EPA Testimony- Carbon Hearing Docket No. EPA-HQ-OAR-2013-0602 (for the Clean Power Plan for Existing Sources)
Pittsburgh, PA August 1, 2014 janice Milburn 114 Mountain Road, Ligonier, PA 15658 724- 238- 4968

My family has resided in western Pennsylvania for generations. My attachment to the area has only been marred by the pollution thatwe endure and the illnesses it causes and exacerbates. I strongly urge EPA to take action to protectour air and consequently our health.

According to a recent Harstad Strategic Research Poll more than two- thirds of Americans agree that the EPA should limitcarbon pollution. Powerplants, which spew out 40% ofcarbon emissions in our country, should not be free to dump unlimited carbon into the atmosphere, intensifying climate change and endangering ourhealth. Pennsylvania ranks second worst 111 the nation in overall power plant pollution, according to a 2011 report based on EPA data. Seven Pennsylvania's coal-fired power plants are among the 100 highest industrial emitters ofgreenhouse gases in the United States, (Environmental Protection Agency, 2012). The EPA mustdo what Congress and the Supreme Court directed it to do many years ago: cut carbon emissions from the power sector nationwide by 30% below the 2005 levels.

As an important co-benefit, particle pollution, nitrogen oxides, and sulfur dioxide will be cut by more than 25%; this will result in avoiding up to 6,600 premature deaths, up to 150,000asthma attacks in children, and up to 490,000 missed work or school days-providing up to $93 billion in climate and public health benefits.

Coal fired power pants are responsible for about 90% ofthe power sector's COz, and for the vast majority ofthe powerindustry's sulfur dioxide, nitrogen oxides, hydrochloric acid, mercury, arsenicand particulate matter. According to the American Lung Association, these chemicals combine to create a stew ofsome 386,000 tons of hazardous air pollutants peryear. A2009 report from the National Research Council found that sulfur dioxide and nitrogen oxides alone impose $62 billion a year in public health cost. A2010 report from the Clean Air Task Force estimates that coal power was responsible for 13,200 premature deaths, 20,000 heart attacks and 9,700 additional hospitalizations that year. [PostGazette, 11-2012)
Pittsburgh ranks among the top ten cities where the highest number of cardiopulmonary deaths occur thatare attributable to particulates. A studyfound a 25% increase in risk for Sudden Infant Death Syndrome in cities with high particulate air pollution. ("Breathtaking: Premature Mortality Due to Particulate Air Pollution in 239 American Cities, NRDC; Woodruff, The Relationship Between Selected Causes ofPost Neonatal InfantMorality and Particulate Air pollution In The US, Env. Health Perspective, sited in Clean Air Council Report, 1998) Those costs are not factored into coal's market price.



### 1In a study commissioned by the Clean Air Task Force, itwas found that Greene and Washington Counties spend over $300,000 on health effects from dirty power plants. Those effects include heartattack, asthma attack, chronic bronchitis and even death. And air pollution is linked to a range ofailments never before thought ofas environmentally related-diabetes, attention deficit disorder, autoimmune diseases, Parkinson's and heart disease. The use ofcoal has only been affordable over the decades because we have been footing the bruntofthe bill in health costs. (Clean Air Council)

Doctors note that carbon pollution cycle is dangerous for children in general. Itraises air temperatures, which worsens smog pollution, which triggers asthma attacks and can permanentlyreduce lung function in some children. Emergency

room visits for respiratory problems can double on high ozone days and asthma attacks increase by nearly a third when ozone levels reach even halfthe currentlegal level. (National Voter, 99)

judy Focarets, a maternal-child nurse in Pittsburgh applauds EPA efforts and notes: 'While otherstates have improved their air quality and conversely reduced their premature birth rates, we have not been able to move that here." (Tom Joseph, Public News Service. 2012) Stanford scientist Markjacobson, a professor ofcivil and environmental engineering, spelled out for the first time the direct links between increased levels ofcarbon dioxide in the atmosphere and increases in human mortality. (jacobson, 2008)

While it has long been known that carbon dioxide emissions contribute to climate change, this study details how for each increase of 1 degree Celsius caused by carbon dioxide, the resultingair pollution would lead annually to abouta thousand additional deaths and many more cases ofrespiratory illness and asthma in the United States. Worldwide, upward of20,000 air-pollution-related deaths peryear per degree Celsius may be due to this greenhouse gas.

"This is a cause and effect relationship, notjust a correlation," saidjacobson ofhis study. "The study is the first specifically to isolate carbon dioxide's effect from thatofother global-warming agents and to find quantitatively that chemical and meteorological changes due to carbon dioxide itselfincrease mortality due to increased ozone, particles and carcinogens in the air."

The effects ofcarbon dioxide's warming are most significant where the pollution is already severe, worsening people's health in cities already experiencing pollution ata much faster rate than elsewhere in the nation. Much ofthe population ofthe United States already has been directly affected by climate change through the air they have inhaled over the last few decades and those health effects will worsen iftemperatures continue to rise.

Jacobson calculated the amount ofozone and airborne particles that result from temperature increases caused by increases in carbon dioxide emissions. Ozone and particles cause and worsen respiratory and cardiovascular illnesses (including out of hospital cardiac arrest (Ensor and Raun, 2013), emphysema and asthma, and many published studies have associated increased ozone with higher mortality. jacobson calculated the effects ofincreasing temperatures on pollution. He observed two important effects:

2Higher temperatures due to carbon dioxide increased the chemical rate ofozone production in urban areas. Increased watervapor due to carbon dioxide-induced higher temperatures boosted chemical ozone production even more in urban areas.

And in general, where there was an increase in watervapor, particles that

were presentbecame more deadly, as they swelled from absorption ofwater. "That added moisture allows other gases to dissolve in the particles-certain acid gases, like nitric acid, sulfuric acid and hydrochloric acid," jacobson said. That increases the toxicity ofthe particles, which are already a harmful componentofair pollution.

jacobson also found thatair temperatures rose more rapidly due to carbon dioxide than did ground temperatures, changing the vertical temperature profile, which decreased pollution dispersion, thereby concentrating particles near where they formed. "Ultimately, you inhale a greater abundance ofdeleterious chemicals due to carbon dioxide and the climate change associated with it, and the link appears quite solid," he said. "The logical next step is to reduce carbon dioxide: Thatwould reduce its warming effect and improve the health ofpeople in the U.S. and around the world who are currently suffering from air pollution health problems associated with it." http:

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In the remainder of my statement I will reference ozone, particulate, NOx, and sulfur dioxide based on their relationship to the production orreduction ofcarbon pollution.

In Westmoreland County where Ireside, and in much ofwestern PA, we are already in a state ofnon-attainmentfor ozone. We have a high incidence ofasthmatic children and high rates ofcertain cancers and birth defects. According to Scorecard records, compiled by Green Media Toolshed, and based on 2002 data (Scorecard's data about criteria air pollutants are derived from U.S. EPA's Air Q\lillitySYstem and Niltiona! ErnissionsTre.ru! database), Westmoreland County ranks in the worst 90% ofcounties nationwide for VOCs, nitrogen oxide, and carbon monoxide. It also ranks in the dirtiest 80% ofcounties nationwide for PM 2.5 emissions and sulfur dioxide. bll.c;_//scorerard.goodguidhU!JllLenv- releases/cap/cQlllit,J(.tcl?f!ps con nty cod c-4212._9

**#~11r r<.~nkings**  The county ranked in the 80 to 90% ofworst counties for cancer risk and developmental toxicants. httn: 1/srorc_card.goodJ,:uitle.comtenv**rdc~lscs** /u\unty.tci?tips_<.-:mm.tJ:__.rodc-"·12129#nnior lhcmical rdeases file: //localhost/( httpj_;.;_i;corccq_rd.goudguidc .com:.fUV- rcl

**e<.~scs:** rankmg.td:J(r3Ffips cnunt_y code-42129 Westmoreland County is not in compliance for ozone standards, and was awarded a grade ofD bythe American Lung Association based on ozone pollution.

Dr. Levy, joel Schwartz, and LisaK. Baxter completed a study in 2009, published in RiskAnalysis, that puts values on the health damage from pollution, including premature deaths. (Post Gazette, Templeton and Hopey, 12-19-11) The study offers a range ofhealth-related damages of$30,000 to $500,000 for every ton offine-particle, or PM 2.5 pollution, with a median rate of$72,000 per ton. For each ton ofsulfur dioxide pollution, or SOx, the health damage ranges from $6,000 to $50,000 per ton, with a median rate of$19,000. For nitrogen oxide pollution, NOx, the per-ton rate ranges from $500 to $15,000, with a median cost of$4,800. (Existing compressor stations in southwest Pennsylvania yield 877 tpy ofNOx.)

Using tbe median per-ton costs ofhealth damage, the total annual health



### 3damage from the region's major sources ofpollution is $9.4 billion. Such costs are "external" because they are borne by the public rather than industry. We cannot afford this burden physically orfinancially. Butdo not change reliance on coal to reliance on natural gas- simply exchanging one dirty fossil fuel for another. Or to nuclear energy with its own unsolved problems.

Just one gas compressor station, Frazier, for example, will add to our air: tons ofsulfur dioxides, carbon monoxide, VOCs, formaldehyde, and 35.04 tons ofNOx peryear, more than the current emission rate for cars peryear. NOx is a precursor to ozone. Westmoreland County alone has 26 new compressor stations and processing plants since 2008.

Methane produced bygas operations also contributes to ozone and itis produced atfar higher rates than originally thought- duringthe drilling phase, according to Purdue and Cornell researchers, 1000 times more. And methane is a potent greenhouse gas, 20 to 30 times more potentthan C0 2• A National Oceanic and Atmospheric Administration study found that 9% ofgas pumped outofthe ground leaks into the atmosphere. Malcom Sweney ofCIRES Utah, the first to actually sample the air downwind via an aircraft, found methane leakage to be 6.2 to 11.7%.

Neither Allegheny nor Westmoreland County is in attainment for ozone at the presenttime, yet fracking will add tons ofpollutants to ouralready polluted air. The Marcellus shale playis perfectly situated to worsen existing ozone and PM nonattainmentin northeastern United States. (Joe Osborne, GASP, Pittsburgh)

The PA DEP annual emissions reportfrom the gas industry found a 7.27% increase from 2011 in carbon monoxide emissions, an 8.51% increase in particulate matter 2.5, and a 3.99% increase in particulate matter 10, a larger type ofparticulate matter. There was also a 42.7% increase in volatile organic compound emissions, an increase due in partto the reportingof 250 additional compressor stations thatwere notrequired to reportin 2011. (Emissions were measured from compressor stations; dehydration units; drill rigs; fugitives, such as connectors. flanges, pump lines, pump seals and valves; heaters; pneumatic controllers and pumps; stationary engines; tanks, pressurized vessels and impoundments; venting and blow down systems; well heads and well completions. htill.JIwww.heraldstandard.comInew today/dep-releases-emissions-data-from -I]atura1-gasj,l[oduction/a_rticle accd6d52-7e28-5572-alde-9d35c999f59d.htmI)

The Post Gazette series dealing with the 14 county Pittsburgh area, presented data on air pollution and risks as they exist now. The standardized mortality ratio comparing disease rates in each county to expected national rates for the same category of disease showed thatall14 counties had heartdisease mortality rates exceeding the national average. 12 of 14counties have respiratory disease mortalityrates exceedingthe national average, 3 of 14have lung cancer mortality rates exceeding the national average, and 13 of 14have a combined mortality rate for all tllree diseases in excess ofcombined national expected rates for tile three. (Post Gazette,12- 2010) The total number ofexcess deaths from those three diseases is a 10% higher mortalityrate overall than should be expected based on nationwide rates.
Mapping revealed an overlap ofdisease rates with the 166 major sources of pollution in the 14county region. "Based on the latestPM [airborne particulate matter]



### 4data it still ranks as one ofthe worst urban areas ofthe countryaccording to john Graham, senior scientist with the Clean Air Task Force. "The air is notclean, and it's killing people." The rate ofasthma is far higher than average. Many school districts have 13- 17% ofstudents afflicted with asthma and in onearea district, 37% ofstudentsare asthmatic. Pittsburgh has some ofthe worst levels ofparticle pollution and ozone in the country according to a recentnews report (Jim Parsons, 7-20-11,WTAEJ Myron Arnowitt, Pennsylvania state director ofClean Water Action, said ofthe asthma statistics, "This is a public health emergency. I've studied this issue. I've read the scientific literature on asthma. Numbers over 30% are offthe charts high."

Children who Jive in highly polluted communities arefive times more likely to have clinicallytow lung function-less than 80% ofthe lung function normal for their age. I have two daughters affected by asthma, therefore Iknow how severe asthma changes

a child's life, resulting in their missing importantchildhood events and interfering with their education, social life, and emotional development

Allegheny and Westmoreland counties (and the rest ofsouthwestern Pa) show higher mortalityrates for multiple sclerosis. Westmoreland County experienced a 41 %increase in MS deaths overa nine- year period. Studies (including a 2003 Finnish study) conclude that poor air quality may make people with MS more susceptible to relapse and infection. Allegheny County residents have increased risks for several cancers including stomach, thyroid, liver, bronchus and lung, kidney, non-hodgkins lymphoma and breast. I

see those statistics personified, having had many friends and family members with cancer and immune diseases. My children have several friends who have had cancer. They are in their thirties. Air pollution causes and accelerates cardiopulmonary disease, lung cancer, and allcause mortality. APenn StateCollege ofMedicine studyfound disturbances in cardiac electrical activities within six hoursafteran episode ofelevated particulatelevels, raising the risk ofcardiac events and chronic heart disease. Ateam at Long Island jewish Medical Center and the Feinstein Institute for Medical Research found thateven modest increases in fine particulate pollution levels in NewYorkCity -even ones under federal pollution standards-cause4 to 10 percent more out- of- hospital cardiac arrest.

The Lancet, Volume 379, Issue 9817, ofFebruary 2012, published a studylinking pollution to stroke, cognitive decline, and heart attacks. Arise in solid orliquid pollutants suspended in the air, including nitrates and sulphates, was found to adversely affect health in both the short and long-term. 19,409 women were studied for a decade and their cognition was checked aboutevery 2 years. Women with higher levels of long- term exposure to air pollution had significantlyfaster declines in cognition.

Upon studying the medical records of 1705 patients admitted with ischemic stroke to Beth Israel Deaconess Medical Center in Boson, between 1999 and 2008, researchers found that increased risk ofstroke peaked between 12 and 14 hoursafter levels ofair particles went up, a shortertime period than previously found. "Even on days when air pollution was moderate, according to the EPA, and Boston is always in compliance with federal levels and is a relatively dean city, the risk ofstroke was 35% higher."



### 5Athird study, cited in The Lancet, found thata rise in concentrated pollutants of 10ugfm3 ofair was linked toa 1-3% increase in the riskofhavinga heartattack. Such

an increase could accountfor up to 4-5% ofall heartattacks in an exposed population. Harvard University's Six Cities Study conductedfrom 1974-1988 revealed that mortalityrates decline when pollution declined; air pollution contributes to excess mortality.

Carbon dioxide (C02) also has a negative effect on plants and the quality ofwheat crops. Large amounts ofC02 collect in the atmosphere, thus affecting plants and crops. Anew study, the first ofits kind, performed by researchers at the University of California, Davis, demonstrated the inhibition ofwheatcrops to convert nitrate into a protein, due to increased C02 levels, which affects its nutritional value. In the past, studies have exhibited this reaction in plants, but this is the first time it is shown in field grown crops. Lead authorand plantscientistProfessorArnold Bloom said, "Food quality is declining underthe rising levels ofatmospheric carbon dioxide thatwe are experiencing." Plant protein is vital to the entire food chain because humans assimilate it from the plants,

or from animals thateat the plants, into energy.

The results showed that not onlyare amino acids like protein affected, buttrace elements as well. There was a 14 percentincrease in lead and an eightpercent drop in the iron contentofthe crop. These are both negative for the health ofpeople around the world, many ofwhich, are already iron deficient Too much lead in the body is a health risk. It is not clearto researchers exactly why higher amounts ofcarbon dioxide has negative effects on plants and crops, http://guarrJianlv.com/20 14/04Icarbon-diuxide -has-ncgat!Ve-etfects-on- plants-and-cropsI

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There is only one solution to our energy problems and that is renewables. I want my tax dollars to go towards a healthy future for my family and thatcan only happen with rigorous regulation offossil fuels, and generous tax credits and other government facilitation ofthe developmentofrenewables. Industry has always complained ofthe inability to meetenvironmental standards. Improvementwill only happen with governmentregulation. Itwill nothappen voluntarily. Meanwhile, residents ofPennsylvania pay for this industry with their health and their health care dollars.



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