Statement of Jennifer Cassel 

Staff Attorney, Environmental Law & Policy Center 

Public Hearing on the Environmental Protection Agency's 

Proposed Carbon Pollution Standard for New Power Plants 

Chicago, IL, May 24, 2012 

I appear here today on behalf of the Environmental Law & Policy Center to support the 

Environmental Protection Agency's proposed carbon pollution standards for new power plants. 

These standards represent a critical milestone: they are the first ever national carbon pollution 

standards for power plants, our nation's largest emitters of carbon dioxide. These standards will 

protect public health and the environment, and they will give the great wheels of American 

innovation a big push, spurring development of better, cleaner technologies to spark our 

economy and power our country for generations to come. It comes as no surprise that over I 

million people have already submitted comments to EPA in support of these standards. With 

more than a month left in the comment period, surely countless more Americans will make their 

voices heard in support of these essential new standards. 

Scientists agree that greenhouse gases, including carbon dioxide, cause climate change, 

and the impacts of climate change are many, sometimes severe, and they are already happenin[;. 

For example, the evidence linking climate change to extreme weather events is rapidly mounting. 

The shifts in temperature associated with the changing climate can change the amount of water 

vapor in the atmosphere, and this can lead to major changes in the probability for extreme 

weather. In 2008, 2010 and 2011 -three times in four years- there were" 100-" or "500-year" 

floods in Iowa, Missouri and Wisconsin. As the Union of Concerned Scientists has explained, 

floods such as those don't only damage property; they also can contaminate our water with 

chemicals, animal wastes, and sewage, making people who drink or swim in that water sick, and 

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fill our soggy basements with mold, creating and exacerbating respiratory problems. 1 And 

floods are just one example of extreme weather events associated with climate change. Droughts 

have been connected to climate change, 2 and scientific models are starting to suggest that 

disasters like the 2010 Russian heat wave, which resulted in the loss of 50,000 human lives and 

billions of dollars of wheat crops, were likely related to human-induced climate change. 

These EPA standards will limit the carbon emissions that lead to climate change and set 

good things in motion. For example 

• They will create jobs. A March 2012 study by the Department of Labor found that the 

transition to cleaner energy and technology already has created 3.1 million jobs3 As we 

move from carbon-intensive electricity generation toward increased production of 

cleaner, renewable energy, even more jobs will be created. 

• They will improve our nation's security. Further research and development into cleaner 

electricity generation, spurred by these standards, will help our country become more 

energy independent and help our military minimize the dangerous transport of fuel in 

combat zones, which has claimed the lives of many of our troops 4 

Midwesterners have long recognized the harmful impacts of climate change, and have begun 

implementing a diverse array of measures to keep those harmful impacts, and climate change 

itself, in check. The Chicago Climate Action Plan, the Iowa Climate Report, and the Wisconsin 

Initiative on Climate Change lmpacts5 are just a few of such programs. These standards will 

complement and bolster those critical efforts. 

Importantly, EPA is well within its legal authority in issuing these landmark standards. As 

ELPC will further discuss in written comments, EPA's decision to set standards for power plants 

1 Union of Concerned Scientists, "After the Storm: The Hidden Health Risks of Flooding in a Warming World" 

(March 2012 ). available at hup .. -.. , 1 11 n lfL"!L'>tt \_ll :.;..- :t:---..ch: d(1L.llll!'-'11h:\doh;J! 11 :tr tum~.-, .. :!nnal, .. :-...:ll:Jn!-'...:-;11\d-!luudi n~> 

'-'_'\<...:L-"1!!11111 pdl (last visited May 23. 2012). 2 See lPCC. "Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation" (2012). 

available at hup \\11 \\ tp...:vnc:~ ~.,~~~ Sf{ L\_ ·lJH:I."'.-..:".·uplu:ld::-. S!H-._\-SP\lh\1;.,_-!HHC r· I\ -\L pdi' (last visited May 23, 

2012). 

3 llup 111111 hh _>!.\.)\ 'JhYI'> r:.:Lh~..:·jxlt -~·"'.q---:l."\1 pdl'(last visited May 23. 2012) 1 See Natalie Pompilio. Yes Magazine. ''Tile Real Reason the Military is Going Green" (summer 2012) 

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based on function, rather than fuel type, is a welcome and authorized manner to ensure that new 

power plants use the best technology to minimize climate-changing carbon emissions. 

Moreover, the law is clear that EPA may rely on reasonable forecasts of the types of plants that 

will power our future, and reasonable forecasts of the types of technologies available to control 

pollution from those plants, in setting new source performance standards. EPA has done that 

here. The market has spoken in favor of a lower-carbon future, 6 and EPA's proposed standards 

mark an important first step in ensuring that future becomes a reality. 

Thank you. 

6 See sources cited by Lashof, "Financial Analysts, Private Economists_ and Government Forecasters All Agree: 

Market Realities, Not EPA, Driving New Power Plants Away from Coal," April 2012, 

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