COMMITTEE ON ENVIRONMENT AND PUBLIC VVORK;S 

Novemb• 6, 2013 

Administrator G:_na McCarthy 

Environmental Protection Agency 

1200 Pennsylvania Ave., NW 

Wa.•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]mirman 

Poll' Rich 

Subject: 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 y g • Let's ho •, pJ• el" i$ p • w real world •, 

Priscilla Rich, founderExpress 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 2859518.h,tml the back story on 

the •lacobson et al studi •, state by statea to g• 100% renewable • •• •K• I • • • I ,• 

Poll•/Rich 

Subject: 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 CampaignAwards- 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% renewable 

Unionof Concerned Scientists o o 

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 our heattrapping 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 Paper 
Unionof Concerned Scientists • o 

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 Paper 
I'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, com 

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. 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 Plants 

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. 

Meeting location 

National 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•$ O0 

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 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 Plants 

November22,2013 

Sharon 

Enclosed 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, 

RaySaracino 

saracino.ra•@e•a.•ov 

4•5-972-3•6• 




b 
OAKLAND 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 9 

75 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.org 

LEAGUE 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 Street 

Suite 300 

Sacramento, CA 

95814-3608 

916 442.7215 

888 870.8683 

916 442.7362 fax 

lwvc @lwvc.org 

W•,•V.IWVC.O rg 

•,vw.smartvotel:.org 

www.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 Ln 

Los 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•£'IS 
These 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•,oO f-•-•'/'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:mbeR 
EPA 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 11/05/2013 

Not 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, Nearly three-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% CI 

STATEMENT 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 and costeffective 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 

1 
must 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. 

2 
I 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 Allen 

Statement 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 Olson 

57 Thousand Oaks St. 

Oakland, CA 94605 

doug@the-olsons.org 

(510) 220-3420 

retired 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 the lightduty 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 Gentlemen 

The 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 opportunity 
to 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 Testimony 

Carbon Pollution Standards for Existing Power Plants 

Listening Session, San Francisco EPA 

Tuesday, November 5, 2013 

Speaker: 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 

Background 

Draft 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 Points 

urge 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 fuel 
power 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?