To: Environmental Protection Agency EPA Docket Center (EPA/DC) Mailcode 28221T 1200 Pennsylvania Avenue, NW. Washington, DC 20460 Date: July 30, 2014 From: Dr. Jalonne L. White-Newsome, Federal Policy Analyst

WE ACT for Environmentai Justice weact.c;r r~ Re: ®ocket ID No. OAR-2013-0602

Thank you for the opportunity to testify today on the EPAs proposed Clean Power Plan. My name is Dr. Jalonne L. White-Newsome and I am federal policy analyst for WE ACT for Environmental Justice, a 25- year old community based environmental justice organization working to build healthy communities through education, research and advocacy. We can no longer deny that emissions of CO2 continue to dampen our resilience to the biggest pubiic health threat of the century, climate change. So your job — and how this Plan is operationalized - is mission critical to protecting the heaith, welfare and quality of life of all Americans, especially thoseliving in communities that are constantly breathing in a myriad of carbon dioxide and other copollutants. While WE ACT is supportive of all the EPAs efforts through the Climate Action Plan to reduce emissions of toxic pollutants, we do have some concerns that we would like to share regarding the potential environmental justice implications of the Clean Power Plan. I will briefly touch on 3 topics: the SIP Process, Mitigation measures and Credits.
® l.et's start with the SIP Process. The SIP Process: Because the Plan offers a'menu' of options for states to meet designated emission goals, it is critical that conducting an environmental justice analysis be a required part of the SIP Process. Some states will focus on improving J. White-Newsomedemand side efficiencies, and others will consider increasing raising their renewable portfolio

standards, and other mitigation tactics. Understanding how these measures could impact low income, communities of colors is critical. Not only should an ej analysis be required, but states should be required to develop multi-pollutant plans, similar to Colorado. Often times in EJ communities, it's CO2 in addition to the other pollutants that really drive negative health
outcomes.

• Secondly, Mitigation practices: The plan is very slanted towards cap and trade as being the most viable option to meet carbon emissions. Other options should be presented, such as carbon pricing. If cap and trade is given as an option, there MUST be controls integrated into the process to make sure that reductions are actually happening in the communities being impacted. Offsets and allowing the most polluting companies to'buy their way out' of compliance is not acceptable. We recommend that EPA present other options that could reduce the disparate impacts of cap and trade are required, such as (1) Identifying high-priority or poilution zones where polluters would pay a higher carbon tax or permit price to give a stronger incentive for industries to reduce emissions, and/or (2) creating a community benefit fund where some fraction of revenues from the carbon tax or permit auctions are channeled into measures that mitigate co-pollutant impacts and enhance community resilience.

• And last but not least, Credits: We feei that the burning of biomass should not be counted as 'credit' towards reducing carbon emissions. Biomass burning often creates more of a health hazard than other mitigation strategies. Why is this considered an option by the agency? The elimination of burning biomass, as well as carbon capture and sequestration (processes typicaily sited in ej communities) as viable options to receive 'credit' for emission reductions should be reconsidered.

2 J. White-NewsomeThere are many more concerns that we will address iater, but we hope that you will consider using the

Principles of Environmental Justice, the Climate Justice Principies for guidance as you finalize this rule, as well as remembering the Intent of Executive Order 12898 and the Title VI of the Civil Rights Act as you hone in on a final rule. In conclusion, we appreciate the EPAs efforts we hope that you strongly consider making an environmental justice analysis a required component of the State Implementation Planning Process, that you carefully provide in the plan a more balanced selection of mitigation options, and remove any 'credits for biomass burning and CCS" to insure that the civil and human rights of all Americans are upheld. Thank you for your time.

3 J. White-Newsome