1 From: Girard Gurgick [ggurgick@gmail.com] Sent: Tuesday, November 12, 2013 5:08 PM To: Carbon Pollution Input



### We have a serious problem with financial structures and risk allocation - not tools and techniques.

C onsider the following two approaches to implementing energy efficiency and carbon footprint reduction

In the MUSH sector:

The US Chamber of Commerce endorses energy service contracting and the Chamber has encouraged the government to vigorously engage in ESCO contracting. It is inherently obvious that the long term ownership of property, assumed with government owned real estate, affords properties owned by the Federal Government and MUSH Sector (Municipalities, Universities, Schools and Hospitals) a long term financial view that promotes the engagement of an ESCO and allows the owner to gain from the utilization of the ESCO’s expertise and their financial services for terms that promote real efficiencies.

In the private sector:

There is no long term view.

Why not allow homeowners and small business the same opportunity available to the MUSH sector? It is time to end the discrimination of FHFA agencies regarding PACE Property Assessed Clean Energy loans. It is time for the EPA, the DOE and FHFA to work out administration of a national insurance plan, if need be, to end the miniscule risk to FHFA for PACE loans. The biggest obstacle to homes and small businesses getting truly energy efficient is the capital risk aspect, the exact same risk avoided by FHFA by nullifying this program.

For a total investment of $45,000 I could go from 14,000 lbs of CO2 to 1,000 pounds by adding geothermal and about $17,000 worth of solar panels. What’s stopping me? The risk and the lack of PACE financing. I would do this immediately if not for the long term paybacks required. Will I get my investment back? The answer with PACE is yes and without PACE it’s no.

As an alternative to PACE, perhaps it is time to create a negawatt utility with the same powers as a regional utility in terms of bill collection, financing, capital formation, regulated profits, expertise. If conservation cost 3 cents per kWh and A new plant cost 9 cents/kWh how do we take advantage of all the conservation before we invest in any new power plants?

We have a serious problem with financial structures and risk allocation - not tools and techniques.

Thank You!

G irard J. Gurgick, P.E., BSCE, MBA, President 

# G **2** 

# EM

43883 Stronghold Court2 Ashburn, VA 20147-3919 

### GGurgick@GSquaredEM.com http://www.GSquaredEM.com http://www.linkedin.com/in/girardgurgick

C: 703 302 99443 From: Ben Kolstad [benkolstad@gmail.com] Sent: Sunday, November 03, 2013 3:17 PM To: Carbon Pollution Input Subject: Clean Air Act: Carbon Pollution Standards need to address Light Pollution as well



### Dear EPA.

I’d like to remind you, as you consider how the Clean Air Act can address carbon pollution from existing power plants, that a significant portion of our existing energy budget (and hence our energy pollution footprint) goes to wasteful and even harmful outdoor lighting at night. Reducing pollution from existing power plants can be as simple as reducing the amount of wasted light cities pour into our skies.

Efficiency is only one part of the solution, however. We must also consider the nature of that outdoor lighting that we need. Certainly we all want safe highways and neighborhoods, and effective lighting at night has an important role to play, but we also need to consider the health effects to both human and other users of the built environment of the potential harm night-time lighting can cause. Light in the white or, commonly, blue, area of the spectrum has significant and substantial negative effects on human health (implicated in circadian rhythm disruption, melatonin production, and even various form s of cancer) and on wildlife populations, from birds and
turtles to insects and bats.

Please consider drafting a rule that requires both efficient and low-impact lights where night-time lighting is necessary. By low impact, I mean light in a narrow spectrum, preferably in the yellow or orange, and focused down on the street, where it’s needed, rather than horizontally or up. This simply shift can do a great deal to reduce both the negative effects of light pollution on human and wild life and its associated carbon footprint.

This simple step can help make sure that as we reduce our carbon footprint, we reduce our light-pollution footprint as well. The Clean Air Act might be the perfect place to address this; if it isn’t, it needs to work in concert with other regulatory structures to reduce both air and atmospheric pollution.

As an example, here is what my area, South Florida, looks like from space at night (the Google Earth overlay is just to get the county lines and other local landmarks on the map).4 

### Imagine how much carbon pollution can be reduced by reducing our light pollution:

The costs of night-time lighting are not just economic, an d they are relatively easy to figure out. you would like to calculate how much your lighting costs can be, you can try out this site at: Selene-NY.org . A variety of prices are defined for the New York are a, however, you can put in your own cost per kilowatt-hour to better reflect your own

u sages. Not only do they calculate the cost of running your lightbulb for the year (including prices due to their burning out), they also add in a number of other5 

### calculations as well. The site also calculates the amount of pollutants given off, the needed amount of coal to be consumed to support your light, the number of trees that would need to be planted to consume your CO 2 

### production, and others that may open your eyes to the true expense of the different types of light sources.

T hank you for your consideration of this comment.

Ben Kolstad
237 NW 7th St Boca Raton, FL 334326 From: Bernard Nadel [bobnadel2@inbox.com] Sent: Friday, October 25, 2013 1:44 PM To: Carbon Pollution Input Subject: FW: RE: The Perfect Fuel DON'T BE FUELED! My last attempt to solve your problem.



### - ----Original Message-----
From: bobnadel2@inbox.com Sent: Sat, 19 Oct 2013 12:31:38 -0800
To: info@kva.se Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

-----Original Message-----
From: bobnadel2@inbox.com Sent: Fri, 4 Oct 2013 13:41:31 -0800
To: desk@knesset.tv Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

The material herein is easily worth a trillion dollars but I am unable to get anyone of importance even to loo look at it I have decided to give it all, the patents, the prototype etc, to the state of Israel..PRO-BONO. .

I only hope Israel has the sachel to realize the implications one of which stopping global warming and the
hutzbah to act.

Bernard Nadel president Hydrogen One Inc. 804 438 6656

-----Original Message-----R : bobnadel2@inbox.com READ ON Sent: Fri, 11 Jan 2013 08:47:16 -0800
To: info@michellebachman.com Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

MY AD V

-----Original Message-----
From: bobnadel2@inbox.com Sent: Wed, 21 Nov 2012 08:45:02 -0800
To: info@barackobama.com Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!7 

### -----Original Message-----
From: bobnadel2@inbox.com Sent: Tue, 13 Nov 2012 09:49:33 -0800
To: editors@fierceenergy.com Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

Pop. Science Magazine " Boeing has produced a drone surveilance plane that runs on hydrogen and maintains a hieght of 65000 ft for 4 days before refueling becomes necessary, which take s but a few minutes." Why not run electric cars on hydrogen fuel cells.etc etc.I'll show you how to make the hydrogen economically. See below.

B-----
From: bobnadel2@inbox.com Sent: Sun, 28 Oct 2012 14:19:51 -0800
To: contact@wiseconvert.com Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

As long as we continue to use fossil fuels, hurricasnes will grow progressively worse. See below for the cure----

-

Original Message-----
From: bobnadel2@inbox.com Sent: Wed, 24 Oct 2012 13:44:19 -0800
To: info@barackobama.com Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

-----Original Message-----
From: bobnadel2@inbox.com Sent: Wed, 24 Oct 2012 13:02:19 -0800
To: secretary@hq.doe.gov Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

-----Original Message-----
From: bobnadel2@inbox.com Sent: Thu, 18 Oct 2012 13:28:26 -0800
To: letters@ibdeditorials.com Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

-----Original Message-----
From: bobnadel2@inbox.com Sent: Tue, 9 Oct 2012 12:28:42 -0800
To: info@sovereign-investor.com Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!8 

### -----Original Message-----
From: bobnadel2@inbox.com Sent: Fri, 5 Oct 2012 13:53:12 -0800
To: info@sovereign-investor.com Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

What ever you do . DO NOT INVEST IN OIL!!!!!!!!!!!!!!!!

-----Original Message-----
From: bobnadel2@inbox.com Sent: Sun, 23 Sep 2012 12:45:57 -0800
To: support@gobignetwork.com Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

-----Original Message-----
From: bobnadel2@inbox.com Sent: Fri, 21 Sep 2012 13:35:17 -0800
To: 60minutes@ty3.co.nz Subject: FW: RE: The Perfect Fuel DON'T BE FUELED!

THINK!

Fossil fuels are comprrised of molecules. A molecule is thousands of times larger than an atom. Hydrogen is the smallest of atoms, therefore one can gbet thousands of times more of them into a fuel tank than the fuels we are using.. So a tiny battery called a fuel cell could propel a vehicle greater distances between refueling and can refuel in just a few minutes, not hours and be on one's way. What emerges from the tailpipe is harmless water

vapor. Will someone please tell me what is going on here. Why can't we get on with saving the planet? The RX is staring us in the face an d we have a prototype to prove it. HAVE WE ALL GONE BLIND?

Th is just one of the many advantages to converting to a world fueled by hydrogen .
Hmmm
Please read on below.

-----Original Message-----
From: bobnadel2@inbox.com Sent: Sat, 1 Sep 2012 08:38:15 -0800
To: info@barackobama.com Subject: FW: RE: The Perfect Fuel9 

### -----Original Message-----
From: bobnadel2@inbox.com Sent: Fri, 13 Jul 2012 13:09:29 -0800
To: eletter@news.personalliberty.com Subject: FW: RE: The Perfect Fuel

-----Original Message-----
From: bobnadel2@inbox.com Sent: Wed, 11 Jul 2012 07:13:29 -0800
To: mail@wyattresearchnewsletters.com Subject: FW: RE: The Perfect Fuel

OIL..OIL SPILLS, GLOBAL WARMING COAL..BLACK LUNG, MINING DISASTERS..GLOBAL WARMING
NATURAL GAS.............GLOBAL WARMING
NUCLEAR..EVENTUAL RADIATION ARMAGEDDON
HYDROGEN..THE PERFECT FUEL WITH NONE OF THE ABOVE

-----Original Message-----
From: bobnadel2@inbox.com Sent: Mon, 9 Jul 2012 08:57:02 -0800
To: info@barackobama.com Subject: FW: RE: The Perfect Fuel

Fossil fuels are extinct, but Wall Street does not know it yet. We still haven't buried this stinking corpse. Biofuels also leave a carbon footprint and tend to spoil gasoline if not used within a short period of time so either one of these fuel alternatives are as dead as the dodo. Welcome to the new era of hydrogen with zero emissions in the production and zero emissions in its use as a fuel. What comes out of the tailpipe is water vapor. Please see below. Replace oil as a fuel with hydrogen and stop global warmig, oil spills etc. Oil is only good for lubrication. Who wants to be the first energy trillionaires? Stop! Do not pass GO.Go directly below. It will blow your mind! Speaking of skepticism, for two years now. I have presented the world with the perfect solution to all of their energy problems, but have been ignored just because it sounds too good to be true..See below. Subject: FW: RE: The Perfect Fuel

Build a better mousetrap and they will build a path to yo ur door" It won't happen if nobody knows about it. You have in your hands the power to save the earth from global warming, and all of the other ills we are encountering while seeking the green holy grail for cheap, clean energy. Please read on and do what you can to shine some light on an invention that will do just that. See below one more time.
l

What the world needs now is a fuel that is plentifull,inexpensive and non pollutive or radio active. The elephant in the room is Hydrogen. Hydrogen, the most plentiful element in the universe has more latent energy than gasoline and unlike gasoline or other fossil fuels does not burn and burn after an explosion; instead, there is water.Do we want oil spills,pollution and global warming? It is insane. A worse alternative is the planet's nemesis, nuclear power. For sometime now,radioactive tritium continues to be found in drinking water 50 miles10 

### distant from nuclear facilities and children who live near them are dying of leukemia..We have had several nuclear disasters and I am sure there will be more.When this happens, not only does it kill thousands of people who die horrible deaths but it makes large areas uninhabitable for hundreds of years ...and our population is growing. We also lose any ground wherein nuclear waste is interred; a growing problem. . We will need more living room, not less.,These structures of doom cost billions to construct and billions to deconstruct after a short life so nukes are not even economically practical,

It cost us more than ten cents per mile to drive our cars and considerably more to move our trucks and buses. With hydrogen, expect to pay two or three cents per mile. Replace those silly, dangerous lithium ion batteries with hydrogen cells. Then expect to run hundreds of miles between charges,recharge in just a few minutes, not hours, and be on ones way. What emerges from the tailpipe is harmless water vapor.This is just one of the ways to benefit from switching to hydrogen and saving the world from global warming. .

All well and good, but how do we produce all of that hydrogen without producing bad emissions in the production?

. If one wave can lift a battleship , . What could 1 trillion , trillion waves do? . It sickened me to witness all all of that wasted energy , so after a few sleepless nights I came up with hydro-generator (H G).

. HG is a teeter totter on steroids.It consists of a balance bar with 5 ton weights at it's opposite ends to act as resistance thereby accentuating the torquing energy it creates. The weights replace the necessity for an immoveable resistance wall at sea which is impractical to say the least .(HG) Comes equipped with departure bearings and gears arranged so that teeter tottering produces one-way rotation to torque a shaft that runs a generator..

No matter which way the teaters totter , they torque a shaft in a singular direction with virtually zero backlash
no matter how tremulous the movement.

In order to get the most out of that process we have to equip a rocking ship with with eight or more HGs torquing a universal shaft running from stem to stern with two generators one fore, one aft, generating DC current. Two wires from each immersed in brine from the sea would render a kiss of oxygen for the atmosphere at the anodes and hydrogen at the cathodes. Hydrogen would be stored below in vast. tanks When full,the ship would be sailed to a distribution point, would be unloaded and paid for .The profits from this would be used to build and outfit another ship and so on ad infinitum .Soon we would exceed Agememnon in ship deployment. While saving the world as we know it , we would also create, as a by product, our first trillionaire.

None of the above can ever happen without financing. We would require about $10,000,000.00 to pay for a specialized machine shop,a tugboat, a hull, raw material, 2 generators and labor. Most of these items have an intrinsic, recoverable value. The historic value? Priceless.!

Bernard Nadel...President Hydrogen One, Inc. 49 Reynolds Landing, Irvington, VA 22480

804 438 6656 bobnadel2@inbox.com

STOP SINKING JAPANESE GHOST SHIPS. WE NEED THE HULLS.11 

### To: mail@wyattresearchnewsletters.com Subject: FW: RE: The Perfect Fuel12



### Subject: The Perfect Fuel

Sent: Tue, 22 May 2012 11:57:02 -0800
To: info@sovereign-investor.com Subject: FW: RE: The Perfect Fuel

From the guy who predicted that Qaddafi would be replaced by a Muslim president or dictator: gold is not the best investment. It is hydrogen. Please read on.

-----Original Message-----
From: bobnadel2@inbox.com Sent: Sat, 12 May 2012 06:52:19 -0800
To: info@barackobama.com Subject: FW: RE: The Perfect Fuel

-----Original Message-----
From: bobnadel2@inbox.com Sent: Tue, 1 May 2012 09:24:00 -0800
To: mndcustserv@cdsfulfillment.com Subject: FW: RE: The Perfect Fuel

-----Original Message-----
From: bobnadel2@inbox.com Sent: Tue, 1 May 2012 09:19:31 -0800
To: scacustserv@cdsfulfillment.com Subject: FW: RE: The Perfect Fuel

Y0u have seen the rest. Now see the best. BELOW

-----Original Message-----
From: bobnadel2@inbox.com Sent: Fri, 27 Apr 2012 10:42:24 -0800
To: info@barackobama.com Subject: FW: RE: The Perfect Fuel13 

### -----Original Message-----
From: bobnadel2@inbox.com Sent: Fri, 27 Apr 2012 06:58:04 -0800
To: dpnewsletter@wyattresearch.comw Subject: FW: RE: The Perfect Fuel

We have answers. Someone of consequence who also has intelligence has to hear us. Please help. See below.

-----Original Message-----
From: bobnadel2@inbox.com Sent: Tue, 24 Apr 2012 10:32:06 -0800
To: staff@siri.biz Subject: FW: RE: The Perfect Fuel

Subject: FW: RE: The Perfect Fuel See below

..... Subject: FW: RE: The Perfect Fuel see below

Elecricity from air . GOOD IF IT WORKS! I bought the stock because it might. But there is something much
better. See below

and......... Subject: FW: RE: The Perfect Fuel See below

Subject: FW: RE: The Perfect Fuel see below14 

### 100,000 shares @ $10.00. First come. First served. See below15161718



### we would, no doubt , create the first trillionaire . however , none of this will happen without financing . I wi l need can million dollars to create a specialized machine shop with two or more boring mills and some smaller machine tools . and will need a forklift , at tugboat, a hull , some raw materials and some send the sophisticated labor . once we get that first ship out thereproducing hydrogen continuously , night and day ,24 seven , we will require . No more financing still eventually put thousands of ships out there . H1920212223



### ip is sailed tco a distrributor who collects and pays forx the cargo.

I operated a tool and die shop for over 50 years and when Clinton signed NAAFTA and GAAT found it dificult to survive butc the coup de grace was his 65% tariff on foreign steel and certain machine tools. So after laying off allf my employees, there I was, surrounded by a forest of prduction equipment and machine tools. So perforce, I became an iinventor. So in a perverted way, we could credit Bill Clinton for saving us from global warming. That is IF I GET SOME FINANCING. I would need $10,000.000 to set up a specialized machine shop with one or two Devlieg' boring mills and smaller machine tools to service these. i'll need a forklift, a tugboat and raw material, mostly aluminum. Note: All of these items have intrinsic value and can be used again and again.Aso needed are a hull to be refitted and the labor to do all this to put one hull out there making hydrogen night and day 24/7. The only other emission in the process is a kiss of oxygen for the atmosphere to dispell some of the poisons we have already put there. The secend HG ship will be built using the profits from running the first ship and so on infinitum. Once started it would grow like wild fire. Just think,. while saving the world as we know it, one could
become a trillionaire.24



### New item: Boeing has produced a drone fueled by HYDROGEN that can fly at 65,000 feet for four days without refueling. This is unprecedented.

We at Hydrogen One Inc. can supply the world with Hydrogen at low cost with a kiss of OXYGEN as the only other emission. PLEASE see below.

then b in popular mechanics in popular mechanics uilt and patented a small working prototype
that makes 12.volts of DC current when rocked

Try FREE IM ToolPack at www.imtoolpack.com Capture screenshots, upload images, edit and send them to your friends through IMs, post on Twitter ® 

### , Facebook ® 

### , MySpace TM 

### , LinkedIn ® 

### – FAST!25



### Send your photos by email in seconds... Try FREE IM ToolPack at www.imtoolpack.com Works in all emails, instant messengers, blogs, forums and social networks.

Free 3D Earth Screensaver Watch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free Online Photosharing - Share your photos online with your friends and family!
Visit http://www.inbox.com/photosharing to find out more!

Free 3D Earth Screensaver Watch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free 3D Marine Aquarium Screensaver Watch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium26



### Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most
webmails

Free 3D Marine Aquarium Screensaver Watch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Free 3D Earth Screensaver Watch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free Online Photosharing - Share your photos online with your friends and family!
Visit http://www.inbox.com/photosharing to find out more!

Free 3D Marine Aquarium Screensaver27



### Watch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most
webmails

Free 3D Earth Screensaver Watch the Earth right on your desktop! Check it out at www.inbox.com/earth28



### Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most
webmails

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Smileys Preview



### Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most webmails

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview29



### Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Receive Notifications of Incoming Messages
E asily monitor multiple email accounts & access them with a click. Visit
www.inbox.com/notifier

and check it out!

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Smileys Preview



### Get Free S mileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most webmails

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Smileys Preview



### Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most webmails

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free 3D Marine Aquarium Screensaver Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Email Notifier Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview30 Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Smileys Preview



### Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most webmails

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Smileys Preview



### Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most webmails

Free Online Photosharing - Share your photos online with your friends and family!
Visit http://www.inbox.com/photosharing to find out more!

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Smileys Preview



### Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most webmails

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Free Online Photosharing - Share your photos online with your friends and family!
Visit http://www.inbox.com/photosharing to find out more!

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview31



### Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Smileys Preview



### Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most webmails

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. Smileys Preview



### Get Free Smileys for Your IM & Email - Learn more at www.crawler.com/smileys
Works with AIM ® 

### , MSN ® 

### Messenger, Yahoo! ® 

### Messenger, ICQ ® 

### , Google Talk TM 

### and most webmails

Free 3D Marine Aquarium Screensaver
W atch dolphins, sharks & orcas on your desktop! Check it out at www.inbox.com/marineaquarium

Free Online Photosharing - Share your photos online with your friends and family!
Visit http://www.inbox.com/photosharing to find out more!

Free 3D Earth Screensaver
W atch the Earth right on your desktop! Check it out at www.inbox.com/earth

Free 3D Earth Screensaver

Watch the Earth right on your desktop! Check it out at www.inbox.com/earth Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Marine A quarium Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview

Right-click here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet. 3D Earth Screensaver Preview32 From: drupal_admin@epa.gov on behalf of Jonny Greenfield [jonny@americanmobilepipeline.com] Sent: Wednesday, December 18, 2013 2:28 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Wed, 12/18/2013 - 14:27

S ubmitted values are:

Name: Jonny Greenfield Email: jonny@americanmobilepipeline.com

Comments: We are a newly created U.S. company that can help solve many of the problems with Carbon Pollution. We can compress Na tural Gas and transport it to many plants or industries that are creating this nasty pollution. We are a mobile pipeline - "pipeline on wheels" solution. How can we get access to the companies, industries or municipalities that can use our help in converting over to Compressed Natural Gas - which is much cleaner than (you name it). Please respond with any suggestions you might have to help us help you create a cleaner and
safer environment for all. Thanks, Jonny
Web Area: Carbon Pollution Standards33 From: Peter Guerrero [studio374photography@gmail.com] Sent: Saturday, December 14, 2013 8:46 PM To: Carbon Pollution Input Subject: Comments on Carbon Pollution Standards for Existing Power Plants



### December 14, 2013

Thank you for the opportunity to comment on EPA’s proposed carbon emission standards for existing

p owerplants. My name is Peter Guerrero and I live in Port Townsend and am a member of the Executive Committee of the North Olympic Group of the Sierra Club.

EPA’s Proposed Carbon Emission Standard is Needed

For decades, there has been a scientific consensus that humans are changing the composition of the

a tmosphere and that these changes will affect climate and have catastrophic effects on our oceans, forests, farms, cities, and way of life. Limiting carbon emissions is key to mitigating these effects and EPA is to be commended for issuing its proposed limits on carbon emissions from existing powerplants.

But even as EPA is considering requiring existing coal-fired power plants to cut their carbon dioxide

ou tput, some utilities have started to look to biomass combustion as a way to achieve the new standard. The utilities and forestry industry have claimed that using modest amounts of wood at a large number of coal plants could be a relatively quick way to phase in renewable energy.

EPA must consider these serious implications were it to allow biomass combustion as a way for utilities

t o comply with the new standard:

**Burning Biomass is not Carbon Neutral**

Biomass incineration releases 50% more carbon dioxide (per unit of energy produced) than coal burning. Proponents claim that biomass is "carbon neutral" because trees take up the extra CO2, but this is not true within any meaningful time frame to address climate change. Studies show that it takes at least 40 years for trees to absorb the extra CO2 and hundreds of years to become "carbon neutral." Climate scientists insist we don't have that long to prevent runaway climate change. While I do not support burning fossil fuels, from a strictly carbon perspective, it makes more sense to burn coal and plant trees than to burn trees and plant trees. The faulty "carbon neutral" notion also relies on the assumpt ion that trees are replanted (not true for all types of biomass) and that they're left alone and not subsequently cut back down to burn again.

Burning Biomass Poses Known and Unknown Health Risks

Biomass combustion releases the same types of pollutants as coal burning, including carbon monoxide ( CO), carbon dioxide (CO2), particulate matter (PM), nitrogen oxides (NOx), sulfur dioxide (SO2), dioxins/furans, acid gases, radioactive pollutants and toxic metals like arsenic, chromium and mercury. For some pollutants, biomass air pollution can be worse than emissions from coal-burning, depending on the types of biomass and the pollution controls required. Ash from biomass combustion also concentrates high levels of toxins, but is not currently treated as hazardous waste34 

### On the Olympic Peninsula where one biomass facility is beginning operations and another is in the planning stages, residents have voiced concerns about potential health effects of the emissions from these facilities. For the Nippon facility in Port Angeles, volatile organic compounds and nitrogen oxides are anticipated to increase by 35 and 18 tons, respectively, per year. These increases are troubling as the association between air pollution and human illness has been well established.

While projections are for PM 2.5 levels to decrease at these facilities, the number of ultrafine particles, which may be more hazardous to health, will increase.

According to an independent study conducted in Colorado in 1997, when PM 2.5 levels decrease, sulfur dioxide and nitrogen oxides “have less surface area on which to condense” and are more likely to “homogeneously nucleate ultrafine particles downwind of the emission site.” This means that while emission controls limit the amount of PM 2.5, smaller, more hazardous ultrafine particles are more likely
to be formed.

Further compounding this potential health problem is the acknowledgement by environmental regulatory and health agencies that existing air monitoring on the Peninsula is inadequate to determine health impacts.

Biomass Subsidies and Regulatory Exemptions Have Significant Negative Impacts on the
Environment

Biomass is dirtier than most fossil fuels, but is considered renewable, competing for subsidies with true renewables like wind and solar. As we move away from coal, biomass is increasingly being sought out as an alternative (even chipping our forests to ship overseas for burning), thanks to misguided renewable energy and climate policies that fail to recognize that biomass is no better than and may be worse than coal for the climate. These misguided incentives have dire consequences for forest ecology, encourage the creation of GMO engineered “weed” tree plantations, and raise the price of basic foods, such as corn, thereby increasing scarcity and contributing to global hunger. There are no sound public policy or economic reasons to provide special tax breaks, subsidies, or regulatory exemptions for biomass
combustion.

Sincerely,

Peter Guerrero

816 O St.

Port Townsend, WA 9836835 From: info@baylocalize.org on behalf of D. [team@baylocalize.org] Sent: Monday, December 02, 2013 11:00 PM To: Carbon Pollution Input Subject: Form submission from: EPA: Our People, Our Earth Need Carbon Caps NOW!

Dear EPA Administrator Gina McCarthy,

W e appreciate the EPA’s efforts to implement President Obama’s Climate Action Plan. We support the EPA regulating existing power plants in line with the best available scientific consensus[i], on the scale of the action needed now to confront the climate crisis.

The Global Context of the Climate Crisis: We write this letter in the context of current climate events. Filipinos are suffering from the impacts of super typhoon Haiyan, the worse storm in recorded human history, which according to the UN has left an uncertain death toll of tens of thousands of people and left more than four million people homeless[ii]. In response to the suffering of his people, the Philippines lead negotiator at the UNFCCC negotiations Naderev Saño, has undertaken a voluntary fast until world leaders "stop the madness" of climate change[iii]. With super storm Sandy just a year behind us and impacted communities in the U.S. still struggling to recover, climate change is real. The next disaster will be upon us sooner than
we think so WE MUST ACT NOW.

Recommendation for Carbon Caps and Carbon Fees: We are calling upon the EPA to take an ambitious approach to regulating carbon dioxide from existing power plants. The EPA should capitalize on this historic opportunity of regulating carbon emissions from existing power plants by imposing a series of annually-lowering carbon caps that would prevent new fossil fuel plants and phase out all existing fossil-fuel plants by 2020. We believe that a series of annually-lowering carbon caps, combined with carbon fees, represents the “best system of emission reduction (BSER)” available.

Carbon Fees to Invest in Local Clean Energy Jobs for a Just Transition: Investing in local clean energy jobs and a just transition away from fossil fuels and nuclear energy would be an economic boon for economic and community development, especially for unemployed and under-employed people in the U.S. Workers employed by existing fossil fuel- fired and nuclear power plants must be provided with a just transition where they are trained and re- hired for careers in renewable energy, energy efficiency, and energy conservation.

Aggr essively investing in renewable energy and energy efficiency industries could generate up to $4.5 trillion in revenue and create 40 million new jobs by the year 2030[iv]. Research demonstrates that renewable energy investments create significantly more jobs than fossil fuel energy investments, per dollar invested. Over the course of a 10-year period the solar industry creates 5.65 jobs per million dollars in investment, the wind energy industry 5.7 jobs, and the coal industry only 3.96[v]. In the case of coal mining, wind and solar energy generate 40 percent more jobs per dollar invested[vi]. A study from the New York State Energy Office found that wind energy would create 27% more jobs than coal and 66% more than a natural gas plant, per kilowatt hour generated[vii].Not only does investing in local clean energy create more jobs, it is also more costeffective for consumers of electricity. In 2009, the California Energy Commission (CEC) found that large-scale distributed solar photovoltaics (PV) in urban areas to be a cost-effective substitute for new gas turbine peaking capacity, denying the permit for construction of a new gas-fired peaker power plant[viii]. In its final report, the CEC recognized distributed generation of urban PV to be “more cost-effective than utility-scale solar thermal36 technology” and also “identified urban PV as a potentially viable alternative to a conventional peaking gas turbine”[ix]..

Clean Energy Jobs Revolving Loan Fund to Invest in Most-Impacted Communities: Energy companies that do not comply with each year’s lowering carbon cap through quantifiable emissions reductions (e.g, plant closures) should pay a carbon fee into a new federal CleanEnergy Jobs Revolving Loan Fund. Revenues from this Fund would be invested into federallybacked grants and zero- to low- interest loans for energy conservation, energy efficiency, and local renewable energy public works projects. Companies that do not comply with each year’s annually lowering carbon cap should pay a hefty daily penalty in addition to the annual
carbon fee.

Loans from this Fund should be directed to climate mitigation, climate adaptation, and clean energy public works projects, with a priority for projects based in and benefiting disadvantaged low-income communities that are most-impacted by pollution and climate change.

EPA’s Unique Responsibility and Opportunity for Climate Leadership: As both the world’s wealthiest industrial country and the most carbon-polluting nation per capita on the planet, the United States has a unique responsibility to take decisive action on climate change. With the U.S. Congress paralyzed by internal political fragmentation, the responsibility for assuming leadership and taking unprecedented meaningful action on climate change lies with the Environmental Protection Agency. With this proposed new regulation of carbon dioxide emissions from existing power plants, the EPA now has the unique opportunity to single-handedly undertake significant climate action, in line with the best available
science.

We believe in the EPA’s potential for unprecedented courage in the face of great political pressure to do nothing. At this juncture, the EPA has the opportunity to change the course of history for the U.S. and for the world.

We thank you in advance for your leadership and initiative.

Sincerely,

First Name: D. Last Name: Singer Email: singerde@ymail.com
Address: 1233 P City: Oakland

State: CA Zip: 94607

The results of this submission may be viewed at: http://www.baylocalize.org/node/905/submission/1294

[i] See the Intergovernmental Panel on Climate Change’s Fifth Assessment Report on Climate Change, released on 09/27/2013. Download the Summary Report for Policymakers athttp://www.climatechange2013.org/images/uploads/WGI_AR5_SPM_brochure.pdf [ii] United Nations Office for the Coordination of Humanitarian Affairs Report on Typhoon Haiyan, available at http://www.unocha.org/crisis/typhoonhaiyan [iii]http://www.nytimes.com/video/world/asia/100000002548526/emotional-speech-by-philippinedelegate.html [iv] Roger Bezdek, Renewable Energy and Energy Efficiency: Economic Drivers for the 21st Century, American Solar Energy Society (ASES) and Management Information Services, Inc. (MISI), 2007, iv,http://ases.org/ASES-JobsReport-Final.pdf37 [v] Daniel Kammen, Kamal Kapadia, and Matthias Fripp, “Putting Renewables to Work: How Many Jobs Can the Clean Energy Industry Create?” UC Berkeley: Renewable and Appropriate Energy Laboratory (RAEL), April 2004 (updated January 2006), 12, http://rael.berkeley.edu/files/2004/Kammen-Renewable-Jobs-2004.pdf [vi] Virinder Singh, BBC Research and Consulting, and Jeffrey Fehrs, “The Work That Goes into Renewable Energy,” Renewable Energy Policy Project, November 2001, 8. [vii] A.K. Sanghi, Economic Impacts of Electricity Supply Options, New York State Energy Office, July 1992. [viii] http://santalucia.sierraclub.org/documents/aug%2009_Nat%20Gas%20&%20Elec%20Jr.CEC%20cancels.p
df [ix] http://santalucia.sierraclub.org/documents/aug%2009_Nat%20Gas%20&%20Elec%20Jr.CEC%20cancels.p
df38 From: drupal_admin@epa.gov on behalf of Michael Uberty [muberty@gmail.com] Sent: Sunday, December 01, 2013 5:05 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Sun, 12/01/2013 - 17:05

S ubmitted values are:

Name: Michael Uberty
Email: muberty@gmail.com

Comments: One of the best ways to reduce CO2 is to regulate the lighting manufactures, government agency small and large. Too many lights are being installed all over the world let alone the US. If everyone follow simple suggestions we could eliminate tons of CO2. Example; 1- Use lights only where needed 2- Use full shielded lights to direct light where it is needed 3- Use dimming lights or motion detectors to prevent lights on all night 4- Do Not use LED light that are rated over 3500K 5- Have lighting ordinances for every county in the US. These are all very simple solutions that can be implemented immediately. These will save money, reduce CO2, and prevent Harmful Light Pollution

Thank You Michael Uberty

585-297-7550 Web Area: Carbon Pollution Standards39 From: drupal_admin@epa.gov on behalf of David Tepper [david.tepper@teplp.com] Sent: Saturday, November 30, 2013 5:06 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Sat, 11/30/2013 - 17:05

S ubmitted values are:

Name: David Tepper
Email: david.tepper@teplp.com

Comments: EPA’s existing source CO2 power plant standards have the potential to be one of the country’s most influential policies for diversifying the U.S. power sector toward low-carbon fuels. To maximize the stringency of these regulations while also managing political tenability, EPA should ensure these regulations allow for a wide variety of mitigation and compliance strategies.

Sustainable biomass should not be overlooked as a mitigation option – this is one of the largest, lowest- cost alternative fuels available to the power sector. While biomass currently only comprises a small percentage of power sector fuel in the United States, the potential for expansion is enormous. In Europe, biomass is expected to meet roughly half of the European Commission’s goal of 20 percent renewables by 2020.

The EPA and other U.S. agencies like USDA and USFS can help ensure that biomass use in the power sector results in real emissions reductions compared to fossil fuels by:

1. Accounting for emissions from biomass in a way that recognizes the distinction between fossil fuel and biogenic emissions. That is, acknowledging that managed sustainably, biomass feedstoc k can contribute low to zero net greenhouse gas emissions to the atmosphere. Note that this would require harmonization between the EPA existing source CO2 power plant standards as well as EPA’s policy for biogenic emissions accounting.

2. Taking an approach that initially allows facilities to utilize cost-effective, incremental mitigation strategies that require few capital investments, such as biomass co-firing. The stringency of CO2 limits could increase over time.

3. Ensuring that biomass supplies that are generated from marginal land, or that result from ecosystem restoration activities such as the removal of invasive brush species, and that don’t compete with food supply, should be specifically recognized and receive a favorable sustainability designation. Such feedstock has comparative sustainability benefits even to waste and residue, which should be recognized and incentivized. This could entail developing interagency guidelines that require minimizing emissions from direct and indirect land use change as well as other sustainability requirements (e.g. related to groundwater, biodiversity, soil carbon, land productivity, etc.) for biomass. The work my company is doing, described below, can inform the development of such guidelines.

There is signifi cant potential for utilizing biomass harvested here in the United States that would meet such strict sustainability criteria, while also allowing for low-cost mitigation in the power sector.

I am the CEO of The Earth Partners, a company that is focused on the nexus of landrestoration and sustainable biomass feedstock. We are developing a scalable model for aggregating marginal and degraded land and harvesting invasive brush or native grasses to40 generate biomass pellets and chips. We have mapped over 20 million acres of suitable land, developed harvest management models to support one million tons of feedstock per year, and secured landowner support, enrolling hundreds of landowners under long-term contracts representing nearly 800,000 acres of early adopters.

We are currently developing contracts with a number of European utilities, which are very interested in using this feedstock to meet their emissions reduction obligations as well as stringent sustainability standards. But clearly this is also an opportunity for U.S. utilities to utilize a low-cost domestic renewable energy source.

Designed accordingly, new EPA standards could allow the U.S. power sector to take advantage of this option.

Web Area: Carbon Pollution Standards41 From: info@baylocalize.org on behalf of Kristina [team@baylocalize.org] Sent: Friday, November 22, 2013 2:18 AM To: Carbon Pollution Input Subject: Form submission from: EPA: Our People, Our Earth Need Carbon Caps NOW!

Dear EPA Administrator Gina McCarthy,

W e appreciate the EPA’s efforts to implement President Obama’s Climate Action Plan. We support the EPA regulating existing power plants in line with the best available scientific consensus[i], on the scale of the action needed now to confront the climate crisis.

The Global Context of the Climate Crisis: We write this letter in the context of current climate events. Filipinos are suffering from the impacts of super typhoon Haiyan, the worse storm in recorded human history, which according to the UN has left an uncertain death toll of tens of thousands of people and left more than four million people homeless[ii]. In response to the suffering of his people, the Philippines lead negotiator at the UNFCCC negotiations Naderev Saño, has undertaken a voluntary fast until world leaders "stop the madness" of climate change[iii]. With super storm Sandy just a year behind us and impacted communities in the U.S. still struggling to recover, climate change is real. The next disaster will be upon us sooner than
we think so WE MUST ACT NOW.

Recommendation for Carbon Caps and Carbon Fees: We are calling upon the EPA to take an ambitious approach to regulating carbon dioxide from existing power plants. The EPA should capitalize on this historic opportunity of regulating carbon emissions from existing power plants by imposing a series of annually-lowering carbon caps that would prevent new fossil fuel plants and phase out all existing fossil-fuel plants by 2020. We believe that a series of annually-lowering carbon caps, combined with carbon fees, represents the “best system of emission reduction (BSER)” available.

Carbon Fees to Invest in Local Clean Energy Jobs for a Just Transition: Investing in local clean energy jobs and a just transition away from fossil fuels and nuclear energy would be an economic boon for economic and community development, especially for unemployed and under-employed people in the U.S. Workers employed by existing fossil fuel- fired and nuclear power plants must be provided with a just transition where they are trained and re- hired for careers in renewable energy, energy efficiency, and energy conservation.

Aggressively investing in renewable en ergy and energy efficiency industries could generate up to $4.5 trillion in revenue and create 40 million new jobs by the year 2030[iv]. Research demonstrates that renewable energy investments create significantly more jobs than fossil fuel energy investments, per dollar invested. Over the course of a 10-year period the solar industry creates 5.65 jobs per million dollars in investment, the wind energy industry 5.7 jobs, and the coal industry only 3.96[v]. In the case of coal mining, wind and solar energy generate 40 percent more jobs per dollar invested[vi]. A study from the New York State Energy Office found that wind energy would create 27% more jobs than coal and 66% more than a natural gas plant, per kilowatt hour generated[vii].Not only does investing in local clean energy create more jobs, it is also more costeffective for consumers of electricity. In 2009, the California Energy Commission (CEC) found that large-scale distributed solar photovoltaics (PV) in urban areas to be a cost-effective
substi tute for new gas turbine peaking capacity, denying the permit for construction of a new gas-fired peaker power plant[viii]. In its final report, the CEC recognized distributed generation of urban PV to be “more cost-effective than utility-scale solar thermal42 technology” and also “identified urban PV as a potentially viable alternative to a conventional peaking gas turbine”[ix]..

Clean Energy Jobs Revolving Loan Fund to Invest in Most-Impacted Communities: Energy companies that do not comply with each year’ s lowering carbon cap through quantifiable emissions reductions (e.g, plant closures) should pay a carbon fee into a new federal CleanEnergy Jobs Revolving Loan Fund. Revenues from this Fund would be invested into federallybacked grants and zero- to low- interest loans for energy conservation, energy efficiency, and local renewable energy public works projects. Companies that do not comply with each year’s annually lowering carbon cap should pay a hefty daily penalty in addition to the annual
carbon fee.

Loans from this Fund should be directed to climate mitigation, climate adaptation, and clean energy public works projects, with a priority for projects based in and benefiting disadvantaged low-income communities that are most-impacted by pollution and climate change.

EPA’s Unique Responsibility and Opportunity for Climate Leadership: As both the world’s wealthiest industrial country and the most carbon-polluting nation per capita on the planet, the United States has a unique responsibility to take decisive action on climate change. With the U.S. Congress paralyzed by internal political fragmentation, the responsibility for assuming leadership and taking unprecedented meaningful action on climate change lies with the Environmental Protection Agency. With this proposed new regulation of carbon dioxide emissions from existing power plants, the EPA now has the unique opportunity to single-handedly undertake significant climate action, in line with the best available
science.

We believe in the EPA’s potential for unprecedented courage in the face of great political pressure to do nothing. At this juncture, the EPA has the opportunity to change the course of history for the U.S. and for the world.

We thank you in advance for your leadership and initiative.

Sincerely,

First Name: Kristina

Last Name: Bennett Email: kristinabridget@hotmail.com
Address: Midvale Ave City: Oakland

State: CA Zip: 94602

The results of this submission may be viewed at: http://www.baylocalize.org/node/905/submission/1217

[i] See the Intergovernmental Panel on Climate Change’s Fifth Assessment Report on Climate Change, released on 09/27/2013. Download the Summary Report for Policymakers athttp://www.climatechange2013.org/images/uploads/WGI_AR5_SPM_brochure.pdf [ii] United Nations Office for the Coordination of Humanitarian Affairs Report on Typhoon Haiyan, available at http://www.unocha.org/crisis/typhoonhaiyan [iii]http://www.nytimes.com/video/world/asia/100000002548526/emotional-speech-by-philippinedelegate.html [iv] Roger Bezdek, Renewable Energy and Energy Efficiency: Economic Drivers for the 21st Century, American Solar Energy Society (ASES) and Management Information Services, Inc. (MISI), 2007, iv,http://ases.org/ASES-JobsReport-Final.pdf43 [v] Daniel Kammen, Kamal Kapadia, and Matthias Fripp, “Putting Renewables to Work: How Many Jobs Can the Clean Energy Industry Create?” UC Berkeley: Renewable and Appropriate Energy Laboratory (RAEL), April 2004 (updated January 2006), 12, http://rael.berkeley.edu/files/2004/Kammen-Renewable-Jobs-2004.pdf [vi] Virinder Singh, BBC Research and Consulting, and Jeffrey Fehrs, “The Work That Goes into Renewable Energy,” Renewable Energy Policy Project, November 2001, 8. [vii] A.K. Sanghi, Economic Impacts of Electricity Supply Options, New York State Energy Office, July 1992. [viii] http://santalucia.sierraclub.org/documents/aug%2009_Nat%20Gas%20&%20Elec%20Jr.CEC%20cancels.p
df [ix] http://santalucia.sierraclub.org/documents/aug%2009_Nat%20Gas%20&%20Elec%20Jr.CEC%20cancels.p
df44 From: info@baylocalize.org on behalf of Barbara [team@baylocalize.org] Sent: Friday, November 22, 2013 1:39 AM To: Carbon Pollution Input Subject: Form submission from: EPA: Our People, Our Earth Need Carbon Caps NOW!

Dear EPA Administrator Gina McCarthy,

W e appreciate the EPA’s efforts to implement President Obama’s Climate Action Plan. We support the EPA regulating existing power plants in line with the best available scientific consensus[i], on the scale of the action needed now to confront the climate crisis.

The Global Context of the Climate Crisis: We write this letter in the context of current climate events. Filipinos are suffering from the impacts of super typhoon Haiyan, the worse storm in recorded human history, which according to the UN has left an uncertain death toll of tens of thousands of people and left more than four million people homeless[ii]. In response to the suffering of his people, the Philippines lead negotiator at the UNFCCC negotiations Naderev Saño, has undertaken a voluntary fast until world leaders "stop the madness" of climate change[iii]. With super storm Sandy just a year behind us and impacted communities in the U.S. still struggling to recover, climate change is real. The next disaster will be upon us sooner than
we think so WE MUST ACT NOW.

Recommendation for Carbon Caps and Carbon Fees: We are calling upon the EPA to take an ambitious approach to regulating carbon dioxide from existing power plants. The EPA should capitalize on this historic opportunity of regulating carbon emissions from existing power plants by imposing a series of annually-lowering carbon caps that would prevent new fossil fuel plants and phase out all existing fossil-fuel plants by 2020. We believe that a series of annually-lowering carbon caps, combined with carbon fees, represents the “best system of emission reduction (BSER)” available.

Carbon Fees to Invest in Local Clean Energy Jobs for a Just Transition: Investing in local clean energy jobs and a just transition away from fossil fuels and nuclear energy would be an economic boon for economic and community development, especially for unemployed and under-employed people in the U.S. Workers employed by existing fossil fuel- fired and nuclear power plants must be provided with a just transition where they are trained and re- hired for careers in renewable energy, energy efficiency, and energy conservation.

Aggressively investing in renewable energy and energy efficiency industries could generate up to $4.5 trillion in revenue and create 40 million new jobs by the year 2030[iv]. Research demonstrates that renewable energy investments create significantly more jobs than fossil fuel energy investments, per dollar invested. Over the course of a 10-year period the solar industry creates 5.65 jobs per million dollars in investment, the wind energy industry 5.7 jobs, and the coal industry only 3.96[v]. In the case of coal mining, wind and solar energy generate 40 percent more jobs per dollar invested[vi]. A study from the New York State Energy Office found that wind energy would create 27% more jobs than coal and 66% more than a natural gas plant, per kilowatt hour generated[vii].Not only does investing in local clean energy create more jobs, it is also more costeffective for consumers of electricity. In 2009, the California Energy Commission (CEC) found that large-scale distributed solar photovoltaics (PV) in urban areas to be a cost-effective substitute for new gas turbine peaking capacity, denying the permit for construction of a new gas-fired peaker power plant[viii]. In its final report, the CEC recognized distributed generation of urban PV to be “more cost-effective than utility-scale solar thermal45 technology” and also “identified urban PV as a potentially viable alternative to a conventional peaking gas turbine”[ix]..

Clean Energy Jobs Revolving Loan Fund to Invest in Most-Impacted Communities: Energy companies that do not comply with each year’s lowering carbon cap through quantifiable emissions reductions (e.g, plant closures) should pay a carbon fee into a new federal CleanEnergy Jobs Revolving Loan Fund. Revenues from this Fund would be invested into federallybacked grants and zero- to low- interest loans for energy conservation, energy efficiency, and local renewable energy public works projects. Companies that do not comply with each year’s annually lowering carbon cap should pay a hefty daily penalty in addition to the annual
carbon fee.

Loans from this Fund should be directed to climate mitigation, climate adaptation, and clean energy public works projects, with a priority for projects based in and benefiting disadvantaged low-income communities that are most-impacted by pollution and climate change.

EPA’s Unique Responsibility and Opportunity for Climate Leadership: As both the world’s wealthiest industrial country and the most carbon-polluting nation per capita on the planet, the United States has a unique responsibility to take decisive action on climate change. With the U.S. Congress paralyzed by internal political fragmentation, the responsibility for assuming leadership and taking unprecedented meaningful action on climate change lies with the Environmental Protection Agency. With this proposed new regulation of carbon dioxide emissions from existing power plants, the EPA now has the unique opportunity to single-handedly undertake significant climate action, in line with the best available
science.

We believe in the EPA’s potential for unprecedented courage in the face of great political pressure to do nothing. At this juncture, the EPA has the opportunity to change the course of history for the U.S. and for the world.

We thank you in advance for your leadership and initiative.

Sincerely,

First Name: Barbara

Last Name: Roemer Email: roemiller4@gmail.com Address: 17373 Refuge Road City: Nevada City

State: CA Zip: 95959

The results of this submission may be viewed at: http://www.baylocalize.org/node/905/submission/1216

[i] See the Intergovernmental Panel on Climate Change’s Fifth Assessment Report on Climate Change, released on 09/27/2013. Download the Summary Report for Policymakers athttp://www.climatechange2013.org/images/uploads/WGI_AR5_SPM_brochure.pdf [ii] United Nations Office for the Coordination of Humanitarian Affairs Report on Typhoon Haiyan, available at http://www.unocha.org/crisis/typhoonhaiyan [iii]http://www.nytimes.com/video/world/asia/100000002548526/emotional-speech-by-philippinedelegate.html [iv] Roger Bezdek, Renewable Energy and Energy Efficiency: Economic Drivers for the 21st Century, American Solar Energy Society (ASES) and Management Information Services, Inc. (MISI), 2007, iv,http://ases.org/ASES-JobsReport-Final.pdf46 [v] Daniel Kammen, Kamal Kapadia, and Matthias Fripp, “Putting Renewables to Work: How Many Jobs Can the Clean Energy Industry Create?” UC Berkeley: Renewable and Appropriate Energy Laboratory (RAEL), April 2004 (updated January 2006), 12, http://rael.berkeley.edu/files/2004/Kammen-Renewable-Jobs-2004.pdf [vi] Virinder Singh, BBC Research and Consulting, and Jeffrey Fehrs, “The Work That Goes into Renewable Energy,” Renewable Energy Policy Project, November 2001, 8. [vii] A.K. Sanghi, Economic Impacts of Electricity Supply Options, New York State Energy Office, July 1992. [viii] http://santalucia.sierraclub.org/documents/aug%2009_Nat%20Gas%20&%20Elec%20Jr.CEC%20cancels.p
df [ix] http://santalucia.sierraclub.org/documents/aug%2009_Nat%20Gas%20&%20Elec%20Jr.CEC%20cancels.p
df47 From: info@baylocalize.org on behalf of Ryan [team@baylocalize.org] Sent: Friday, November 22, 2013 12:07 AM To: Carbon Pollution Input Subject: Form submission from: EPA: Our People, Our Earth Need Carbon Caps NOW!

Dear EPA Administrator Gina McCarthy,

W e appreciate the EPA’s efforts to implement President Obama’s Climate Action Plan. We support the EPA regulating existing power plants in line with the best available scientific consensus[i], on the scale of the action needed now to confront the climate crisis.

The Global Context of the Climate Crisis: We write this letter in the context of current climate events. Filipinos are suffering from the impacts of super typhoon Haiyan, the worse storm in recorded human history, which according to the UN has left an uncertain death toll of tens of thousands of people and left more than four million people homeless[ii]. In response to the suffering of his people, the Philippines lead negotiator at the UNFCCC negotiations Naderev Saño, has undertaken a voluntary fast until world leaders "stop the madness" of climate change[iii]. With super storm Sandy just a year behind us and impacted communities in the U.S. still struggling to recover, climate change is real. The next disaster will be upon us sooner than
we think so WE MUST ACT NOW.

Recommendation for Carbon Caps and Carbon Fees: We are calling upon the EPA to take an ambitious approach to regulating carbon dioxide from existing power plants. The EPA should capitalize on this historic opportunity of regulating carbon emissions from existing power plants by imposing a series of annually-lowering carbon caps that would prevent new fossil fuel plants and phase out all existing fossil-fuel plants by 2020. We believe that a series of annually-lowering carbon caps, combined with carbon fees, represents the “best system of emission reduction (BSER)” available.

Carbon Fees to Invest in Local Clean Energy Jobs for a Just Transition: Investing in local clean ener gy jobs and a just transition away from fossil fuels and nuclear energy would be an economic boon for economic and community development, especially for unemployed and under-employed people in the U.S. Workers employed by existing fossil fuel-fired and nuc lear power plants must be provided with a just transition where they are trained and re- hired for careers in renewable energy, energy efficiency, and energy conservation.

Aggressively investing in renewable energy and energy efficiency industries could ge nerate up to $4.5 trillion in revenue and create 40 million new jobs by the year 2030[iv]. Research demonstrates that renewable energy investments create significantly more jobs than fossil fuel energy investments, per dollar invested. Over the course of a 10-year period the solar industry creates 5.65 jobs per million dollars in investment, the wind energy industry 5.7 jobs, and the coal industry only 3.96[v]. In the case of coal mining, wind and solar energy generate 40 percent more jobs per dollar inve sted[vi]. A study from the New York State Energy Office found that wind energy would create 27% more jobs than coal and 66% more than a natural gas plant, per kilowatt hour generated[vii].Not only does investing in local clean energy create more jobs, it is also more costeffective for consumers of electricity. In 2009, the California Energy Commission (CEC) found that large-scale distributed solar photovoltaics (PV) in urban areas to be a cost-effective substitute for new gas turbine peaking capacity, den ying the permit for construction of a new gas-fired peaker power plant[viii]. In its final report, the CEC recognized distributed generation of urban PV to be “more cost-effective than utility-scale solar thermal48 technology” and also “identified urban PV as a potentially viable alternative to a conventional peaking gas turbine”[ix]..

Clean Energy Jobs Revolving Loan Fund to Invest in Most-Impacted Communities: Energy companies that do not comply with each year’s lowering carbon cap through quantifiable emissions reductions (e.g, plant closures) should pay a carbon fee into a new federal CleanEnergy Jobs Revolving Loan Fund. Revenues from this Fund would be invested into federallybacked grants and zero- to low- interest loans for energy conservation, energy efficiency, and local renewable energy public works projects. Companies that do not comply with each year’s annually lowering carbon cap should pay a hefty daily penalty in addition to the annual
carbon fee.

Loans from this Fund should be directed to climate mitigation, climate adaptation, and clean energy public works projects, with a priority for projects based in and benefiting disadvantaged low-income communities that are most-impacted by pollution and climate change.

EPA’s Unique Responsibility and Opportunity for Climate Leadership: As both the world’s wealthiest industrial country and the most carbon-polluting nation per capita on the planet, the United States has a unique responsibility to take decisive action on climate change. With the U.S. Congress paralyzed by internal political fragmentation, the responsibility for assuming leadership and taking unprecedented meaningful action on climate change lies with the Environmental Protection Agency. With this proposed new regulation of carbon dioxide emissions from existing power plants, the EPA now has the unique opportunity to single-handedly undertake significant climate action, in line with the best available
science.

We believe in the EPA’s potential for unprecedented courage in the face of great political pressure to do nothing. At this juncture, the EPA has the opportunity to change the course of history for the U.S. and for the world.

We thank you in advance for your leadership and initiative.

Sincerely,

First Name: Ryan Last Name: Van Lenning Email: vanlenning@hotmail.com
Address: 835 60th St. City: Oakland

State: CA Zip: 94608

The results of this submission may be viewed at: http://www.baylocalize.org/node/905/submission/1214

[i] See the Intergovernmental Panel on Climate Change’s Fifth Assessment Report on Climate Change, released on 09/27/2013. Download the Summary Report for Policymakers athttp://www.climatechange2013.org/images/uploads/WGI_AR5_SPM_brochure.pdf [ii] United Nations Office for the Coordination of Humanitarian Affairs Report on Typhoon Haiyan, available at http://www.unocha.org/crisis/typhoonhaiyan [iii]http://www.nytimes.com/video/world/asia/100000002548526/emotional-speech-by-philippinedelegate.html [iv] Roger Bezdek, Renewable Energy and Energy Efficiency: Economic Drivers for the 21st Century, American Solar Energy Society (ASES) and Management Information Services, Inc. (MISI), 2007, iv,http://ases.org/ASES-JobsReport-Final.pdf49 [v] Daniel Kammen, Kamal Kapadia, and Matthias Fripp, “Putting Renewables to Work: How Many Jobs Can the Clean Energy Industry Create?” UC Berkeley: Renewable and Appropriate Energy Laboratory (RAEL), April 2004 (updated January 2006), 12, http://rael.berkeley.edu/files/2004/Kammen-Renewable-Jobs-2004.pdf [vi] Virinder Singh, BBC Research and Consulting, and Jeffrey Fehrs, “The Work That Goes into Renewable Energy,” Renewable Energy Policy Project, November 2001, 8. [vii] A.K. Sanghi, Economic Impacts of Electricity Supply Options, New York State Energy Office, July 1992. [viii] http://santalucia.sierraclub.org/documents/aug%2009_Nat%20Gas%20&%20Elec%20Jr.CEC%20cancels.p
df [ix] http://santalucia.sierraclub.org/documents/aug%2009_Nat%20Gas%20&%20Elec%20Jr.CEC%20cancels.p
df50 From: drupal_admin@epa.gov on behalf of Virgil Fenn [VirgilTimeScout@gmail.com] Sent: Wednesday, November 20, 2013 3:17 AM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Wed, 11/20/2013 - 03:16

S ubmitted values are:

Name: Virgil Fenn
Email: VirgilTimeScout@gmail.com

Comments: Dear EPA, Let's assume that increasing atmoshperic CO2 levels is the most critical threat to the environment. It is a global threat and therefore requires a global solution. That would solve the problem. Consider the possibility of an energy source that would be able to provide load responsive power to the grid to smooth the intermittancy of solar and wind. Consider the possibility of an energy source that would be sustainable and renewable for millenia. Consider the possibility of an energy source that would be able to provide high temperatures for industrial processes like desalination of seawater as well as run generators. Consider the possibility of an energy source that would not need to be subsidized because it can produce cleane energy cheaper than coal. Consider a molten salt nuclear reactor. It was demonstrated by Oak Ridge National Labs back in the 60's. There are several fourth generation nuclear powerreactors in the works, but molten salt dual fluid designs using thorium will be the best, IMHO. The good news is that the EPA doesn't have to do much to make it happen. First, you need to quit treating thorium as a radioactive hazard. It is far less radioactive than natural uranium and generates only a tiny fraction of the natural background radiation. Also quit treating thorium as a nuclear waste. Thorium is useful. Also set reasonable standards for safety of a molten salt liquid fu el reactor because they are nothing like solid fuel reactors and the do not even require containment buildings to contain steam explosions because MSRs operate a low pressure. That makes everything safer and less expensive. One more thing, low level ionizing radiation is not as dangererous as opnce was thought. The Linear No Threshold theory is too simplistic and simply wrong. Maybe the EPA could do something to educate the public on that point. Virgil Fenn “For a successful technology, reality must take precedence over public relations, for nature
cannot be fooled.” ― Richard P. Feynman

Web Area: Carbon Pollution Standards51 From: Susan Leeper [leeper.susan@gmail.com] Sent: Thursday, November 14, 2013 7:40 AM To: Carbon Pollution Input Subject: AZ carbon regulations



### I have lived in Arizona since 1992 and I am concerned about the EPA’s proposed rules regarding carbon

r egulations in areas surrounding the Navajo Generating Station in northern Arizona, and other coal fired power supplies in Arizona.

The Clean Air Act gives both EPA and states a role in reducing air pollution from power plantsthat are already in operation. The law directs EPA to establish guidelines, which states use to design their own programs to reduce emissions.We object to the Carbon regulation proposed for existing coal fired power plant that do not take into account the costs involved in different geographies, nor the effects on the Largest NativeAmerican
Tribe in the US.

AZ has no oil wells to pump carbon into underground reserviors which makes it un feasible in AZ. Carbonination our underground water supplies is not good water management practice.AZ has no natural gas supplies and new carbon regulations that force the replacement of coal with Natural Gas plants only work in

st ates that have Natural Gas. AZ has no such option.The States implementation plan is the best solution for long term transition to a less carbon, and the 10th Amendment requires The EPA to use the State Plan in these regulations.

We are opposed to the sta cking of regulations on power plants that force them to close, switch to Natural Gas or join a Carbon CAP and TAX marketplace like the one in California or REGI.Because the EPA's proposed rules is unworkable on several levels at NGS, we urge the EPA to adopt the TWG BART Proposal as the final rule for NGS. We also urge the EPA to giveexclusions to the rules that damage tribal and state economies. We have
no Gas no Oil no choice in AZ.

Susan Leeper Scottsdale, AZ AZ Taxpayer

-- We cannot solve our problems with the same thinking we used when we created them - Albert Einstein52 From: drupal_admin@epa.gov on behalf of Russell Donnelly [RDDonnellymd@aol.com] Sent: Thursday, November 14, 2013 4:31 AM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Thu, 11/14/2013 - 04:30

S ubmitted values are:

Name: Russell Donnelly
Email: RDDonnellymd@aol.com Comments: Understand there is a lot of pushback against these plans.If we needed to continue the status quo in order to land the troops on Omaha Beach it would be one thing.We are so far from that.I would propose the simple plan of replacing the payroll tax,two points per year,with a carbon tax.Then the more polluting plants would simply be shut down,while millions would be employed in building retrofits,solar gardens,wind farms,etc.
Web Area: Carbon Pollution Standards53 From: Willard Westre [wwestre@hotmail.com] Sent: Tuesday, November 12, 2013 5:15 PM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website

I attended the listening session in Seattle and afterward came up with this input:

P roblem : It has been widely reported here in Washington State that renewable energy sources are frequently pulled off line when power generation exceeds grid demand, while fossil fuel generation continues. This is done because for the power producers renewable sources are more flexible , being easier to shut down and start up again. This is a primary negative factor in considering new renewable energy investments, in raising the relative cost of renewables, and
also increases carbon emissions.

Proposal : Although it is not the charter of EPA to regulate power distribution issues this problem could be addressed from the emissions perspective. EPA could give priority to renewable generation by banning high level emissions from fossil fuel generation while low level renewable energy sources are available.

Benefits : In the beginning this would probably not have a major effect, but it would continue to grow as more
renewable sources come on line. It would accelerate renewable investments. Most i mportantly, it would realign market forces by shifting flexibility costs to the fossil fuel sources, thus helping to balance the cost economics.

Thank you for this opportunity,

Willard N. Westre Mechanical Engineer
15704 SE 44th St Bellevue, WA 98006-451454 From: Hannam, Herbert [HHannam@scsengineers.com] Sent: Monday, November 11, 2013 8:58 AM To: Carbon Pollution Input Subject: Comments relative to carbon policy

Thanks for the opportunity to chime in on the topic of carbon policy relative to electrical power generation. I’ve been
fo llowing this topic closely for many years.

A little on my background, when in college I worked at a coal fired plant for a summer, as a plant helper. Got first hand exposure as to the nature of generating power from coal, including pulling slag on the boilers, cleaning fly ash precipitators, unloading coal boats, cleaning coal pulverizers, and other aspects of changing coal into electricity. I more recently have worked for a power company as an energy engineer, helping to find ways our customers could reduce their energy consumption to lower their total energy costs and carbon footprint. Also had a stint as a REM (resource efficiency manager) with the ANG helping 9 bases in the Midwest find ways to lower their energy costs and environmental impacts. Pretty much driven by EPACT2005. I now am an energy engineer working with SCS Engineers primarily focusing on industrial clients and working with our local MEP (WMEP) to help reduce Wisconsin manufacturing companies environmental footprint.

I am a fan of wind and solar, both PV and concentrating, but have an issue with the overall financial viability. The wind system we installed at Eden was generating electricity, at the end of the day, at about $.08 per kWh at utility scale. This is compared to about $.03 for coal and natural gas. The PV systems that are being installed now will be lucky to match this cost structure, even given the subsidies. For a mid to long term viable production source of power we need to be able to produce a base load resource that is in the same rough cost structure of our present capabilities. Nuclear has this possibility, but we are presently in the mode of decommissioning this resource. A few newer units are being built, but nothing at the scale that will be needed if we are trying to decommission our coal units at the rate we are. The only reason the present utility generation plans allow this is that the economy is still not recovered. In a growth scenario, there is no way we can reduce our coal footprint without significant investment in nuclear. And serious research investment in fusion technology. We managed to release enough fusion power to destroy an island in 1950, but haven’t pursued the technology to throttle it back to controlled power generation. Several private companies are making progress on this front, but we need an effort similar to the man on the moon effort to move this technology forward.

Personally I think a bridge technology of nuclear, with a goal of fusion is the only viable approach to meeting the overall energy needs of the world. Any carbon based energy source, be it coal or natural gas will only accelerate our climate change issues, and the underdeveloped nations are going to add carbon faster than any conservation efforts we could accomplish. And don’t forget that all the advances we have made in the last century, be it on the agricultural or industrial fronts, have come at the cost of adding energy consumption to the processes, not reducing it. 5% of the people can produce all the food for our nation only because they leverage a significant amount of fossil fuel resource to do this. This includes planting, harvesting, and the fertilizers that have increased production levels. The automated manufacturing systems I built for 25 years actually increase the energy footprint of production, not reduce it. And the average citizen wants a more comfortable living environment, which in most parts of the world translates to environmental conditioning, translating to heating and cooling, that cost energy.

I would be happy to participate in any kind of citizen review board relative to footprint. I think I have a reasonably good understanding of the issue and am open to all ideas for a good solution. And I have three kids that will have to live with the results of these actions. Please let me know how I could help.

Thanks for listening.

**Herb Hannam, CEM**
Sr. Energy Engineer55 **SCS ENGINEERS** 2830 Dairy Drive Madison, WI 53718

608.224.2830
Direct: 608.216.7359 Cell: 608.695.0575 www.scsengineers.com56 From: Shamus Thornton [shamusd@pacbell.net] Sent: Friday, November 08, 2013 4:31 PM To: Carbon Pollution Input Subject: Offset Carbon Emissions by Planting Trees



### I regret that I wasn’t able to attend today’s Public Listening Session, for which I had registered, due to illness in the family.

Comment:

========= Existing power plants can effectively reduce the net carbon that they put into the atmosphere by planting trees. Utilities can either plant the trees by administering their own planting operation, or they can donate to organizations that plant trees. All tree planting would have to adhere to certain rules in order to ensure that carbon is effectively offset.

Suggested Rules:

===============

1. New tree planting counts. Preservation of trees from being cut down does not count.

2. Trees planted must be viable in the location planted for the expected lifespan of the trees.

3. Trees planted that are to be harvested for lumber hav e a different lifespan and therefor carbon offset value than trees that are planted to grow in forests that are not to be harvested.

4. Qualified biologists will provide the carbon credit v alues by consensus for the various species of trees planted since growth rate, size and lifespan duration will result in different carbon offset values.

5. The trees may not be harvested for burning, but may b e harvested for lumber, or for other uses that keep the carbon sequestered.

List of Tree Planting Organizations:

==============================

1. Trees for the Future - Trees for the Future is dedicated to planting trees with rural communities in the developing world, enabling them to restore their environment, grow more food, and build a
sustainable future.

2. American Forests - American Forests protects and restores forests, helping to preserve the health of our planet for the benefit of its inhabitants.

3. GROW - (Great Reforestation Organizations of Worth) consists of those nonprofit tree-planting organizations that practice the best standards within the industry. This is defined by setting benchmarks, providing excellent business partnerships, not engaging in scams or deceptions, focusing on quality at all levels rather than profitability; and engaging in reforestation that tangibly benefits more than simply forest ecosystems.

Thanks,
Shamus Thornton shamusd@pacbell.net

707-642-235257 From: Barbara McPherson [barbara.mcpherson@gmail.com] Sent: Friday, November 08, 2013 3:51 PM To: Carbon Pollution Input Subject: EPA listening session in Seattle Oct. 7, 2013



### Yesterday we attended the hearings in Seattle. While we appreciated the many requests for strict pollution

s tandards of existing power plants, we were somewhat disappointed by the lack of suggestions for practical solutions. These are solutions that can involve each of us. They relate to the way that utilities produce and distribute power.

Here is a practical suggestion. We have considered putting solar panels on our roof, but we have always rejected it because it would not be cost-effective. On top of that we disliked the idea that we would have to sell the generated electricity to our local power plant and then buy it back for our use.

We are talking about a house that sits in a not very densely populated area, where power outages are not unheard of. That means in case of emergency we would not be able to use our self-generated electricity. There are particular problems with batteries synchronizing with the grid.

We believe, that consumers would be much more willing to install solar or other electricity-producing devices on their properties, if they felt they have control over their own product. Of course this is mostly a psychological effect, but we believe that the installation rate of home devices would go up considerably.

Therefore, we urge you to include in your new rules and regulations a mandate for power plant operators to continue to have to buy the electricity generated by individual producers but only after the producer has
covered his own needs.

Sincerely,

Barbara and William McPherson58 From: drupal_admin@epa.gov on behalf of Regina Dentzman [dentzma1@gmail.com] Sent: Friday, November 08, 2013 3:15 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Fri, 11/08/2013 - 15:15

S ubmitted values are:

Name: Regina Dentzman
Email: dentzma1@gmail.com

Comments: The most effective way to reduce carbon pollution from existing power plants is to create a cap on carbon emissions. In ad dition to this, our great country should look to other nation's for the ways in which they not only reduced carbon pollution but increased use of renewable energies. Using other countries as a model provides us great evidence of what will and what will not work to get toward a goal of economic growth that includes renewable energy. This way, we can create new jobs in energies that do not negatively affect the environment nor our health (e.g. coal, natural gas). Providing federal subsidies to power plants to reduce their carbon production would be
effective. Perhaps the EPA could run commericals to endorse alternate energies such as wind and solar. The more accessible clean energies are to homes and communities, the more these ideals will spill over into workplaces and nearby power plants.
Web Area: Carbon Pollution Standards59 From: Steve Thompson [steve93thompson@gmail.com] Sent: Friday, November 08, 2013 2:23 PM To: Carbon Pollution Input Subject: Rulemaking for existing power plants



### Thank you for your listening session in Seattle. I listened to most of the verbal comments and was impressed

w ith the large base of people who support strong stringent regulations soon as do I. Suggestions:

1. When considering the cost impacts, as you are required to do, include all the external costs not currently calculated into the price of delivered electricity. These include current and future health costs caused by the pollution, costs of litigation over future liability, and costs of future clean up that we currently don't
even know how to address.
2. Create rules/regulations which place strong incentives on reduced energy use. Power companies are famous for historic "meter spin" programs. That type of thinking has to go away. There is a 100% reduction of all pollution when energy is no longer needed. Insulation, better windows, efficient electrical appliances and other smart home/business strategies can allow for future population growth and still eliminate the need for coal or NG power plants. Also PSE is proposing grid improvements for growth that would also not be needed (and associated costs) if energy use reductions strategies were aggressively pursued.
3. Make power companies pay for energy produced but not used by local grid connected producers like me. My residential solar system was sized to produce 100% of my historical usage plus enough for an electric car (10,000 miles per year). I don't yet have the car and my children have moved out so I am using less power. At the end of PSE's solar year April 30, any power left in my bank will become PSE's

at no cost. There is great potential for residential solar as some locations and little at other shaded locations. I can produce power for my neighbors who are shaded. Why should there be a dis-incentive for local investment in distributed power production? Most most building have a large potential for reducing energy use but the financial incentive is not there if we give the power to PSE who then can sell it at as premium green power. Is it true that energy companies do not like residential solar because it reduces their ability to make a fixed profit on infrastructure? If so please address that issue.
4. Converting coal power to natural gas is not a good strategy. The complete process of NG production is no better and probably worse than coal. Leaking NG is a horrible polluter.
5. While these rules appear to apply to air pollution, I urge you to consider water pollution as well. The PSE power plant at Colstrip Montana is polluting ever increasing amounts of ground water and there is no current technology for cleaning it up. These types of situations will in the future be similar to the - near hopeless- problems currently at the Hanford Nuclear Reservation. In twenty years, it is likely that PSE ratepayers will have to pay for groundwater pollution at Colstrip. You could make fossil fuel power companies put money in escrow for future liabilities of current pollution. That would help make the cost of renewable energy more competitive and drive renewable energy and storage technology innovation.
6. Oh how I wish fossil fuel companies had put their resources, efforts, and innovations into green energy instead of fracking, off shore drilling, and other hazardous operations.

I will close with a little story told by a relative on a recent visit to Chicago. In the early history of Chicago, the sewage was dumped into Lake Michigan and the water supply came from Lake Michigan, after all it was a really big lake. Well that went along fine, people lived their lives and business made money until a typhoid epidemic broke out. Seems like our air space is a really big space but like Lake Michigan, we are dumping into it. What and when will our epidemic be?60 

### Steve Thompson.61 From: William B. Grant [wbgrant@infionline.net] Sent: Friday, November 08, 2013 1:24 PM To: Carbon Pollution Input Cc: wbgrant@infionline.net Subject: Air pollution and cancer

Dear EPA:

T his paper estimates that three-to-five percent of U.S. cancer deaths can be attributed to air pollution. The cancer types identified as being associated with air pollution are mostly the same ones that are associated with smoking. The largest effects seem to be in the northeast and to be associated with coal fired power plants. While this is an ecological study, the results seem to be reasonable. The paper can be downloaded from the publisher's
website.

Sincerely,

William B. Grant, Ph.D. Sunlight, Nutrition, and Health Research Center P.O. Box 641603 San Francisco, CA 94164-1603, USA

www.sunarc.org wbgrant@infionline.net

1-415-409-1980

Anticancer Res. 2009 Sep;29(9):3537-45. Air pollution in relation to U.S. cancer mortality rates: an ecological study; likely role of carbonaceous aerosols and polycyclic aromatic hydrocarbons.

Grant WB.
Source

Sunlight, Nutrition and Health Research Center (SUNARC), P.O. Box 641603, San Francisco, CA 94164-1603, USA. wbgrant@infionline.net Abstract

BACKGROUND:

There are large geographical variations of cancer mortality rates in the United States. In a series of ecological studies in the U.S., a number of risk-modifying factors including alcohol, diet, ethnic background, poverty, smoking, solar ultraviolet-B (UVB), and urban/rural residence have been linked to many types of cancer. Air pollution also plays a
role in cancer risk.

MATERIALS AND METHODS:

Cancer mortality rates averaged by state for two periods, 1950-1969 and 1970-1994, were used in multiple-linear regression analyses with respect to many of the risk-modifying factors mentioned with the addition of an air pollution index in the form of a map o f acid deposition in 1985. This index is correlated with emissions from coal-fired power plants. In addition, lung cancer mortality rates for five-year periods from 1970-74 to 1990-94 were used in multiple linear regression analyses including air pollution and cigarette smoking.

RESULTS:

The air pollution index correlated with respiratory, digestive tract, urogenital, female, blood and skin cancer. Air pollution was estimated to account for 5% of male cancer deaths
and 3% of female cancer deaths between 1970- 1994. Solar UVB was inversely correlated with all62 these types of cancer except the respiratory, skin and cervical cancer. Cigarette smoking was directly linked to lung cancer but not to other types of cancer in this study.

CONCLUSION:

Combustion of coal, diesel fuel and wood is the likely source of air pollution that affects cancer risk on a large scale, through production of black carbon aerosols with adsorbed polycyclic aromatic hydrocarbons.

PMID:
19667146 [PubMed - indexed for MEDLINE] http://www.ncbi.nlm.nih.gov/pubmed/19667146

Free full text63 From: Richard Lindsey [mr.richard.lindsey@gmail.com] Sent: Friday, November 08, 2013 12:31 PM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website



## H ello EPA!

Please consider the coal replacement technology of SMR’s (Small Modular Reactor) in your deliberations to reduce the carbon footprint of coal power plants. A SMR can be installed in close proximity to the power feeds currently serviced by a coal plant for easy and inexpensive shifting of the power lines. The use of SMRs to replace coal plants would reduce global warming to near zero as compared to coal-fired plants.

Thank you,

Richard Lindsey64 From: Mark [mafalappi@comcast.net] Sent: Friday, November 08, 2013 9:04 AM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website

I would like to propose that the EPA spend money, time and effort in replenishing the trees

a nd forest and plant more trees that would consume the excess carbon dioxide.

With all the wild fires that have happened in the western part of the US, you would think the EPA would step up to replenish the "carbon dioxide consuming" trees that were lost.

There used to be a big push for planting more trees. Talk about a "green" movement. Where are all the environmentalist when a simple solution is right in front of peoples faces.

Sent from my iPhone65 From: George Robertson [george.robertson@consultgra.com] Sent: Thursday, November 07, 2013 9:12 PM To: Carbon Pollution Input Subject: Re:Input - 111(d) Carbon Pollution Standards for Existing Power Plants Public Listening Session Confirmation

I had hoped to speak to you all at the meeting but I discovered after arriving that there is no publicly accessible WiFi in the US Federal Building in Seattle. Because my files are stored on IBM smartcloud, I could not access my notes. Rather than to do do a bad job of trying to remember the fine points of my presentation and waste two minutes of everyone's time, I left. The points I had intended to present follow.

Policy regarding extension of permits for existing coal fired generation plants shall internalize within the enterprise a better than zero carbon footprint for current and past energy production and use.

All coal fired plants shall be immediately shut down except as provided below :

A. No coal fired plant shall operate prior to the commencement of and during continuous operation of new added carbon absorption that absorbs 120% of it's total carbon footprint.

Exception 1. provided that no new coal fired plants are built, an existing coal fired plant may be allowed to run temporarily while new "emissions free" * generation capacity that will replace no less than 40% of the coal fired plants maximum energy output is constructed annually by the utility.

* emission free means any fully internalized, raw materials extraction to end user, energy production solution with no net carbon or other greenhouse gas or particulate emission footprint.

Exception 2. a coal fired plant may be allowed to restart and run after the utility creates, and while it fully maintains, sufficient new natural green plant carbon absorption to absorb 120% of the total carbon production from mining and transporting the coal, operating the plant, and distribution of the power.

Exception 3. a coal fired plant may be allowed to run while a combination of natural green plant carbon absorption and a proven effective emissions filtration solution, that shall remove carbon emissions, is in operation, provided the combination is proven to absorb the equivalent of 120% of the total carbon production from modifying the plant , mining and transporting the coal, operation the plant, and disposal of the products of filtration and distribution of the power.

B. These regulations applied to coal fueled energy generation may be eliminated at such time as regulations that internalize the impacts of all coal uses are effective in application to all coal mining, producing the elimination or absorption of 120% of all carbon released from all coal mining, transportation, and end uses.

C. Similar regulations requiring the internalization of impacts should apply to all industry and agricultural operations that produce or cause to be produced, carbon or green house gas and particulate emissions that can contribute to environmental dis-equilibrium.

In this model the 120% requirement seeks to begin removing more carbon than is being released to restore historic environmental carbon levels in the interest of stabilizing the climate and restoring a lower level of ocean acidification. Scientists might be better at setting a perfect percentage target than I am, but we have to start somewhere.

Without these or equivalent measures our biosphere will continue to be disrupted, and the EPA will fail in66 it's core mission, and remain unworthy of its name. My grandchildren will be the judge of how well we performed in this, and so will yours.

George Robertson
GRA Inc PS 3416 19th Ave S Seattle, WA 98144-6706
206 723 420067 From: Bactow@aol.com Sent: Thursday, November 07, 2013 4:36 PM To: Carbon Pollution Input Subject: Carbon Absorbing Products That Help To Reduce Global Warming

Sir/Madame:

As Chairman and CEO of U.S. Harvest Energy & Technologies Corporation ( www.usheat.us ), we sincerely appreciate this opportunity to inform you and the listening audience of products we have recently developed that will allay concerns over how do we deal with anthropogenic CO 2 ., a major contributor to global warming. The answer is to trap, retain and recycle i t for commercial purposes. It is well known that TiO 2 (toothpaste whitener) will bind with H 2 S and NOx (two other

e xtremely important greenhouse gas components and major contributors to global warming) such as that being emitted from the over 1300 coal fired power plants in America but carbon absorption is the international prize. Since the Great East Japan Earthquake and nuclear meltdowns in March, 2011 (at Fukushima Japan) we have been working on products that will trap airborne radioisotopes such as Cs & Sr but we never imagined our products could be used to help reduce global warming by absorbing CO 2

.

O ur new, smart coated, advanced technical textile products are designed to literally absorb radioactive isotope particles of cesium and strontium such as those emitted from the Fukushima Nuclear Power facility in Japan, air pollution particulates such as PM 2.5, radio and microwaves such as those emitted from cell phones and other wireless devices, ubiquitous radon gas and CO 2 using Clinoptilolite Zeolites (natural minerals) for adsorption and absorption. Zeolites are currently being used in Japan with the ongoing nuclear reactor cleanup and have been used, in the past, as a food additive to protect the Citizens of Chernobyl, Russia from consumption of heavy metals and radiation poisoning (see article: Heart Disease Caused by Radioactive Elements). These specialized but easy to use interior decorations (passive wall coverings) and nuclear grade air filtration media are designed to make the environment in homes or offices essentially radio/particulate free and are available in America, Japan and throughout the world (UNPD Vendor #33387) . For more information about our products go to: www.usheat.us - ContactPage

.
Sincerely,

William L. Robinson, Jr. U.S. Harvest Energy & Technologies Corporation (443) 320-3123 - Phone ($10) 504-5258 - Ph/Fax68 From: "© 2013 Email Support Team" [dennisnelson987@yahoo.com] Sent: Thursday, November 07, 2013 10:23 AM To: Carbon Pollution Input Cc: dennisnelson987@yahoo.com Subject: PUSHING AN INHERENTLY CLEANER AND SAFER "'CARBON-FREE/NUCLEAR-FREE' ENERGY PATHWAY" MEANS SUPPORTING TOUGHER, FINAL STANDARDS TO CUT THE CARBON POLLUTION FROM ALL OF OUR EXISTING FOSSIL FUEL POWER PLANTS BY 35-40%!!

"USEPA PUBLIC LISTENING SESSION: 111(d) Carbon Pollution Standards For Existing Fossil

F uel Power Plants," U.S. Environmental Protection Agency (USEPA) Region V (5) Offices, Metcalfe Federal Building, 77 West Jackson Boulevard, Chicago, Illinois 60604; 12th Floor (Lake Michigan Room), Friday, November 8, 2013, 9 AM-4 PM. My name is DENNIS R. NELSON, and my mailing address is: 3817 South Winchester Avenue, 2nd Floor, Chicago, Illinois 60609-2011. I am one of the original, modern environmental/energy activists ever since around very first "EARTH DAY" (Wednesday, April 22, 1970), over 43 years ago--and still going strong! I have a Bachelor of Science (B.S.) Degree in Biology and Environmental Studies from Dana College, Blair, Nebraska 68008. I am the Vice President of the Chicago-based Nuclear Energy Information Service (NEIS), "Illinois' Nuclear Power Watchdog Group." Our website is: www.neis.org. Well, what does a "sound science-based" environmental/non-nuclear advocacy, research, and education group like NEIS have to do with supporting stronger, final USEPA carbon pollution standards for all of our current fossil fuel power plants to cut their carbon pollution between 35-40%? (NEIS recommends that these more stringent carbon pollution reduction standards be set for all of our newer fossil fuel power plants as well!) First off, NEIS was an integral part of the Chicago Clean Air Coalition, the citizens' group which put pressure on the City of Chicago to finally close the two older, polluting coal-fired power plants within the city limits, the Fisk Coal Plant in the [predominately] Mexican-American Pilsen neighborhood and the Crawford Coal Plant in the [mainly] Mexican-American Little Village neighborhood. Secondly, NEIA advocates a speedier, yet smoother, nationwide total transition within 30-50 years to a "'CARBON-FREE/NUCLEAR-FREE' ENERGY PATHWAY"--being the best technically and economically feasible way of getting off of all oil. 'CARBON-FREE/NUCLEAR- FREE' includes: [1]The full practical use of the best energy efficiency improvements. [2] Combined heat-andpower (CHP), otherwise referred to as co-generation. [3] Well-designed and properly installed dispersed/distributed appropriate renewable energy technologies using solar, wind, solid biomass, liquid biofuels, biogas, wave and tidal, hydropower, and geothermal. [4] An updated, modernized "'smart' electricity grid" with advanced energy storage. Continuing on, we desper ately need the U.S. Environmental Protection Agency to put the "final
touches" on TOUGHER FOSSIL FUEL POWER PLANT STANDARDS ASAP TO REDUCE THEIR CARBON EMISSIONS BY 35-40%--and not to "knuckle under" to the pressure of the bigger corporate fossil fuel polluters. In the absence of competitive market-based incentives to put a price on carbon (like a 'cap-and-dividend' and/or a 'carbon tax'): Such stronger, final carbon pollution reduction standards will be our BEST "REGULATORY SIGNALS" in the energy marketpla ce to hasten the implementation of these things: More efficient lighting, industrial motors, industrial processes, and household appliances; community-owned solar photovoltaic (PV) projects with "feed-in tariffs;" concentrating solar power (CSP), also called solar-thermal electricity; community-run wind turbines with "group-net-metering;" solid biomass-fueled combined heat-and-power/district heating plants; farm-based and municipal-based methane biogas co-digesters; tidal power systems; wave energy converters; stationery fuel cells using 'renewably-generated hydrogen'to produce electricity (and heat); newer micro-hydro systems; lower-temperature 'groundsource' geothermal heating and cooling systems; higher-temperature geothermal for 'geopower'69 electricity; and so forth. Efficiency, co- generation, and renewables provide us with the BEST "ENERGY BANG-FOR-THE-BUCK" in keeping the most carbon pollution out of the Earth's climate system. In conclusion, it has taken us more than 43 years since the very first "EARTH DAY" (when our global climate problem was known as the 'greenhouse effect'), about 25 years since the summertime heat wave of 1988, and five reports by the United Nations (UN)-appointed Intergovernmental Panel on Climate Change (IPCC) to finally reach this stage. The IMMEDIATE URGENCY of effectively dealing with human-caused climate disruption makes the FINALIZATION OF THE MOST STRINGENT CARBON POLLUTION REDUCTION STANDARDS POSSIBLE THE HIGHEST PRIORITY FOR THE U.S. ENVIRONMENTAL PROTECTION AGENCY. These tougher, final carbon pollution standards will result in HEALTHIER LIFESTYLES, besides a BETTER QUALITY OF LIFE, for single individuals (such as myself), families with children, and our
communities!

Respectively submitted, DENNIS R. NELSON, Energy-Environmental Researcher

[REFERENCES (a partial list): Arjun Makhijani, CARBON-FREE AND NUCLEAR-FREE: A ROADMAP FOR U.S. ENERGY POLICY, A Joint Project of the Nuclear Policy Research Institute (NPRI) and the Institute for Energy and Environmental Research (IEER), Takoma Park, Maryland: IEER Press, 2010 (3rd Edition), 257 Pages. Greg Pahl, POWER FROM THE PEOPLE: HOW TO ORGANIZE, FINANCE, AND LAUNCH LOCAL ENERGY PROJECTS, A Community Resilience Guide, Santa Rosa, California: Post Carbon Institute/White River Junction, Vermont: Chelsea Green Publishing, 2012, 259 Pages. Gar Smith, NUCLEAR ROULETTE: THE TRUTH ABOUT THE MOST DANGEROUS ENERGY SOURCE ON EARTH, White River Junction, Vermont: Chelsea Green Publishing, 2012, 279 Pages.]70 From: Bob Galteland [bgalteland@msn.com] Sent: Thursday, November 07, 2013 1:19 AM To: Carbon Pollution Input; carbon-pollutioninput@epa.gov Subject: Comment on reducing carbon from power plants - Use Hydro-Electric Power



### There was an article in the Seattle DJC saying you were soliciting comments on how to reduce carbon pollution from power plants. One way would be to increase the use of Hydro-Electric power plants. I don't know the specifics, but it seems Hydro-Electric power in the west is under siege to restore fisheries. Might there be a way to look at the amount of carbon burning electrical generation that is eliminated by utilizing Hydro-Electric power. A comparison could be analyzed comparing the decreased product ion of carbon gasses and the overall benefit to the environment and perhaps fish directly by replacing hydrocarbon generated electricity with Hydro-Electric generated power.

Bob Galteland Snohomish, Washington bgalteland@msn.com71 From: drupal_admin@epa.gov on behalf of Matt Owens [matthewowens95@yahoo.com] Sent: Thursday, November 07, 2013 12:59 AM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Thu, 11/07/2013 - 00:59

S ubmitted values are:

Name: Matt Owens Email: matthewowens95@yahoo.com

Comments: We may have to take carbon dioxide out of the air, even if we hypothetically stopped emissions right now. Therefore, if the goal is to reduce carbon pollution, then it's a bo ring goal. However, if the goal is to eliminate carbon pollution - or to price it so that we can later remove that exact same amount of carbon and pay for climate damages, then that's a worthy goal.

Obviously, if we were to be honest with ourselves, we'd be shutting carbon pollution down
with all due haste.

Considering the cost to remove carbon from the air is much higher than the cost to remove it at the source of emission, or to not emit it in the first place, I think the conclusion one
must draw is obvious.

If we wish to keep our sanity, we must now embark on an urgent transition to a renewable carbon-free energy future that also includes mechanisms to pull carbon from the air in order to compensate for the sources that we will not be able to - or which will not wish to halt. One useful role of the EPA may in part be to ratchet up carbon pollution standards and thereby lock in place productive change.

Sincerely,

Matt Owens executive director
Fairfax Climate Watch matthewowens95@yahoo.com
Web Area: Carbon Pollution Standards72 From: Ronal W.Larson [rongretlarson@comcast.net] Sent: Wednesday, November 06, 2013 5:42 PM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website

Apologies: I think this may be a duplicate. I may have sent this through your website - but am not sure that happened.

EPA comments - intended to have been given at your coal emissions hearing in Denver on 30 October

Listening Committee

My main point in this note is that the instructions for these hearings have omitted one important approach - that of carbon negativity. I have read the four question areas - and probably could squeeze my concern into one or more of those. But that does not seem the best way to justify adding a category to the many carbon neutral approaches you now have under study (wind, solar, DSM, etc) - all of which have been most of my life’s work. As near as I can tell, EPA is missing totally this additional carbon negativity approach applicable to all the electrical generating options under review (new, old, replacement, etc.)

An alternative descriptor of what I hope can appear in your final report on these hearings is the phrase “CDR” - Carbon Dioxide Removal. CDR is that portion of the larger policy area called “Geoengineering” which deals with actually removing carbon, not simply putting less in. - or hiding its effects through added aerosols In my opinion, taking out carbon is today more important than putting less in. The reason is that showing carbon negativity is practical is key to giving hope to the nation’s youth.

Most CDR approaches are energy consumers; two are not. The approach I do NOT favor is BECCS - Biomass Energy with Carbon Capture and Sequestration. It has had considerable Federal (DoE) funding - and is languishing. The approach I do favor and have worked on for longer that the name has been in use is “biochar”. The biochar area is NOT languishing, with an annual doubling time that might be as short as two years - more than 35% annual growth as measured by technical papers, new corporations, funds invested, etc. These accomplishments have occurred with essentially zero Federal funding (a few million per year at the USDA - using non-authorized/non-appropriated funds) - but with many dozens of excited federal soil scientists finding ways to get in a little research.

As a former national lab researcher (Branch Chief and first Principal Scientist at SERI from 1977 to 1982) and earlier a staffer for the US Congress, I understand how difficult it is to add new material in a review such as is now going on. I understand the circular file in which this plea could be placed. Nevertheless, I hope someone reading this understands the importance of adding this new category of action to which a utility can consider its possible mitigation action (biomass with pyrolysis). We are in danger of losing a decade in getting to what many European countries are already committed. Fortunately the IPCC’s AR5 document for policy makers did include CDR and biochar - apparently as a last minute decision. The EPA can do the same.

One problem with my biochar/CDR suggestion probably is that it addresses too many global problems. These hearings are on carbon, but biochar also addresses issues of soil degradation, food insecurity, waste management, fertilizer runoff, reduced irrigation needs, rural economic development, jobs, all the energy end-uses (biofuels, thermal needs, etc) and many more besides electricity. So, I hope the EPA individual(s?) who will read this can agree that our excess carbon emergency demands that the EPA adds this biochar tool for utilities and states to consider. There is a huge information data base to backup the claims of this note at www.biochar-international.org

.
I signed up to speak in Denver on 30 October, but decided instead to submit these comments in writing - so as to have a better chance to organize them logically. I have worked in the renewables area since 1973 (then in the first class of Congressional Fellows) and am a Fellow and former board chair of ASES - American Solar Energy Society. I of course support eliminating not just coal but all fossil sources. Here I am asking for the next follow-up step after achieving carbon neutrality: achieving carbon negativity. It is not too early to start.

Ronal W. Larson, PhD Golden, Colorado 31 October, 201373