9■1),VT1 i) 

G1.4, 1/M-eely6 

Public Comment on the US.EPA proposed "Clean. Power Plan" 

in regards to: Power Plant Carbon Emission Regulations 

Three Main Environmental Problems resulting from Clean Power Plan 

-" SZI7=f2:4210.t=tatT.e"-P—r..=..=•,•4•4-0...14072,02-"'''y 

Overall, the "Clean Power Plan" is very good for its limited scope, but 

must go further to achieve long-term benefits. 

Short-term, the Clean Power Plan substantially reduces atmospheric 

carbon GHGases & other criteria air pollutants (particulates, NOx, S0x, HC, 

etc.), by means of replacing coal burning with nat. gas. at power plants. 

PROBLEMS: However, at least 3 long-term problems will be exacerbated 

by the CPP and could potentially override the intended benefits. 

1. GHG emissions could potentially increase from CPP. Fugitive 

methane emissions are not measured accurately enough in 

regards to it whole life-cycle atmospheric emissions, (which are 

from gas/oil extraction, its distribution, its processing and finally its 

3% ,9 7,. ? combustion). 

In addition, surface and underground pollution from oil/gas 

extraction is often found to be excessive, as it becomes further 

researched. 

2 The insufficiently regulated oil/gas industry will expand to 

produce even cheaper nat. gas prices. A major result is 

inevitably to stifle the essential growth in energy efficiency 

(DSM...) and renewable energy implementation. 

3. The expansion of gas/oil extraction will not necessarily lead to a 

reduction in coal extraction, nor in global GHG & other 

pollution. The coal mining (& oil extraction) operations can 

simply export their excess capacity to the world's industrial 

markets, instead of our U.S. power plants. 

from: John C. Bollinger, PE, CEM, GBE, BPI/BAP 143 Salina St., Lafayette, CO 80026 720-937-3176 printed:7,10/14 Pagel of 2 
Public Comment on the US.EPA proposed "Clean Power Plan" 

in regards to: Power Plant Carbon Emission Regulations 

SOLUTIONS: The CPP must enable EPA to plan for developing better 

regulations to remedy the three growing problems, (previously 

mentioned). Solutions should include: 

1. EPA must support research to accurately measure the total 

system's fugitive methane emissions, (being from extraction, 

processing, distribution & utilization). 

Furthermore, EPA must support researching, measuring and 

better estimating the total "external costs" of all pollution from 

the increased nat. gas, & other fossil fuel 

production/consumption. 

2 Then, to compensate for large fugitive methane emissions and 

other resulting pollution costs, there must be a commitment to 

gradually yet substantially increase fossil fuel taxes accordingly. 

Then refund all tax revenue back by supporting more rapid 

expansion of our energy efficiency and renewable energy 

applications. 

3. Limit the total GHG and other pollution resulting from fossil fuel 

production & consumption in U.S. This may require limiting 

the rate of fossil fuel extraction. 

Overall, the CPP does very well to close front door to keep out the threat 

of atmospheric carbon & other pollutant from power plants. 

However, our metaphorical back door is left wide open to allow other 

threats to enter, 

where Fugitive methane emissions grow, 

Oil & other fossil fuel extraction expands uncontrollably, and 

our essential Energy Efficiency/Renewable energy industry is stifled. 

As a contingency to passing the CPPlan, EPA must commit to a broader 

plan to resolve these 3 major problems, which will otherwise result from 

the currently proposed CPP. 

from. John C. Bollinger, PE CEM, OBE FPI BAP 143 Salina St., Lafayette, CO 80026 720-937-3176 printed:7/30/ I 4 Page 2 of 2