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. 

Consider 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! 

 

Girard J. Gurgick, P.E., BSCE, MBA, President 

G

2

EM 

43883 Stronghold Court 
2

Ashburn, VA 20147-3919 

GGurgick@GSquaredEM.com

http://www.GSquaredEM.com

http://www.linkedin.com/in/girardgurgick

 C: 703 302 9944 
3

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 forms 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, and 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 area, 

however, you can put in your own cost per kilowatt-hour to better reflect your own 

usages. 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 other 
5

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 CO2 production, and others that may open 

your eyes to the true expense of the different types of light sources.

Thank you for your consideration of this comment. 

Ben Kolstad 

237 NW 7th St 

Boca Raton, FL 33432 
6

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 takes 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 Fuel 

 
9

-----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 your 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 miles 
10

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 Fuel 
12

 

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 Fuel 
13

 

-----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 below 

 

 
14

 

 

 

 

 

 

 

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

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
15

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
16

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
17

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
18

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 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 . H 

 

 

 

 

 

 
19

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
20

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
21

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
22

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
23

 

 

 

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 

 

 

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32

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 

Submitted 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 Natural 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 Standards 
33

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 

powerplants. 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 

atmosphere 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 

output, 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 

to 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 assumption 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 waste
34

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 98368
35

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, 

We 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 thermal 
36

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 Clean 

Energy 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.pdf 
37

[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

df 
38

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 

Submitted 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 Standards 
39

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 

Submitted 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 feedstock 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 significant 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 to 
40

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 Standards 
41

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, 

We 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 thermal 
42

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 Clean 

Energy 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.pdf 
43

[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

df 
44

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, 

We 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 thermal 
45

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 Clean 

Energy 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.pdf 
46

[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

df 
47

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, 

We 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 thermal 
48

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 Clean 

Energy 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.pdf 
49

[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

df 
50

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 

Submitted 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 fuel 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 Standards 
51

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 

regulations 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 

states 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 stacking 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 Einstein 
52

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 

Submitted 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 Standards 
53

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: 

Problem: 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 importantly, 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 98006-4514 
54

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 

following 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 Engineer 
55

SCS ENGINEERS

2830 Dairy Drive 

Madison, WI 53718 

608.224.2830 

Direct: 608.216.7359 Cell: 608.695.0575 

www.scsengineers.com
56

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 have 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 values 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 be 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

707-642-2352 
57

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 

standards 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 McPherson 
58

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 

Submitted 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 addition 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 Standards 
59

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 

with 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: 

This 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 of 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 all 
62

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 text 
63

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

Hello 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 Lindsey 
64

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 

and 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 iPhone 
65

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 in 
66

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 4200
67

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 CO2., a major contributor to global warming. The answer is to trap, retain and recycle 

it for commercial purposes. It is well known that TiO2 (toothpaste whitener) will bind with H2S and NOx (two other 

extremely 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 CO2. 

 

Our 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 CO2 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/Fax 

 

 

 
68

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 

Fuel 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 desperately 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 marketplace 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 production 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.com
71

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 

Submitted 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 boring 

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 Standards 
72

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, 2013 
73