David K. Moscatello 4523 Osage Avenue Philadelphia, PA 1943-2111

July 31, 2014

Environmental Protection Agency EPA Docket Center (EPA/DC), Mailcode 28221T Attention Docket ID No. EPA-HQ-OAR-2013-0602 1200 Pennsylvania Avenue, NW. Washington, DC 20460

I strongly support the EPA's effort to limit industrial carbon pollution from existing power plants. As the single largest source of carbon pollution, responsible for 40 percent of the carbon dioxide emissions in the United States, reducing carbon pollution from these power plants is an essential step to address climate change, which is leading to more frequent, destructive, costly and deadly extreme weather events.

The strong, yet flexible standards proposed by the EPA will push every state to do its best to cut carbon emissions from power plants by at least 30 percent below 2005 levels by 2020. We can replace the retired dirty coal plants with geothermal, solar, and wind energy, and the growth in these industries will more than replace the jobs lost from the coal industry.

Last year, wind energy contributed 4.13% of total U.S. electricity according to the National Renewable Energy Laboratory (NREL), or 4.8% according to the American Wind Energy Association (AWEA), up from under 2% just five years ago.

At the end of 2013, nearly 80,000 workers were employed in wind industry jobs, at the many wind farms in the USA (http://www.thegreenjobbank.com/green-jobs/wind-energy-jobs), nearly as many workers as all the coal miners in the U.S. (Average Number of Employees by State and Mine Type, Energy Information Administration), and most of these jobs have been created since 2005. More than 89 percent of all U.S. wind capacity has been installed since 2005. Prior to 2005, only one wind turbine original equipment manufacturer (OEM) assembled utility-scale turbines in the United States. By the end of 2012, a total of 12 nacelle assembly facilities were online.

This growth in U.S. wind-related manufacturing has occurred across the entire supply chain — there are currently 13 facilities producing blades and 12 tower manufacturing facilities. This growth has attracted supply chain companies capable of supplying the 8,000 components comprising a wind turbine. As a result, there are now at least 559 wind-related manufacturing facilities spread across 44 states supplying components to the wind energy industry, so that 67 percent of U.S.-deployed turbines' value being manufactured domestically in recent years, up from less than 25 percent prior to 2005. In addition to the direct manufacturing and maintenance jobs, wind turbines have become a "drought-resistant cash crop," providing consistent income for farmers and ranchers who host turbines on their land.

By the end of 2013, a total of 61 GW of wind power was installed, with overl2 GW of wind turbines are under construction in 2014. Lessons from the wind farms deployed to date have resulted in substantial improvements in turbine technology, with turbines getting larger and more efficient, such as the new 2.5 MW turbines from General Electric feature sensors and interne connections enabling more efficient operation, and includes 50 kilowatt-hours of storage for each turbine, smoothing out power supply from wind farms. Given the proximity to the densely populated mid-Atlantic and Northeastern states, our excellent offshore wind potential is an essential part of our wind resources.Without question, solar must be a big part of our future energy portfolio, and as much as possible should be on existing rooftops. In 2013 Photovoltaic (PV) installations increased 41% over 2012 to reach 4,751 MW(dc), and 410 MW(ac) of concentrating solar power (CSP) plants also came online. Solar was the second-largest source of new electricity generating capacity in the U.S., exceeded only by natural gas. And the cost to install solar fell throughout the year, with average system prices ending the year 15% below the mark set at the end of 2012. In fact, solar accounted for 29% of all new electricity generation capacity in 2013, and more solar has been installed in the U.S. in the last eighteen months than in the 30 years prior.

As always, we must ask "compared to what'?" when considering energy options. In the heart of the Marcellus Shale boom, the pipelines being installed are mostly from Korea. Which has the greater potential for damage to wildlife, another thousand or so more turbines at existing wind farms in Pennsylvania, or many thousands more well pads and waste ponds for hydraulic fracturing for natural gas and oil? From 2002 through 2012, 6,283 unconventional oil and gas wells were drilled in Pennsylvania on more than 2,700 well pads. It's estimated that at least 60,000 wells will be needed to maintain oil and gas from the Marcellus Shale formation by 2030. Even just doubling the number of well pads would mean far more forest fragmentation, plus air and water pollution, would result from gas exploitation sufficient to just maintain output than from a complete build out of projected Pennsylvania wind resources. And I haven't even touched on the climate impacts of wind versus fossil fuels.

New, industrial-scale batteries are being deployed in both wind and solar farms to store excess power generated when the facilities are operating at peak capacity, then distribute the power during off hours. This smooths out the power supply from the wind farms, thus avoiding a lot of the disruptions and reliability issues that came along with the fact that the wind does not always cooperate with the needs of us humans.

Besides direct generation of electricity, each year approximately 30,000 solar water heating and cooling (SHC) systems are installed in the U.S., generating an estimated $435 million in annual revenue. There is currently 9 GWth of SHC capacity installed in the U.S., and the country ranks 36th in the world in installed capacity relative to its population.
So, not only are prices for both solar and wind power dropping rapidly, but efficiency is increasing and power storage is being deployed to smooth out power availability. Furthermore, no state, Pennsylvania included, has to go uit alone, anymore than we do now. Studies of actual regional grids, such as the PJM grid encompassing PA, NJ, DE, MD, VA, WV, and OH, with parts of KY, IN, IL, and MI, have found that combinations of solar, wind, and electrochemical storage can reliably power the grid with up to 99.9% reliability, tossing the old line that "the sun doesn't always shine and the wind doesn't always blow" into the dustbin of expired excuses.

It is certainly true that this measure alone won't reverse global warming, but it's a good step in the right direction. Yes, every nation in the world needs to address the same questions, but the fact that some other countries behave badly in this regard is no reason to dodge our own responsibilities. We will not lead the world from behind! By pushing the required renewable technologies now, the United States can achieve true energy independence, increase national security, and gain a competitive edge - or we'll be buying the technology from China in twenty years and suffering far greater economic shocks as the price of fossil fuels skyrocket and the impacts of climate change start to get serious.

Sincerely, 

# -mok 4

,t4,10-tirl

David K. Moscatello, Ph.D. 4523 Osage Avenue Philadelphia, PA 19143
dkmoscatello@verizon.net