EPA CO2 Coal Plant Reduction Hearing Comments 

30 July 2014 

Good morning and thank you for this opportunity. I'm Dr. Crispin Pierce, toxicologist, Associate Professor and 

Program Director of the Environmental Public Health Program at the University of Wisconsin-Eau Claire. My credentials 

include 15 peer-reviewed publications, 44 scientific presentations and the Fulbright Scholar Award. 

I've traveled 1,000 miles from Wisconsin to make two points: 

1. All fossil fuel use causes risks to human health, from carbon pollution to frac sand mining; and 

2. I support the proposed CO2 reductions, as the first step in a strategy that should include carbon fees and 

dividends and a shift to renewable energy, in order to protect public health and private property. 

Greenhouse gas emissions are warming the planet, providing longer seasons for Lyme Disease and more breeding 

habitat for mosquitoes carrying West Nile Virus in Wisconsin. We've seen the costly breach of Lake Delton due to heavy 

rains and flooding, and we're worried about the Emerald Ash Borer and warming trout streams. All of these are 

associated with burning coal, which accounts for 70% of electricity in Wisconsin. Mercury from this coal has now led to 

fish advisories to limit consumption for pregnant women for every lake in the state. 

A more recent energy source has been oil and gas extraction from hydraulic fracturing. Frac sand mining will 

remove 26 million tons of sand from Wisconsin this year, and with mining fine particulates including'silica are released 

into the air. Our state regulator, the Wisconsin Department of Natural Resources, is requiring less than ten percent of the 

135 active frac sand operations to monitor their emissions, and they are not measuring the most dangerous fine 

particulates, PM2.5, which can cause cardiovascular disease, lung cancer, and premature death. 

To address this important concern, our research group has done independent testing of the air around frac sand 

plants over the last five years. We've found elevated levels of PM2.5 including silica in neighboring communities. 

In order to buy EPA-certified instruments to confirm our findings and provide needed comparison with the EPA 

PM2.5 standards, we have now turned to public crowd-sourced funding. 

I've brought with me today one of our instruments, to emphasize the need for air monitoring. This is the DustTrak 

II which will now measure the PM2.5 fine particulates associated with frac sand mining. These two tubes contain the 

natural sandstone that contains all size particles, and the final frac sand containing just the large particles used in 

hydraulic fracturing. 

Starting the instrument, we see that the PM2.5 level in the room is below the 12 micrograms per cubic meter EPA 

average standard. When I invert the tube with the frac sand and measure emissions, we see no or a slight elevation in the 

PM2.5 level. In contrast, when I invert and measure the sandstone, the PM2.5 level increases hundreds of times above 

the EPA standard. These are the dangerous fine particles emitted or left behind after mining. And this is why air 

monitoring must be required during frac sand mining and hydraulic fracturing operations. 

Even knowing that less reliance on coal will lead to more frac sand mining in Wisconsin, I want to express my 

support for the EPA initiative because of the important health, cost and property benefits this regulation will provide for 

our country. 

All uses of fossil fuels for energy — coal, oil, tar sands, methane — carry health risks. The proposed CO2 reductions 

are an important first step to protect public health, control costs, and protect private property. 

Crispin Pierce, PhD 

Associate Professor and Program Director 

Environmental Public Health Program 

University of Wisconsin-Eau Claire 

105 Garfield Ave. 

kA/I A-7111