350 Colorado Statement to EPA Regarding the Clean Power Proposed Rule Presented on July 30, 2014 at the Denver Hearing By Roberta Mooney, 350 Colorado Founding Board Member

Hello and thank you for this opportunity to provide public comment on the EPA Clean Power Proposed Rule. I am Roberta Mooney, an environmental attorney, and I'm speaking today on behalf of 350 Colorado, a nonprofit organization working locally to build a global GRASS

ROOTS movement to solve the climate crisis and transition to a sustainable future.

350 Colorado is very supportive of EPA's efforts to reduce carbon emissions from power plants through the Clean Power Plan, and while we believe that much deeper reductions in CO2 emissions than 30% below 2005 levels by 2030 are needed, we realize that this is an essential first step toward putting some limits on CO2 emissions that have so far been unregulated. The buildup of greenhouse gases in our atmosphere has already raised global temperatures by about 1 degree Celsius, and even now we have begun to experience terrible impacts, both here in Colorado with increased droughts, floods, wildfires and pine beetle epidemics, and around the world with more devastating storms, sea level rise, ocean acidification and more. Our planet has just had its hottest May on record, followed by the hottest June on record, and high temperature records around the world continue to be broken, posing ever more danger to human health and welfare. We thank the EPA under the Obama Administration for stepping up to its responsibility to protect human health and the environment by enacting measures to reduce carbon pollution.

Of course, CO2 is not the only green house gas of concern. 350 Colorado strongly urges the EPA to include in the Clean Power Plan the CO2 equivalent of other important greenhouse gases, especially methane - a powerful greenhouse gas. As you are likely aware, methane is the primary constituent of natural gas, and according to the 2013 report from the International Panel on Climate Change, the heat trapping power of methane is 34 times more potent than CO2 over a 100 years, 86 times more potent over the critical next 20 years, and 125 times more potent with feedback during the next decade.

In 2012 and 2013 studies, NOAA 1 observed that 4-9% of the methane accessed from oil and gasproduction, leaks directly into the atmosphere, contributing significantly to climate DESTABILIZATION. Another study by researchers at the University of California, Irvine 2

, published by the National Academy of Sciences this past March, showed that drilling operations at several natural gas wells in southwestern Pennsylvania released methane into the atmosphere at rates that were 100 to 1,000 times greater than the EPA has previously estimated. Using a

http://www.nature.com/news/methane-leaks-erode-green-credentials-of-natural-gas-1.12123

2 Toward a better understanding and quantification of methane emissions from shale gas development, http://www.pnas.org/content/early/2014/04/10/1316546111plane that was specially equipped to measure greenhouse gas emissions in the air, scientists found that drilling activities at seven well pads in the booming MAR-CELL-US shale formation emitted 34 grams of methane per second, on average - far greater than EPA's estimates that such drilling releases between 0.04 grams and 0.30 grams of methane per second.

These leakage rates have led some analysts to surmise that natural gas produced by hydraulic fracturing and horizontal drilling, also known as fracking, is perhaps even more dangerous for the climate than burning coal, since many wells leak far more than THE 3.2% "break-even" point beyond which methane leakage rates are considered worse for the climate than coal burning. 3 Since 2007, atmospheric methane concentrations have been rising rapidly'', and the recent increase in fracking for oil and gas in the United States and elsewhere, is a likely contributor to the higher methane levels.

If the CO2 equivalent of methane is not considered as part of the Clean Power Proposed Rule, the consequence could be power-source switching from coal-burning to natural gas-burning Power Plants, since burning natural gas (which is mostly methane) produces about half as much CO2 per unit energy as burning coal. However, if the intention of the Clean Power Plan and the President's Climate Action Plan is to mitigate climate change, then it would be folly not to consider the heat-trapping impacts of methane leakage during the production and transportation, as well as the burning, of natural gas.

In order to achieve the greenhouse gas reductions needed to avert catastrophic climate change, we must transition as rapidly as possible off all fossil fuels, including natural gas, and quickly ramp up our use of renewable energy, energy efficiency, and conservation. Resource switching from coal to natural gas would waste valuable time and Utility Ratepayers' money, with little to no climate benefits. So it is vital that the Clean Power Plan does not inadvertently reward switching to natural gas by not considering the CO2 equivalent heat-trapping potential of

methane.

Again, 350 Colorado thanks the EPA for its work to reduce greenhouse gas emissions from vehicles, power plants, and other sources. Get this right, and our children and future generations will also certainly be grateful.

3 Alvarez, R. A., Pacala, S. W. Winebrake, J. J., Chameides, W. L. & Hamburg, S. P. Proc. Natl Acad. Sci. USA 109, 6435-6440 (2012).

4 http://www.scientificamerican.com/article/why-is-there-more-methane-in-the-atmosphere/