# of God's Creat:ion

July 30, 2014 Testimony ofJaydee Hanson, Secretary ofCaretakers ofGod's Creation on the EPA Draft Carbon Reduction Rule for Coal Fired Power Plants As Christians, we are taught by Jesus to love God and to love our neighbor. Today, loving God means Caring for God's Creation so that our neighbors around the world can survive in aglobal warming world
. Caretakers of God's Creation is a network of United Methodists working around the world to help United Methodists be faithful stewards ofthe Earth. We do not speak forThe United Methodist Church, but are faithful United Methodists informed by our Church's Discipline and Resolutions as they speak to Caring for Creation. The bishops ofThe United Methodist Church from Africa, Latin America, Asia, and the United States in 2009 issued a pastoral letterto all our churches, called "God's Renewed Creation." This letter declared thatthe United States has a special responsibility as it consumes morethan its fair share of resources and generates the most waste (including carbon dioxide pollution). The bishops from the US committed themselves to working to reduce this pollution, including urging the US governmentto do better. The Caretakers ofGod's Creation is a lay and clergy movement inspired by the bishops' letter and we will like, the bishops, push our churches and the governmentto a betterjob caring for God's Creation. The United Methodist Church has been long concerned about pollution that comes from coal fired power plants. In 1980, the Church warned in its Energy Policy Resolution that large scale burning ofcoal was contributing to global warming, but cautioned that using nuclear power to replace coal fired plants was notthe answer either
. In its most recent (2012) General Conference, the Church voted into its Discipline, the Church's law book, new language on "Energy Resources" (The Book of Discipline,

**~160,** § C) which proclaims 

### "Westrongly advocatefor thepriority ofthe developmentofrenewable energies. The deposits ofcarbon
...resources are limited andtheircontinuous utilization accelerates global warming
. The use of nuclearpoweris nosolutionfor avoiding C02 emissions
." We agree with EPA Administrator Gina McCarthy, who said in announcing the new coal fired power plant rules that "We have a moral obligation to act on climate." We are concerned thatthe EPA is proposingtoo little. The new rule does not require the nearly one thousand coal fire power

**plan~s** to actually clean up their pollution. More than 60 percent ofthese power plants are some 40 years old. Instead, the EPA rule would have states develop their own plans that would not be implemented until at least 2016. The states could meetthe emission targets for power plants in manyways, including Caretakers of God's Creation 475 Riverside Dr
. Room 1413 New York NY 10115 212-870-3560 1upgrading old inefficient plants, switching to natural gas, improving energy efficiency elsewhere in the state and promoting renewable energy. Nuclear Power is NO SOLUTION. Unfortunately, the draft rule also declares forthe first time that nuclear power is a core element ofthe nation's climate policy and pushes states to preserve old nuclear power plants, expand existing plants and subsidize nuclear power. These pro-nuclear provisions could undermine the growth of renewable energy in these states and help keep open old polluting coal fired plants. The Virginia chapter ofCaretakers for God's Creation has actively opposed the development of uranium mining in Virginia. The inclusion ofnuclear power in the EPA rule will only serve to encourage those who want to open a huge uranium mine in Virginia. Unlike the arid Western United States, tailing ponds in Virginia are expected to fill rapidly with rain water and will likely overflow in Virginia and North Carolina waters. This draft rule also ignores the other environmental impacts ofnuclear power: • It disregards the vast water consumption of nuclear reactors. • It dismisses the production of radioactive waste as an environmental concern. • It ignores the extreme toxicity and radiological contamination from uranium mining and processing entirely. The EPA sells our best climate solutions short by assuming that renewable energy, efficiency, energy storage, and conservation cannot grow fast enough or play a large enough role, despite all the evidence tothe contrary. Sustainable solutions are our most cost-effective and practical resources for protecting the climate AND replacing nuclear power. Nuclear powershould not be included in any cap and trade programs orever considered "clean energy".

ENVIRONMENTAL JUSTICE Calls For Controls on Individual Power Plants By side stepping controls on individual polluting power plants, the EPA draft continues to allowthose old aging plants to pollute more than they would with real controls on each plant. According to ajoint study by the Harvard School of Public Health and the Syracuse University Center for Health and the Global Environment, 

### "Carbon pollutionstandardsfor existingpowerplants wouldnot onlyhelp confrontthe challenge ofglobal climate change, theywouldconfersubstantia/localand regional benefits byreducingpowerplantemissions ofthesemajorco-pollutants byup to27percent forsulfurdioxide andmercuryand22 percentfornitrogen oxides"by2020
. .The study said the greatest benefits would come in the Ohio River Valley and the Rocky Mountain region.
The EPA draft would reduce the overall use ofcoal, which would reduce the number ofasthma cases, other respiratory diseases and heart attacks which impact poor people disproportionately, but targeting individual power plants for reductions would reduce the pollution load forthose groups in the most certain way.
In short, we wish the EPA draft targeted the most polluting power plants in a more direct way, promoted renewable energy even more strongly and left nuclear power offthe table entirely. Nonetheless, we greatly appreciate the EPA fortackling the most wrenching environmental problem of our age, namely the huge contribution fossil fuel fired power plants make to our nation's carbon dioxide pollution.