Physicians for Social Responsibillt\-· 

### On theproposed "StandardsofPerformancefor Greenhouse Gas Emissions for New StationarySources: ElectricUtility GeneratingUnits" DocketID No. EPAHQ-OAR-2011-0660

Physicians for Social Responsibility CatherineThomasson, 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 submittingthis testimony onbehalfofthe40,000 members and e-activists ofPhysicians for Social Responsibility as the Executive Director. I would like first to applaud the Environmental ProtectionAgency and the Administration for proposing the first federal rule to address the largestpublichealth threat ofthis century, global warming. PSR is also supportive ofthis action in response to the U.S Supreme Court's decision identifying greenhouse gas pollution as a threat to ourhealth and welfare. Mycomments outline the severe public health threats from global warming, some ofwhich we are already seeing. Global warming will continueto speed up without regulations to control greenhouse gas emissions. As electricityproduction via burning offossil fuels is the leading source ofgreenhouse 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 magnitudeimpacting most those incapable ofcooling, the poor, the elderly, children and those with chronic diseases. 1 Humidityrises too with increase in temperature makingit hard to compensate for the heat and its health impact greater. Air-gualitv
Ozone-- Nitrous oxides react with volatile organic compounds in the presence ofsunlight and heat to produces ground-level ozone (smog), which cause various respiratoryproblems. The more heai the more ozone. Ozone can cause asthma attacks, coughing, and wheezing and shortness ofbreath. Some sayit is like getting sunburn in the lungs. Children, senior citizens, and people with lung diseases areparticularlyvnlnerable to the health effects ofozone. Breathing unhealthy levels ofsmog can even send healthypeopleto the hospital. In addition, studies in Los Angeles shows that exposures to ambient ozoneresulted in adverse birth outcomes based on the

1 Belmin J, AuffrayJC, 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(31:298-303.findings oflowerbirth weight and intrauterine growthretardation inregions with high ozone. These effects were worse when pregnant women were exposed more duringthe 2"ct and 3'ct trimester and correlate withhigher ozone and carbon monoxide levels2
To bringthis close to home, 10 counties in Maryland already have highozone days. In 2006, the worst county, Prince Georges, had nearly 1month (29 days) ofhigh ozone levels followed by Harford (23 days) and Baltimore County (22 days). On these days we shouldberecommending that our children not playoutdoors for long periods oftime and children with asthmamayhave recommendations to stayhome! 3
Pollen counts are on therise as increasing carbon dioxide levels increases ragweed pollen production significantly and out ofproportionto plant sizeproviding yet another trigger for asthma attacks.4 One out ofnine children in Americahas 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 thebeetle infested forests are dying. This markedly increases particulates which has a major impact onrates ofmyocardial infarction, asthma and chronic lung disease.
Extreme Weather Events- James Hansenhas statistically analyzed frequency ofextreme weather events and has concluded that current weather outliers events are human induced.6 4 out of5 Americans have beenimpacted in the last I0 years by an extreme weather event. More severe and prolonged hurricanes, more frequent tornadoes and heavyprecipitation events are already occurring and will increase7 Flooding, loss ofhousing, economic andjob loss with resultant loss in health insurance markedly affects health. Flooding causes risk ofdrowning, blunttrauma and infectious disease. It also increases mold another significant source of allergens and thus asthma.
Food insecurity and extreme weather- More frequent droughts alongwith increased evaporation ofmoisture from the ground requiring additional irrigation for crops orcrop failure is strongly predicted. In addition, increase in heavyrainfall and flooding will impact local food production will suffer. Worldwide this will betrue henceprices 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 ofclimate change: common ragweed, urbanization, and public health. JAllergy 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 PhysicalScience Basis: Contribution afWorking Group I to the Fourth Assessment Report ofthe 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 ofdrinking water near coastal areas will become contaminated with saltwater with increasing storm surges and sea level rise. Not only is there increase in salinitybut also reduction in flushing ofwater as there is back up from the ocean. This can increase concentrations ofnitrates and otherpollutants 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 increasingthe concentration ofcontaminants in well water. Snowmelt-Reduction in snowpack in the western United States and in many other regions ofthe world will markedlyreduce the summer source ofdrinking water, river flows for in stream fish as well as water for irrigation and food crops. SeaLevel Rise-This is already impacting coastal communities where 16 ofthe 23 largest cities in the world are located. Storm surge increases effect ofsea level rise exponentially, increasing land erosion and threatening public health and civic infrastructure. Wave force and height are now documented to be increasingon the Pacific Coastincreasing rates ofinjuryand infrastructure damage.
Infectious Diseases Vector-borne disease-Spread ofarbovirus infections such as West Nile virus have increased with rising temperature especially warmer winters9 There is already increase in global incidence ofdengue 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, Lymeborreliosis, tick-borne encephalitis, and hantavirus infections are all projected to increase as a result ofglobal climate change. 11

, 12 Increasing rates ofmalaria in higher latitudes and elevations due to wannertemperatures which increase the range are documented. In addition. the mosquito vector hatches earlier. smaller and lives longer with warmer temperatures. Water-bome disease--With rising ocean temperatures toxic algae blooms are increasing as well as increased risk ofcholera, carried on temperature-sensitive marine copepods.
Conclusion: Physicians for Social Responsibility strongly endorses this rule to reduce the serious public health threat ofglobal 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, MaindonaldJ, 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.