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 that we endure and the illnesses it causes 

and exacerbates. I strongly urge EPA to take action to protect our air and consequently our 

health. 

According to a recent Harstad Strategic Research Poll more than two- thirds of 

Americans agree that the EPA should limit carbon pollution. Power plants, which spew out 

40% of carbon emissions in our country, should not be free to dump unlimited carbon into 

the atmosphere, intensifying climate change and endangering our health. 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 of greenhouse gases in the United States, (Environmental 

Protection Agency, 2012). The EPA must do 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 150,000 asthma 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% of the power sector's 

COz, and for the vast majority of the power industry's sulfur dioxide, nitrogen oxides, 

hydrochloric acid, mercury, arsenic and particulate matter. According to the American 

Lung Association, these chemicals combine to create a stew of some 386,000 tons of 

hazardous air pollutants per year. A 2009 report from the National Research Council found 

that sulfur dioxide and nitrogen oxides alone impose $62 billion a year in public health cost. 

A 2010 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. [Post Gazette, 11-2012) 

Pittsburgh ranks among the top ten cities where the highest number of 

cardiopulmonary deaths occur that are attributable to particulates. A study found 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 of Post Neonatal Infant Morality 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. 

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In a study commissioned by the Clean Air Task Force, it was found that Greene and 

Washington Counties spend over $300,000 on health effects from dirty power plants. Those 

effects include heart attack, asthma attack, chronic bronchitis and even death. And air 

pollution is linked to a range of ailments never before thought of as environmentally 

related-diabetes, attention deficit disorder, autoimmune diseases, Parkinson's and heart 

disease. The use of coal has only been affordable over the decades because we have been 

footing the brunt of the bill in health costs. (Clean Air Council) 

Doctors note that carbon pollution cycle is dangerous for children in general. 

It raises air temperatures, which worsens smog pollution, which triggers asthma 

attacks and can permanently reduce 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 half the current legal 

level. (National Voter, 99) 

judy Focarets, a maternal-child nurse in Pittsburgh applauds EPA efforts and notes: 

'While other states 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 Mark jacobson, a professor of civil and environmental 

engineering, spelled out for the first time the direct links between increased levels of carbon 

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 resulting air pollution would lead annually to about a thousand 

additional deaths and many more cases of respiratory illness and asthma in the 

United States. Worldwide, upward of 20,000 air-pollution-related deaths per year per 

degree Celsius may be due to this greenhouse gas. 

"This is a cause and effect relationship, not just a correlation," said jacobson of his 

study. "The study is the first specifically to isolate carbon dioxide's effect from that of other 

global-warming agents and to find quantitatively that chemical and meteorological changes 

due to carbon dioxide itself increase mortality due to increased ozone, particles and 

carcinogens in the air." 

The effects of carbon dioxide's warming are most significant where the pollution is 

already severe, worsening people's health in cities already experiencing pollution at a much 

faster rate than elsewhere in the nation. 

Much of the population of the 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 if temperatures continue to rise. 

Jacobson calculated the amount of ozone 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 of increasing temperatures on pollution. He observed 

two important effects: 

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Higher temperatures due to carbon dioxide increased the chemical rate of ozone 

production in urban areas. 

Increased water vapor 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 water vapor, particles that 

were present became more deadly, as they swelled from absorption of water. "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 of the 

particles, which are already a harmful component of air pollution. 

jacobson also found that air 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 of deleterious 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: That would reduce its warming 

effect and improve the health of people in the U.S. and around the world who are currently 

suffering from air pollution health problems associated with it." 

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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 or reduction of carbon pollution. 

In Westmoreland County where I reside, and in much of western PA, we are 

already in a state of non-attainment for ozone. We have a high incidence of asthmatic 

children and high rates of certain 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 Nil tiona! 

ErnissionsTre.ru! database), Westmoreland County ranks in the worst 90% of counties 

nationwide for VOCs, nitrogen oxide, and carbon monoxide. It also ranks in the dirtiest 80% 

of counties nationwide for PM 2.5 emissions and sulfur dioxide. 

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The county ranked in the 80 to 90% of worst counties for cancer risk and developmental 

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Westmoreland County is not in compliance for ozone standards, and was 

awarded a grade of D by the American Lung Association based on ozone pollution. 

Dr. Levy, joel Schwartz, and LisaK. Baxter completed a study in 2009, published in 

Risk Analysis, 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 of health-related damages of $30,000 to $500,000 for every 

ton of fine-particle, or PM 2.5 pollution, with a median rate of $72,000 per ton. For each ton 

of sulfur 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 of health damage, the total annual health 

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damage from the region's major sources of pollution is $9.4 billion. Such costs are 

"external" because they are borne by the public rather than industry. We cannot afford this 

burden physically or financially. 

But do 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 of sulfur 

dioxides, carbon monoxide, VOCs, formaldehyde, and 35.04 tons of NOx per year, more than 

the current emission rate for cars per year. NOx is a precursor to ozone. Westmoreland 

County alone has 26 new compressor stations and processing plants since 2008. 

Methane produced by gas operations also contributes to ozone and it is 

produced at far higher rates than originally thought- during the drilling phase, 

according to Purdue and Cornell researchers, 1000 times more. And methane is a potent 

greenhouse gas, 20 to 30 times more potent than C02• A National Oceanic and Atmospheric 

Administration study found that 9% of gas pumped out of the ground leaks into the 

atmosphere. Malcom Sweney of CIRES 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 

present time, yet fracking will add tons of pollutants to our already polluted air. The 

Marcellus shale play is perfectly situated to worsen existing ozone and PM 

nonattainment in northeastern United States. (Joe Osborne, GASP, Pittsburgh) 

The PA DEP annual emissions report from 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 of particulate matter. 

There was also a 42.7% increase in volatile organic compound emissions, an increase 

due in part to the reporting of 250 additional compressor stations that were not required to 

report in 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. 

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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 heart disease mortality rates exceeding the 

national average. 12 of 14 counties have respiratory disease mortality rates 

exceeding the national average, 3 of 14 have lung cancer mortality rates exceeding 

the national average, and 13 of 14 have a combined mortality rate for all tllree 

diseases in excess of combined national expected rates for tile three. (Post Gazette,12-

2010) The total number of excess deaths from those three diseases is a 10% higher 

mortality rate overall than should be expected based on nationwide rates. 

Mapping revealed an overlap of disease rates with the 166 major sources of 

pollution in the 14 county region. "Based on the latest PM [airborne particulate matter] 

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data it still ranks as one of the worst urban areas of the country according to john 

Graham, senior scientist with the Clean Air Task Force. "The air is not clean, and it's killing 

people." 

The rate of asthma is far higher than average. Many school districts have 13-

17% of students afflicted with asthma and in one area district, 37% of students are 

asthmatic. Pittsburgh has some of the worst levels of particle pollution and ozone in the 

country according to a recent news report (Jim Parsons, 7-20-11, WT AEJ Myron Arnow itt, 

Pennsylvania state director of Clean Water Action, said of the 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 off the charts high." 

Children who Jive in highly polluted communities are five times more likely to 

have clinically tow lung function-less than 80% of the lung function normal for their 

age. I have two daughters affected by asthma, therefore I know how severe asthma changes 

a child's life, resulting in their missing important childhood events and interfering with 

their education, social life, and emotional development 

Allegheny and Westmoreland counties (and the rest of southwestern Pa) show 

higher mortality rates for multiple sclerosis. Westmoreland County experienced a 41 

%increase in MS deaths over a 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. A Penn State College of Medicine study found disturbances in cardiac 

electrical activities within six hours after an episode of elevated particulate levels, 

raising the risk of cardiac events and chronic heart disease. A team at Long Island 

jewish Medical Center and the Feinstein Institute for Medical Research found that even 

modest increases in fine particulate pollution levels in New York City -even ones 

under federal pollution standards-cause 4 to 10 percent more out- of- hospital 

cardiac arrest. 

The Lancet, Volume 379, Issue 9817, of February 2012, published a study linking 

pollution to stroke, cognitive decline, and heart attacks. A rise in solid or liquid 

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 a bout every 2 years. Women with higher levels of 

long- term exposure to air pollution had significantly faster 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 of stroke peaked between 12 and 14 hours after levels of air 

particles went up, a shorter time 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 of stroke was 35% higher." 

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A third study, cited in The Lancet, found that a rise in concentrated pollutants of 

10ugfm3 of air was linked to a 1-3% increase in the risk of having a heart attack. Such 

an increase could account for up to 4-5% of all heart attacks in an exposed population. 

Harvard University's Six Cities Study conducted from 197 4-1988 revealed that 

mortality rates decline when pollution declined; air pollution contributes to excess 

mortality. 

Carbon dioxide (C02) also has a negative effect on plants and the quality of wheat 

crops. Large amounts of C02 collect in the atmosphere, thus affecting plants and crops. 

A new study, the first of its kind, performed by researchers at the University of 

California, Davis, demonstrated the inhibition of wheat crops 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 author and plant scientist Professor Arnold Bloom said, "Food quality is 

declining under the rising levels of atmospheric carbon dioxide that we are experiencing." 

Plant protein is vital to the entire food chain because humans assimilate it from the plants, 

or from animals that eat the plants, into energy. 

The results showed that not only are amino acids like protein affected, but trace 

elements as well. There was a 14 percent increase in lead and an eight percent drop 

in the iron content of the crop. These are both negative for the health of people around 

the world, many of which, are already iron deficient Too much lead in the body is a health 

risk. It is not clear to researchers exactly why higher amounts of carbon dioxide has 

negative effects on plants and crops, 

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I eeGxOsvlbfq4X88. 99 

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 that can only happen with 

rigorous regulation of fossil fuels, and generous tax credits and other government 

facilitation of the development of renewables. 

Industry has always complained of the inability to meet environmental standards. 

Improvement will only happen with government regulation. It will not happen voluntarily. 

Meanwhile, residents of Pennsylvania pay for this industry with their health and their 

health care dollars. 

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