Testimony regarding EPA's proposed Power Plant revisions. 

My name is Randy Cunningham, I live at 3623 West Blvd, Cleveland, Ohio 44111. My phone 

number is 216-245-1073. I am chair of the coal and energy committee of the Northeast Ohio 

Sierra Club group, and a member of the Cleveland Environmental Action Network. My views 

expressed here are my own. 

I wish to speak in favor of the proposed standards. Their primary virtue is that they are the first 

steps we have seen in dealing with the issue of climate change since the disastrous collapse of 

climate legislation in Congress during the summer of 2010. They will buttress our negotiating 

position at the next UN conclave on the climate. They are at least something in a policy 

environment that has offered us nothing. Their primary vice is that they are nowhere near 

what it will take to protect us from the consequences of climate change. But we should not let 

the good get in the way of the inadequate. 

That inadequacy is shown in what they do not take into consideration - the revolution in fossil 

fuel production that has been brought about by the advent of fracking for oil and natural gas, 

mountain top removal coal mining, tar sands development of northern Alberta and Deep Ocean 

oil production. This revolution produces coal, oil and natural gas from sources that were long 

written off as technically unfeasible or economically unprofitable. It is frequently called 

extreme energy. I call it berserk energy because an energy regime that blows the tops off 

mountains, strip mines a whole region of North America, ruins aquifers, and turns the Gulf of 

Mexico into a dead zone is berserk. 
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One problem of the proposed standards is that they only pay attention to what happens once 

the fuel source gets to the power plant. They do not consider the whole process from 

extraction to combustion. Fracking illustrates this problem. It is during the process of fracking 

that the case for natural gas as a more environmentally friendly form of fossil fuel begins to fall 

apart. There is the release of potent methane gas at drill sites, and the poisoning of air and soil, 

aquifers and streams from the byproducts of drill sites. Fracking also pollutes our democracy 

with fracking exemptions to home rule, the flooding of state legislatures with money, the 

coopting of regulatory agencies and the use of gag orders to silence those who have been 

harmed by fracking wells. 

Next we should consider natural gas as a bridge fuel to a renewable energy future. I don't 

know what is worse — the gullibility of those who believe this lie, or the mendacity of those who 

promote it. The bridge is a bridge to nowhere. The producers have no intension of helping a 

transition to renewable energy that will put them out of business. 

When the EPA promotes natural gas production from fracking as a way to deal with climate 

change because it does not release as much carbon as coal, it is acting like an alcohol treatment 

program that urges its clients to sober up by giving up vodka and whiskey, and switching to 

beer and wine. After all beer and wine do not have as high an alcohol content as vodka and 

whiskey. 

Another problem is that the proposed standards use as a guide line the overall efficiency of 

emissions per unit of energy generated. This dove tails nicely with the administration's energy 

mantra of all of the above which really means the same old, same old. The standards should 
prioritize renewable energy sources over traditional fossil fuels. We need to mobilize for a 

transition to renewables as we mobilized to fight World War II. Then we would be able to call 

this a serious policy initiative on climate change. 

To end, we must inject a sense of moral urgency into the debate on this proposal. If you saw a 

toddler wandering into traffic, would you text its parents, or would you rush to pull the child 

from harm's way. We need that sense of urgency with the climate challenge we face. Simple 

moral decency and the well-being of those who come after us, demands it. 

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