t

AMERICAN 

LUNG 

ASSOCIATION® 

OF THE MID-ATLANTIC 

Serving Delaware, New Jersey, 

Pennsylvania and West Virginia 

Testimony of 

Kevin M. Stewart 

Director of Environmental Health 

American Lung Association of the Mid-Atlantic 

Before the 

United States Environmental Protection Agency 

Regarding its 

Clean Power Plan Proposed Rule 

(Carbon Pollution Guidelines for Existing Power Plants: 

Emission Guidelines for Greenhouse Gas Emissions from Existing Stationary Sources: 

Electric Utility Generating Units) 

Docket ID No. EPA-HQ-OAR-2013-0602 

William S. Moorhead Federal Building 

1000 Liberty Avenue 

Pittsburgh, Pennsylvania 

July 31, 2014 

Good morning. I thank the panel for your work here today. 

I am Kevin Stewart and I serve as Director of Environmental Health for the American Lung 

Association of the Mid-Atlantic. I represent not only the three million people in our four-state 

service area who suffer from chronic lung disease, but also the tens of millions more who desire 

to breathe clean air and so protect their good health. 

We have supported the Environmental Protection Agency's efforts to set strong carbon pollution 

standards for new power plants. We have likewise looked forward to EPA's establishment of 

similar standards for existing power plants. 

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There are standards, and properly so, for air toxics, acid gases, heavy metals, smog-forming and 

soot-forming emissions from power plants, and there is no excuse for there not to be standards 

for carbon pollution as well. Anything less shortchanges our health and our children's health. 

Health concerns 

We are here to remind everyone of why we need strong controls on carbon pollution and on air 

pollution in general: Reducing carbon pollution will help protect public health. 

Carbon pollution results in higher temperatures that enhance the conditions for ozone (smog) 

formation. Even with the steps that are in place to reduce smog, increasing temperatures are 

likely to increase the risk of unhealthful smog levels in large parts of the United States, and to 

lengthen the ozone season. Indeed, as the American Lung Association's State of the Air report 

(April, 2014) recently demonstrated by showing an increase in the three-year average number of 

days of unhealthful ozone at nearly every monitor in our service area compared with last year's 

report, we cannot rest assured that ozone levels will always continue to diminish. 

In addition, just as the National Climate Assessment (May, 2014) does not limit its concerns to 

the direct effects of temperature on smog formation, the Lung Association also recognizes other 

consequences: 

• Higher temperatures result in increased energy production and electricity use—e.g., for 

air conditioning—and in increased emissions of fine particles and their precursors. 

• Pollen and mold spore production increase. These are known to act synergistically with 

ozone and other pollutants to exacerbate asthma and allergies. 

• Increased carbon dioxide levels promote the growth of plants and hence result in the 

production of more ozone precursors. 

• The risk of wildfires and their pollution increases. 

• Vector-borne diseases show evidence of doing so. 

• The potential for severe weather events increases. In our service area, Superstorm Sandy 

resulted in mold and health problems in tens of thousands of homes that people 

experience to this day. 

Benefits of the rule 

While EPA makes clear that "the primary goal of the proposed guidelines is to reduce emissions 

of CO2," by 2030, according to its Regulatory Impact Analysis (June, 2014), not only do the 

climate benefits alone from CO2 reductions amount to about $30 billion ($US2011) annually 

(discounted at the 3 percent discount rate in the federal Social Costs of Carbon analysis (Nov., 

2013), on which rate the government has centered its attention), but also the corresponding 

health co-benefits are valuated at on the order of up to two times as much as the climate benefit 

portion. 

Furthermore, the annual total benefits by 2030 accrue to a factor ranging between 6.6 and 12.2 

times the accompanying compliance costs (again, presuming a three percent discount rate). And 

this ratio is calculated without monetizing and including the potentially significant benefits such 

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as those that result from reduced environmental exposure to sulfur dioxide, nitrogen dioxide, 

mercury, and hydrochloric acid. 

Moreover, according to the Co-Benefits of Carbon Standards report by Syracuse and Harvard 

Universities (May, 2014), "with a strong carbon standard, air quality and atmospheric deposition 

improvements would be widespread with every state receiving some benefit. The greatest 

improvements are projected for states in and around the Ohio River Valley as well as the Rocky 

Mountain region." Indeed, model results consistently show air quality improvements in western 

Pennsylvania projected to occur under this rule to be among the largest in the country. 

Stronger targets 

While the American Lung Association supports the Clean Power Plan, we find that some 

improvements in its Best System of Emission Reduction (BSER) formulas would strengthen it: 

• The more that energy efficiency and renewable energy generation displace the generation 

from the dirtiest fossil fuels, greater emissions reductions would result than EPA has 

assumed, so the BSER targets should be set higher. 

• Many emission reduction measures are already occurring in the states, so the formulas 

need to account for that. For example: 

o States' energy efficiency measures are already demonstrating a higher energy 

savings rate (over 2%) than is recognized in the targets (1.5%). 

o Utilities have already planned replacements of old, high-emitting plants with 

lower-emitting resources; those changes are not fully recognized in the formula. 

o The formula does not account for the emissions from new natural gas plants 

currently planned. (Though included as a way to comply, their additional 

emissions are not factored into the formula for the targets themselves.) 

• With the caution that there are several reasons for excluding biomass combustion from 

the menu of clean alternative energy sources, base the inclusion of a wide variety of clean 

renewable generation in the formulas on resource availability rather than limited to 

currently mandated levels. 

• Include opportunities for transmission and distribution efficiency improvements. 

The bottom line is this: 

EPA must make certain that its standards do not simply tally reductions that would have been 

achieved even had the Clean Power Plan not been in place. I must stress: We are in the midst of 

a slow-motion crisis of global proportions. It is, to be sure, irregular and intermittent in its 

progression. As a result, many are apt to deceive themselves and others about the necessity for 

serious action. But the crisis is real and on the scale of decades it is inexorable, so the objective 

here must not be one of doing the minimum necessary to meet some arithmetic goal, but rather 

one of finding ways to do as much as possible to reduce the severity of the impacts already on 

their way. 

Indeed, as the President's Council of Economic Advisers recently underscored in its report The 

Cost of Delaying Action to Stem Climate Change (July, 2014), "An analysis of research on the 

cost of delay for hitting a specified climate target (typically, a given concentration of greenhouse 

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gases) suggests that net mitigation costs increase, on average, by approximately 40 percent for 

each decade of delay. These costs are higher for more aggressive climate goals: each year of 

delay means more CO2 emissions, so it becomes increasingly difficult, or even infeasible, to hit 

a climate target that is likely to yield only moderate temperature increases." 

People at risk 

I conclude by recounting that people at special risk of sickness or even death from air pollution 

include infants, children, the elderly, persons with asthma or COPD, those who are immunecompromised, and people in indigent and minority communities. 

We emphasize that these populations are not a small minority of particularly sensitive persons, 

but in the service territory of the American Lung Association of the Mid-Atlantic — Delaware, 

New Jersey, Pennsylvania, and West Virginia — are constituted of groups containing hundreds of 

thousands or even millions of individuals. They include the following: 

• 5.4 million infants, children and teens under 18 

• 3.7 million persons aged 65 and above 

• 510,000 children with asthma 

• 1.8 million adults with asthma 

• 1.25 million adults with chronic obstructive pulmonary disease (COPD) 

• 1.7 million persons with cardiovascular disease (excluding hypertension) 

• 1.9 million persons with diabetes, and 

• 3.1 million persons living in poverty. 

• Pregnant women, their developing unborn, persons who work or exercise outdoors, 

and many others with existing health problems are also at risk. 

Indeed, far from being a small minority, persons falling into one or more of these high 

risk groups together compose more than half the population. And even more important to 

remember: As you heard a few minutes ago from Mrs. Franks, these are not faceless numbers ... 

Every one of these millions is a real person, not a nameless statistic. Every one of these people 

is a human being worthy of our protection — a neighbor, a coworker, a friend, a family member, 

maybe even yourself. 

The American Lung Association's mission is to save lives by improving lung health and 

preventing lung disease. Let's get about the business of saving some lives. 

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