Physicians for 

Social 

Responsibillt\-· 

On the proposed "Standards of Performance for Greenhouse 

Gas Emissions for New Stationary Sources: Electric Utility 

Generating Units" 

Docket ID No. EPAHQ-OAR-2011-0660 

Physicians for Social Responsibility 

Catherine Thomasson, MD 

Executive Director 

!Ill 14'h St, NW, Ste 700 

Washington DC 20005 

202-587-5240; 503-819-1170 cell 

\V\V\v.psr.org 

cthomasson@psr.org 

I am submitting this testimony on behalf of the 40,000 members and e-activists of Physicians for 

Social Responsibility as the Executive Director. I would like first to applaud the Environmental 

Protection Agency and the Administration for proposing the first federal rule to address the 

largest public health threat of this century, global warming. PSR is also supportive of this action 

in response to the U.S Supreme Court's decision identifying greenhouse gas pollution as a threat 

to our health and welfare. 

My comments outline the severe public health threats from global warming, some of which we 

are already seeing. Global warming will continue to speed up without regulations to control 

greenhouse gas emissions. As electricity production via burning of fossil fuels is the leading 

source of greenhouse gas emissions it is appropriate for the EPA to propose this initial rule 

limiting carbon dioxide emissions from plants to be built in the future. 

Temperature-related Heat waves will intensify in both duration and magnitude impacting most 

those incapable of cooling, the poor, the elderly, children and those with chronic diseases. 1 

Humidity rises too with increase in temperature making it hard to compensate for the heat and its 

health impact greater. 

Air-gualitv 

Ozone-- Nitrous oxides react with volatile organic compounds in the presence of sunlight and 

heat to produces ground-level ozone (smog), which cause various respiratory problems. The 

more heai the more ozone. Ozone can cause asthma attacks, coughing, and wheezing and 

shortness of breath. Some say it is like getting sunburn in the lungs. Children, senior citizens, 

and people with lung diseases are particularly vnlnerable to the health effects of ozone. Breathing 

unhealthy levels of smog can even send healthy people to the hospital. In addition, studies in Los 

Angeles shows that exposures to ambient ozone resulted in adverse birth outcomes based on the 

1 Bel min J, Auffray JC, Berbezier C, et al. Level of dependency: a simple marker associated with mortality during the 

2003 heat wave among French dependent elderly people living in the community or in institutions. Age Ageing. 

2007 ;36(3 1:298-303. 
findings of lower birth weight and intrauterine growth retardation in regions with high ozone. 

These effects were worse when pregnant women were exposed more during the 2"ct and 3'ct 

trimester and correlate with higher ozone and carbon monoxide levels2 

To bring this close to home, 10 counties in Maryland already have high ozone days. In 2006, the 

worst county, Prince Georges, had nearly 1 month (29 days) of high ozone levels followed by 

Harford (23 days) and Baltimore County (22 days). On these days we should be recommending 

that our children not play outdoors for long periods of time and children with asthma may have 

recommendations to stay home! 3 

Pollen counts are on the rise as increasing carbon dioxide levels increases ragweed pollen 

production significantly and out of proportion to plant size providing yet another trigger for 

asthma attacks.4 One out of nine children in America has asthma and increasing ozone and pollen 

will drive the number higher5 

Wildfires-Increase in wildfires is occurring in drought impacted locations in the Southwest. 

With further warming this will increase throughout the west as the beetle infested forests are 

dying. This markedly increases particulates which has a major impact on rates of myocardial 

infarction, asthma and chronic lung disease. 

Extreme Weather Events- James Hansen has statistically analyzed frequency of extreme 

weather events and has concluded that current weather outliers events are human induced. 6 4 out 

of 5 Americans have been impacted in the last I 0 years by an extreme weather event. More 

severe and prolonged hurricanes, more frequent tornadoes and heavy precipitation events are 

already occurring and will increase7 Flooding, loss of housing, economic and job loss with 

resultant loss in health insurance markedly affects health. Flooding causes risk of drowning, 

blunt trauma and infectious disease. It also increases mold another significant source of 

allergens and thus asthma. 

Food insecurity and extreme weather- More frequent droughts along with increased evaporation 

of moisture from the ground requiring additional irrigation for crops or crop failure is strongly 

predicted. In addition, increase in heavy rainfall and flooding will impact local food production 

will suffer. Worldwide this will be true hence prices will rise. Impacts on our low income 

2 Salam, M, et al. "Birth Outcomes and Prenatal Exposure to Ozone, Carbon Monoxide and Particulate Matter: 

Results from the Children's Health Study." Environ Health Perspectives. 113, 2005: 1638-44. 

3 www.countvhealthrankings.org/maryland. Robert Wood Johnson Foundation/University of Wisconsin Population 

project. Accessed 2/12/12 

4 Ziska LH, Gebhard DE, Frenz OA, Faulkner S, Singer BD, Straka JG. Cities as harbingers of climate change: common 

ragweed, urbanization, and public health. J Allergy Clin lmmunol. 2003;111(2):290-295. 5 O'Neill MS, Ebi KL. Temperature extremes and health: impacts of climate variability and change in the United 

States. J Occup Environ Med. 009;51(1):13-25. 

6 J. Hansen, M. Sato, R. Ruedy. Climate Variability and Climate Change: the New Climate Dice. 

hnp:/iw\VV/.columbia.edu/-jehl/mailings/2011/20111110 NewClimateDice.pdf. Accessed 5/23/12 7 Solomon S, Qin D, et al. Technical summary. In: Solomon S. Climate Change 2007: The Physical Science Basis: 

Contribution af Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate 

Change. New York, NY: Cambridge University Press; 2007. 
vulnerable populations will occur and with worse nutrition, health especially fetal and child 

growth and development will suffer. 

Groundwater- Groundwater sources of drinking water near coastal areas will become 

contaminated with saltwater with increasing storm surges and sea level rise. Not only is there 

increase in salinity but also reduction in flushing of water as there is back up from the ocean. 

This can increase concentrations of nitrates and other pollutants in groundwater. 8 Miami is 

already having trouble with flooding at high tide during a full moon even without a storm. In 

addition, there is further demand for groundwater for irrigation dropping the water table and 

increasing the concentration of contaminants in well water. 

Snowmelt-Reduction in snowpack in the western United States and in many other regions of the 

world will markedly reduce the summer source of drinking water, river flows for in stream fish 

as well as water for irrigation and food crops. 

Sea Level Rise-This is already impacting coastal communities where 16 of the 23 largest cities 

in the world are located. Storm surge increases effect of sea level rise exponentially, increasing 

land erosion and threatening public health and civic infrastructure. Wave force and height are 

now documented to be increasing on the Pacific Coast increasing rates of injury and 

infrastructure damage. 

Infectious Diseases 

Vector-borne disease-Spread of arbovirus infections such as West Nile virus have increased 

with rising temperature especially warmer winters9 There is already increase in global incidence 

of dengue fever, which is spreading in endemic proportions in Texas and the Florida Keys. 10 

Schistosomiasis the most common parasitic disease worldwide. fascioliasis, alveolar 

echinococcosis, leishmaniasis, Lyme borreliosis, tick-borne encephalitis, and hantavirus 

infections are all projected to increase as a result of global climate change. 11 , 

12 Increasing rates 

of malaria in higher latitudes and elevations due to wanner temperatures which increase the 

range are documented. In addition. the mosquito vector hatches earlier. smaller and lives longer 

with warmer temperatures. 

W ater-bome disease--With rising ocean temperatures toxic algae blooms are increasing as well 

as increased risk of cholera, carried on temperature-sensitive marine copepods. 

Conclusion: 

Physicians for Social Responsibility strongly endorses this rule to reduce the serious public 

health threat of global warming due to greenhouse gas emissions. 

8 Wilson, Alicia, eta!. Storm-driven Groundwater Flow in a Salt Marsh. Water Resources Research. 47, 2011. 

9 Weaver SC, Reisen WK. Present and future arboviral threats. Antiviral Res. 2010;85(2):328-345. 

10 Hales 5, de Wet N, Maindonald J, Woodward A. Potential effect of population and climate changes on global 

distribution of dengue fever: an empirical model. Lancet. 2002;360(9336):830-834. 11 Mas-ComaS, Valero MA, Bargues MD. Effects of climate change on animal and zoonotic helminthiases. Rev Sci 

Tech 2008; 27: 443-57. 12 Gray JS, Dautel H, Estrada-Pef\a A, l<ahl 0, Lindgren E. Effects of climate change on f1cks and t'1ck-borne diseases 

in Europe. lnterdiscip Perspect Infect Dis 2009; 2009: 593232.