executive Committee of the San Francisco

Sierra Club Group.

I'm here today to call for the strongest

possible

standards

in reducing

carbon pollution from power plants

EPA has proposed

standards

for future power plants to ensure that they are the cleanest,

most efficient

modern

plants, y.•t_t,•here

are no limits for existing

plants. These plants account

for approximately

i•,oOf-•-•'/'r the carbon pollution

that causes climate

change,

the largest single source. Because, make no mistake---

the impact on public health is a clear and present danger. As carbon is reduced,

so are air pollutants.

But with the buildup

of carbon pollution, temperatures

will rise and in turn increase

the risk of unhealthful

ozone smog levels, which we know is a trigger for childhood

asthma attacks.

Children

are

more susceptible

to the health effects of air pollution,

because

their lungs are still developing and they spend more time outdoors

compared

to adults. Additionally, older adults, people with heart or lung disease

and people living in poverty

all have increased risk from carbon pollution

and the ensuing

smog and soot.
Researchers from a 2013 study published

in Nature Climate

Change have found that the efforts enacted

now to reduce greenhouse

gases from all sources

in the US would prevent

more than 16,000 premature

deaths by 2030; a study from Stanford states that unchecked

carbon pollution

could lead to 21.000 climate

change-related deaths.•nslq "mwoq

•,nLta•

mo•t noDulloq

nod•,s3

•i:mbeREPA Hearing Comments Global climate change is a great threat to the future of human kind. We should make every effort to reduce carbon pollution in our atmosphere.

One critical way to reduce atmospheric

pollution is by regulating

and reducing

fossil fuels emissions

from our power plants. We must develop our cdtical thinking skills and bring ourselves

to see the big picture. This is difficult for many humans.

So wonder to myself, why are humans so often so unwilling to face the situation in which we find ourselves. As a physician

draw the analogy of a person who on examination

has the incidental

finding of elevated BP. The patient is instructed

in diet, exercise,

medication,

etc. Then six months passes and on retum the instructions

have been ignored; the BP is still elevated.

Why are you ignoring the problem?

Doc I'm feeling so good couldn't see any reason to change. In the same way with global climate change, we are too easily persuaded

to see no reason for making changes.

After all, the weather is great outside today. By neglecting

high BP today, the person will suffer tomorrow.

By neglecting

fossil fuels pollution as the cause of climate change today, we as humanity

are consigning

ourselves

to a future of misery. Yet too many of us cannot see it. also observe that many of the climate change naysayers

are business

people and money managers. In many cases, believe they have succeeded

in business

and financial markets by being contrarian

thinkers.

This has worked for them and is difficult to abandon.

They have learned to swim against the tide. But being a contrarian

in science can be a deadly mistake. When the evidence

points in one direction,

that direction

is the way to bet. The science is overwhelming

for fossil fuel pollution as the cause of climate change.

Thus we need cooler heads to prevail. The time for aggressive

action is now. We cannot afford to wait.

Version 11/05/2013Not

only is coal burning responsible

for one: third of US carbon emissions--the

main contributor

to -., climate disruption--but

it is also making us sick, leading to as many as 13,000 premature

deaths every year and more than $100 billion in annual health costs. Stronger

soot standards

could avoid up to 35,700 premature

deaths, 23,290 visits to the emergency

room, and 2.7 million days of missed work or school due to air pollution-caused

ailm.ents

every year, Think how much more of an effective society we could be if coat plants•ad

stricter emissions

regulations. For those across the country who couldn't

speak out at a hearing,

hear this. According

to a new poll by Hart Research

for the League of Conservation

Voters (LCV), The EPA's proposed

carbon pollution standards

have broad support in 11 states with key swing Senate races.. Support crosses political lines, even after voters hear arguments

both for and against the new standards,

Nearlythree-infour (74%) of likely voters in 11 states with swing Senate races say they favor the EPA 's "regulations to set limits on the amount of carbon pollution

power plants can release into the air', Hart Research

interviewed

1,113 likely voters E• 1 l/swing states (AK, AR, CO, GA, IA, I_A, MI, MT, NH, NC, and VA) from Oct. 9-13; MoE is +/-2.9% points overall at the 95% CISTATEMENT OF SALT RIVER

PROJECT EPA Listening

Session

on Carbon

Standards

for Existing

Power Plants Under Section

lll(d) of the Clean Air Act San Francisco,

California November 5, 2013 [Good morning]

[Good afternoon].

Thank you for the opportunity

to comment

at today's listening session.

My name is Barbara

Sprungl,

and I am the Manager

of Air Quality and Laboratory Services

at Salt River Project Agricultural

Improvement

and Power District.

SRP is

a political

subdivision

of the State of Arizona

that provides

retail electric services

to nearly 1 million residential,

commercial,

industrial,

agricultural

and mining customers

in Arizona.

SRP

serves these customers

with a diverse portfolio

of owned and purchased

electricity

resources

that includes coal, natural gas, hydroelectric,

nuclear,

solar, wind, biomass

and geothermal generation.
In the brief time I have to speak today, I would like to focus on five key principles

that SRP believes

are important

to consider

in development

of regulations

to regulate

carbon dioxide from existing

power plants: 1. States have primary

authority

under Section 111 (d). Congress

gave states, not EPA, the primary responsibility

and authority

to set and implement

performance

standards

for existing sources.

This is because

States are in the best position

to determine

what solutions will work to address carbon dioxide while preserving

a stable, reliable andcosteffective energy supply for their electricity

consumers.

EPA's emissions

guidelines

to the States must include a "best system of emission reduction" (BSER) for reducing

carbon emissions

from existing

units that is premised

on what is achievable

"within the fence" at each source to be covered

by the standards.

EPA 1must carefully

consider

cost, unit-specific

characteristics

and actual demonstrated technology for carbon reduction

in making this BSER determination.

Once BSER is established,

States should be provided

with abundant

flexibility

to craft plans for 111 (d) performance

standards

that use a diverse mix of emissions

reduction strategies, including

plant efficiency

improvements,

renewables,

customer

energy efficiency programs,

fuel switching

and emissions

trading programs.
4. EPA's emissions

guidelines

must not force States to retire or curtail existing

coal-fired units that provide

stable, reliable baseload

generation

for consumers.

SRP has recently committed to significant

new pollution

controls

on our coal fleet in response

to other EPA regulations,

such as the Regional

Haze Rule. These investments

should not be stranded under a carbon regulation

when they were considered

cost-effective

under previous EPA analysis.

Carbon standards

for existing

sources must consider

the "remaining useful life" of each covered

source to avoid premature

abandonment

of

EPA must allow States to incorporate

State-specific

needs into their plans for 111 (d) performance standards.

States that have made heavy investments

in renewable generation, or have had plant retirements

should receive full credit for the emissions reductions attributable

to these actions.

States with newer, well-controlled

baseload

resources should be able to adjust timelines

for compliance

to allow for full utilization

of these resources.

States that are anticipating

significant

load growth will need a performance standard

that accommodates

this growth.

2I

would like to close my remarks

by saying that EPA's best opportunity

for success in this effort is to actively

partner with the States and support State engagement

with stakeholders

in crafting their plans for future emissions

reductions.

Such an approach

will address local circumstances, significantly mitigate

the economic

impacts

of this regulation,

and ensure an effective

transition to future energy resources.

Thank you.Amy

AllenStatement to EPA on Existing Power Plant Standard

As a young person concerned

about her future, urge you to enact the strongest

possible standards

for existing power plants.

am 22 years old, and a masters'

student at Stanford

University,

studying

civil engineering with a focus on building energy efficiency.

am originally

from Springfield,

Illinois, and have witnessed the impacts of coal mining and burning in the form of farmland

subsidence

and bodies of water irreparably

damaged

by coal ash. Like everyone,

have witnessed

the impacts of climate change in the form of increasingly

frequent

extreme weather.

will attend the listening session in San Francisco tomorrow to make these comments

in person, and represent

many others from my school, and my generation.Specifically, suggest you adopt standards

similar to the ones recommended

by the Natural Resources Defense Council, with a limit equivalent

to 1,500 Ibs/MWH

for coal, and :•,000 Ibs/MWH

for gas. But most importantly,

some standard

needs to be put in place to set a precedent

that existing coal plants no longer have a license to pollute unabated.

want to secure a future for my own generation•and

that of my children that is not irreparably

damaged

by climate chaos: droughts,

wildfires,

natural disasters,

and conflicts over water, land, and other essential

resources.

CO2 emissions

to date have locked in a certain about of climate disruption,

but we must act now to avert the worst impacts. Please enact the strongest standards possible for existing power plants.Comments to EPA Listening

Session on Power Plant CO2 emissions

in San Francisco

on Nov. 5, 2013. From:Douglas Olson57 Thousand

Oaks St.Oakland, CA 94605doug@the-olsons.org(510) 220-3420retired scientist
Thank you for this opportunity

to comment

on the EPA role making for power plant CO2 emissions. While I am a retired scientist,

this field is not my area of expertise

so my comments

are general and rather short.The longer CO2 emissions

continue

the effects will be worse and the consequences

will be more expensive.Therefore the EPA should push strongly

to reduce CO2 emissions

as soon as possible. One important

question

you have to deal with is "what is a reasonable

cost of power plant modifications to reduce CO2 emissions?"

The scale for "what is reasonable

cost" should be determined by the cost of mitigating

the climate effects caused by these CO2 emissions. The transition

from fossil fuels to sustainable

sources of energy is disruptive

and will cause many changes

in what types of jobs are available

and where they are located,

as well as many other changes.

However,

this can not be accepted

as a reason to delay the transition

away from fossil fuels since the consequences

of climate change will also cause great disruption

to lifestyles and the economy.

Since disruption

is unavoidable,

the sooner the transition

is complete the shorter will be the period of disruption. We are all counting

on the EPA to do its job effectively

and expeditiously.
Thank you.EPA ELECTRICITY

GENERATING

UNIT CARBON

LIMITS HEARINGS: 5 NOVEMBER

2013, SAN FRANCISCO,

CALIFORNIA Good afternoon.

I am Robert Sawyer,

Professor

of Energy Emeritus

at the University of California•n•r of the National

Academy

of Engineering,

former Chair of the California Air Resources

Board, and a member

of the Board of Directors

of the American Lung Association

in California.

I am speaking

today as an individuala•d

9•-a• Thank you for the opportunity

to endorse

the initiative

of the Obama administration and the•EPA

to address

climate

change through

reducing

the carbon emissions •.t'¢/•• existing

electric

power generation.

Congratulations

on your recent regulation of the new fossil fuel electric

power generation

sector. Addressing climate

change requires

a comprehensive

national

commitment,

which, unfortunately, remains

elusive.

Ideally, a nationwide

carbon tax would be the preferred policy. Lacking

the national

consensus

to adopt this approach,

taking pragmatic measures

within the existing

regulatory

framework,

specifically

the Clean Air Act, is appropriate.California's conventional

air pollutant

reduction

initiatives

in the light-duty

vehicle sector, employing

the delegated

authority

under the Clean Air Act, demonstrated technological feasibility.

Adoption

by other states strengthened

the impact of our initiative. Coordination

with the Obama Administration

spread our program nationwide.The pattern

is being repeated

for the reduction

of greenhouse

gases from thelightduty vehicle

sector. Nationwide

adoption

of California's

measures

increases

the •mpact by nearly a factor of I0. The situation

with the electric power sector is somewhat

different

because

of greater geographical

differences

than is the case with light-duty

vehicles.

California historically has had relatively

low carbon electricity.

To reduce the carbon content of our electricity

further,

we have adopted

multiple

measures:

a 33% renewable portfolio standard,

a cap-and-trade

program,

low carbon fuel standard,

and, to reduce the impact of carbon remaining

in our electricity,

efficiency

standards.

Two other western

states and two Canadian

provinces

are coordinating

their efforts with US.g•(ational l•'mgram,

using EPA's authority

under the Clean Air Act, in kt• simplest form, should include:1) A fuel and technology

neutral,

performance-based emission

standard

that includes carbon dioxide

and the so-called

short-lived

greenhouse

gases. 2) Averaging

across an electricity

provider. 3) Credit for reduced

consumption

through

efficiency

improvement.Remarks for the Environmental

Protection

Agency

Public

Listening

Session

on 111 (d) Carbon

Pollution

Standards

for Existing

Power

Plants Kenneth Gibson

November

5, 2013 EPA Region

9 Office

San Francisco Regional Administrator

Blumenfeld Air Division

Director

Jordan Ladies and GentlemenThe current

work of the Environmental

Protection

Agency

today is, once again, critically important to demonstrate

the determination

and commitment

of one of the world's

largest economies to protect

the life of the planet.

It is critical

that this Agency

make clear to the major players

in the global economy

that a change

of direction

in the production

and use of energy is irrevocably

at hand. To date, regrettably,

the United

States has been derelict

in its obligation

to contribute

to global leadership

in the effort to slow, stop and redress

global warming.

The peoples

of the world, including

our own, have suffered,

and will suffer more as a result. The EPA and the other agencies

of government

allied on the new Council

on Climate

Preparedness

and Resilience must move all levers at their disposal

stop and reverse

global warming

without sacrificing the environment

in other, equally

dangerous

ways. It is clear that the United

States cannot

continue

to produce

10 times the GHG emissions

per capita that the world as a whole produced

in 1990. Nor can Europe

continue

to do so. If we are to lead the world back an average

CO2 equivalent

emissions

rate of 2 tons per capita we must set dramatic

change

in motion.

We must make it clear to all sectors

of the economy

that carbon-based-fuel-fired, base-load,

power plants are no longer acceptable.

Clearly,

no new ones will be built and old ones must be retired at a rate of 5% to 10% of the existing

fleet per year. The EPA must send the message

that coal and fuel oil are not acceptable

fuels for power plants.

Natural

gas should be viewed

as an energy

source acceptable

only for peaking needs over the next 10 to 15 years and only for unplanned

emergencies

after that. At the same time the EPA must be prepared

to defend

U.S. citizens,

and by extension

and example, people

around

the world,

from the risks associated

with all stages of the nuclear fuel cycle. Uranium

mining

and milling

is unsafe,

nuclear

power plants present

unacceptable risks and we are unable

to "dispose"

of spent fuel safely. No new nuclear

power plants should be built anywhere.

Current

nuclear

power plants should be retired

at the expiration

of their current

licenses

or earlier if they are threatened

by errors of siting (earthquake

faults or tsunami) or the weather

effects

of climate

change. If the EPA and allied agencies

make it clear that a new course must be set for the production, conservation and use of energy

the private

sector and other governments

will respond.Based

on reasonable

estimates

(made conservatively

by me and by others)

it is clear that the wind resource

of the United

States

the Great Plains,

the Great Lakes,

the Northwest,

the Pacific Offshore

and the Atlantic

Offshore

is sufficient

to meet all current

U.S. energy

needs for light, heat, entertainment

and transportation.

The solar resource

available

in the Southwest and much of the Southeast

offers a substantial

supplemental

contribution

of predictable power.

Solar resources

throughout

the country

can contribute

energy

to the grid
on a distributed

basis.Wind turbine

generators

optimally

sited in the regions

mentioned

above can meet all U.S. energy demand.

Concentrated

photovoltaic

generating

systems

optimally

sited as mentioned above can provide

a supplemental

resource

at mid-day

when winds tend to slack and to meet demand for cooling.Therefore the EPA should not yield to the argument

that we need coal-fired

power plants or nuclear power plants to meet our basic energy

needs. What is needed

is a clear signal to utility sale power companies

and to the oil and gas energy companies that the time for renewables

is now. Well sited wind power is already

cheaper than new-building

power plant of any other type. Solar CPV and PV are already

cheaper

than new-building nuclear

power.

Those old technologies

are dead for growth.

As the EPA demands automobile

mileage

greater

than 50 miles per gallon the oil and gas sector will also be dead for growth.

Traditional

energy

companies

will redirect

their vast investment resources to clean electric

power. When the United

States makes a commitment

to this new path, other countries

that claim the mantle of leadership

will walk beside us. Countries

that do not take steps to bring their level e necessary

g• should be subjected

to tariffs on their exports.

We can do this. Help make it so.EPACarbon Pollution

Listening

Session Tuesday, November

5 th 2013 Testimony- Michael

Bosse 3 minutes

to 3:30 minutes Good afternoon.

My name is Michael

Bosse and am the Deputy National

Program

Director

of the National

Sierra Club. appreciate

the opportunity

to speak to you today about why the Sierra Club strongly

supports

the EPA's effort to tackle carbon pollution

from existing power plants. These critical safeguards

will be an important

and historic step toward addressing

what believe to be one of the greatest

and most daunting

challenges

of our time global climate disruption.

am a regular Bay Swimmer

and a proud member

of the San Francisco's

South End Rowing Club, which, having been established

in 1873, is one of the few Bay Area organizations

older than the Sierra Club. As a member

of these two long-lived

organizations

am here today to urge the EPA to do its utmost to address

the urgent problem

of climate disrupting

carbon pollution. Climate disruption

represents

a threat not just to distant polar bears, but to communities

and ecosystems nationwide.

Here in the bay area, the enduring

swimmers

who take to the Bay's frigid waters year round our local polar bears also now need to contend

with planning

for sea level rise due to the warming

of the planet. We may be able to move or jack up our swimming club as the seas rise or perhaps,

despite our longevity,

our limited resources

as a public club will be too little to adjust. However,

our rowing and swimming

club is very much the tip of the iceberg. A warmer

world will mean changes

that many will not be able to easily adjust for: more extreme weather,

reduced

crop yields and water shortages

and intensified

precipitation

events such as hurricanes

with storm surges and flooding.

This will cost us lives and livelihoods,

and also hurt our economy

by costing billions of dollars in damages. The Sierra Club applauds

the EPA's efforts to limit climate pollution

from coal-fired

power plants and address

the impacts

of climate disruption.

This is a once in a generation

opportunity

to address the single largest stationary

source of climate pollution

in the United States. would also like to talk about the proposed

carbon pollution

standards

for existing gas plants. If these standards

are propagated

in line with the recently

proposed

standards

for new natural gas plants they will fail to significantly

reduce climate pollution

from natural gas plants and the EPA will miss the opportunity

to fulfill the President's

climate promise

of putting this country on a path to generating

electricity

in a way that will not harm future generations. On October

24th on the PBS Newshour,

EPAAdministrator

McCarthy

talked about the EPA's role in regulating

natural gas as ensuring

the President's

goal that it be "safe and responsible". What does "safe and responsible"

mean for existing gas power plants? "Safe and responsible"
means carbon p011ution.standards

that ensure those plants are si_•nificantly

reducing

climate disrupting carbon pollution

immediately.

To propagate

a standard

that does not achieve significant reductions

in carbon pollution

from existing gas plants would be a missed opportunityto

ensure the President's

legacy of putting this country on a path to avoid the worst forms of climate disruption.Remember, too, that burning 'more natural gas .inevitably

means more drilling and fracking

and more climate pollution.

In fact, a recent UT Austin study found that greenhouse

gas emissions from fracking

for gas alone were equivalent

to 10 million cars on the road each year and that's just the pollution

from fracking,

not counting

the emissions

when the gas itself is burned or leaks along transport

lines. Those life cycle emissions

make strong carbon pollution

regulations

for existing gas plants even more of a necessity.

That's what "safe and responsible"

means. From my 140 year old rowing and swimming

club to all of us who live around this beautiful

bay
so vulnerable

to sea level rise, we applaud

your efforts to address

climate pollution

and urge EPA to move forward quickly with this critically

important

standard.

Thank you.EPA

TestimonyCarbon Pollution

Standards

for Existing

Power

Plants Listening Session,

San Francisco

EPA Tuesday, November

5, 2013Speaker: Andr•e

Duggan,

Interfaith

Power

& Light Position: Pro safeguards

Good morning.

Thank

you for the opportunity

to present

testimony

for the EPA's listening

session

on Carbon

Pollution

Standards

for Existing

Power Plants.My name

is Andree

Duggan,

and I'm the National

Campaigns

Manager

for Interfaith Power

& Light, based

in San Francisco.

We are a grassroots, interfaith network

of 14,000

congregations,

in 40-states,

reaching

an estimated 5 million

of people

of faith. Together

we are a religious

response to climate

change,

and we heartily

support

EPA safeguards

that will reduce carbon pollution

from existing

power

plants.
In my capacity

as National

Campaigns

Manager,

work with congregations

of all major

faith traditions

that are gravely

concerned

about

climate

change and the world

that we're

leaving

to our children

and grandchildren.
We know that carbon

pollution

is unequivocally

causing

global

warming.

can tell you that over the years,

thousands

of clergy

from across

the United States have given climate

sermons

and talks to millions

of people

in the pews about the importance

of taking

personal

responsibility

in protecting

the climate and God's

Creation,

and urging

them to reduce

their carbon

footprint by transitioning

to clean,

renewable

energy. Every February,

we hold a Preach-In

on Climate

Change.

This year, President Obama received

37,000

Valentines

for Christians,

Jews, Muslims,

Buddhists, Unitarians, and people

of just about

every other faith tradition

all urging him to "Love the Earth"

and to act boldly

on climate

change.We

commend

the President's

response

to the public's

outcry

and the scientific facts about

global

warming.

This summer

the President

released

his Climate Action

Plan, and on Friday

he announced

the creation

of the Task Force on Climate

Preparedness

and Resilience

made

up of state,

local and tribal leaders

from across

the country.
We stand behind

the President

and we stand behind

the EPA's Gina McCarthy. And we support

their efforts

to steer this Titanic

country

of ours out of harm's

way before

it's too late. And we not only support

them in words, we support

them in action. Through our many programs,

Interfaith

Power

& Light congregations

are not only talking

about

climate

change,

they are doing

something

about.it

by rolling up their sleeves,

swapping

out light bulbs,

putting

in insulation,

adding solar panels

and geothermal,

adding

bike racks even. All in an effort

to preserve a future

for all of God's

Creation.

They are doing their part. T.hat's why they are so passionate

about

industry

doing

its part. Do you know that many of our congregations

won't

see a positive

return

on their Iongterm financial,investments for 20 years.

But they don't care. They have a higher moral calling

andthey're

willing

to make sacrifices

so our chilclren

have a future, and have a place to call home

in 20, 30, 50 years down the road. Members of Interfaith

Power

& Light, the clergy,

the congregants--the ones doing the hard work--don't

have a lot of patience

for shirkers. They are updating

their very old, historic

congregations

and they expect

the nation's Behemoth

and polluting

fossil fuel burning

plants

to do the same. We all need to meet this challenge

together

so when

our children

look back, they will know that we did our best, thank you for listening

to my testimony

today.Interfaith Power & Light

A Religious Response to Global Warming

EPA Listening

Sessions

on Existing

Power Plant Rule Those scheduled

to speak get 3 minutes.

Session

times and online registration

available

at: http://www2.epa.gov/ca rbon-pollution-standards/pu blic-listening-session-registration
You may also submit written input by November

8, 2013 to: carbonpollutioninput@epa.gov BackgroundDraft Emission

Guidelines

for reducing

carbon pollution

from existing

fossil fuel power plants are due to be proposed

by the Environmental

Protection

Agency

(EPA) in June 2014, finalized

June 2015. States will have until June 2016 to complete

plans providing how the required

emission

reductions

will be achieved

in each state. EPA is setting carbon pollution

standards

for new and existing

power plants in two separate rulemaking

processes.

Carbon

standards

for new power plants were proposed in September

2013. Suggested Talking Pointsurge the Environmental

Protection

Agency

(EPA) to move forward

with safeguards

for existing power plants so that we can reduce carbon pollution

as quickly as possible

to address climate change,

protect human health, and care for all of Creation. Interfaith Power & Light (IPL) is helping

congregations

become

models

of energy stewardship. We've reduced

our carbon pollution

while saving money for other critical needs. We've shown that it can be done. But we know that our actions alone will not be enough

as power plants are responsible

for about 40% of carbon pollution

in the U.S. Therefore,

support

strong Carbon Pollution

Standards

for Power Plants.

• As a person of faith, believe it is our moral responsibility,

for the benefit of our neighbors and children's

future, to care for all that has been entrusted

to us.

• As people of faith, we believe that the world around us was given to us as a gift to tend and keep and that we are called on to care for the "least among us." Yet, fossil fuelpower plants are the single largest source of climate pollution

in the US, most often located in poor .communities. The costs of inaction

are already

apparent:

worsened

air quality which means more asthma attacks for our kids; increased

transmission

of infectious

diseases

from insects, food, and water; and increased

impacts

from extreme

weather

including

floods, storm surges, and wildfires.

0 Millions

of Americans--including people

of faith, businesses,

health

and environmental groups,

morns

organizations,

Latino groups,

and others--support strong carbon limits for power plants. There are currently

no national

carbon limits for power plants. Those who oppose these common

sense standards

need to explain why they support

no limits at all on this kind of pollution

from power plants. Wouldn't

we all agree that unlimited pollution is bad for everyone?