Comments to the US Environmental Protection Agency on the proposed 

Carbon Pollution Emission Guidelines for Existing Stationary Sources: 

Electric Utility Generating Units 

Docket ID #: EPA-HQ-OAR-2013-0602 

Submitted by Richard Nunno 

Sierra Club, Washington, DC Chapter 

30 July 2014 

Good evening EPA leaders and staff. I am a member of the board of the DC Chapter of the 

Sierra Club. We advocate for progressive change on a wide range of local issues affecting the 

Washington, DC community. These include increasing energy conservation and promoting 

renewable sources of energy in DC, supporting the National Sierra Club's Beyond Coal 

Campaign, supporting weatherization of homes and buildings, and promoting legislation for 

smart energy policy. We also have extensive efforts underway in the areas of transportation 

and smart growth, zero waste legislation and policy, environmental justice, and lowering the 

carbon footprints of individual citizens. 

Our Chapter and our Club as a whole support the EPA's efforts in general to regulate gases that 

contribute to climate change, and in particular its Clean Power Plan. 

• As the most urban Sierra Club chapter in the nation, our constituents are exposed to the 

harmful health effects of dirty energy more so than most state-based chapters, and we 

are acutely aware of the risks of failing to reduce the nation's and the world's carbon 

output in terms of environmental degradation and increasing environmental 

catastrophes. 

• Power plants account for 40% of the carbon pollution in the United States, and most 

urban dwellers live in areas where the air is unsafe to breathe, making the Clean Power 

Plan a critical step to reduce those risks. 

• The Plan will prevent thousands of asthma cases and premature deaths annually, and 

will drive innovation in clean energy sources, growing the economy and creating jobs. 

• From the soot and smog reductions alone, each dollar invested in the Plan will net 

Americans $7 in health benefits. We cannot afford to fail to regulate carbon pollution. 

• While some states like West Virginia have a long way to go to meet the proposed 

standard, they will have a full decade before they would have to show progress, and 

initial improvements will be far easier for West Virginia than for other states that have 

already made progress. 

• We embrace the idea that the Plan is designed to shift the nation away from coal, and 

we oppose the idea of ramping up the coal industry for export to China and India. And 

the vast majority of Americans agree with us. 

• Indeed, the proposed Plan does not do enough in protecting the health of the front-line 

communities that are exposed to the hazards of coal mining and burning, but it is a good 

first step toward the ultimate goals. 

• To repeat the words from Senator Markey's speech at yesterday's rally, "You can't 

preach temperance from a bar stool" to the rest of the world on climate change. We 
need to wean off of coal, oil, natural gas, and nuclear energy, and ramp up our use of 

renewables along with improving our energy efficiency by orders of magnitude to 

forestall a climate crisis. It is only fair to future generations to act responsibly now. 

• If we don't take action at the national level, it will be impossible to convince other 

nations to do so. 

• The time is far overdue to end the corporate control of our energy policy and to take 

actions in the best interest of our citizens oftoday and the future. 

Thank you for the opportunity to share my views. 

Richard M. Nunno 

3539 13th St. NW 

Washington, DC 20010 

(202)361-6164