of God's Creat:ion 

July 30, 2014 

Testimony of Jaydee Hanson, Secretary of Caretakers of God'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 a global warming world . 

Caretakers of God's Creation is a network of United Methodists working around the world to help 

United Methodists be faithful stewards of the Earth. We do not speak for The 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 of The United Methodist Church from Africa, Latin America, Asia, and the United States in 

2009 issued a pastoral letter to all our churches, called "God's Renewed Creation." This letter declared 

that the United States has a special responsibility as it consumes more than 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 government to do better. The 

Caretakers of God's Creation is a lay and clergy movement inspired by the bishops' letter and we will 

like, the bishops, push our churches and the government to a better job 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 of coal 

was contributing to global warming, but cautioned that using nuclear power to replace coal fired plants 

was not the 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 "We strongly advocate for the priority of the development of renewable energies. The 

deposits of carbon ... resources are limited and their continuous utilization accelerates global warming. 

The use of nuclear power is no solution for 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 that the EPA is 

proposing too 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 of these 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 meet the emission targets for power plants in many ways, including 

Caretakers of God's Creation 

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upgrading 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 for the first time that nuclear power is a core element of the 

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 of Caretakers for God's Creation has actively opposed the development of uranium 

mining in Virginia. The inclusion of nuclear 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 of nuclear 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 

to the contrary. Sustainable solutions are our most cost-effective and practical resources for protecting 

the climate AND replacing nuclear power. Nuclear power should not be included in any cap and trade 

programs or ever 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 allow those old 

aging plants to pollute more than they would with real controls on each plant. 

According to a joint study by the Harvard School of Public Health and the Syracuse University Center for 

Health and the Global Environment, "Carbon pollution standards for existing power plants would not 

only help confront the challenge of global climate change, they would confer substantia/local and 

regional benefits by reducing power plant emissions of these major co-pollutants by up to 27 percent for 
sulfur dioxide and mercury and 22 percent for nitrogen oxides" by 2020 . . 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 of coal, which would reduce the number of asthma cases, 

other respiratory diseases and heart attacks which impact poor people disproportionately, but targeting 

individual power plants for reductions would reduce the pollution load for those 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 off the table entirely. 

Nonetheless, we greatly appreciate the EPA for tackling 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.