LEAGUE OF WOMEN

**VOTERS~** OF 

### PENNSYLVANIA 226 Forster Street, Harrisburg, PA 17102-3220 717.234.1576 Making Democracy Work" Grassroots leadership since 1920 

### League of Women Voters of Pennsylvania Comments to the United States Environmental Protection Agency Regarding Rule III (d) Rule for Existing Power Plants July 31, 2014 Good Morning. I am Susan Carty, President ofthe League ofWomen Voters ofPennsylvania for whom I am speaking. We sincerely thank you for the opportunity to speak with you today. I would like to suggest that we take a few seconds to consider a different world. Imagine a world where all invisible gases are infused with color and odor. Imagine the impact of such a world. Consider the visual ofan interstate highway snaking across the state as a massive, thickly-fogged purple corridor. Who will breathe deeply-{)ur children, grandchildren, elderly, and the infirm? Who will act? Who will block an action? What if? The LWVPA is sensitive to the role that Pennsylvania plays in carbon dioxide emissions and the costs it may incur. We are the fourth largest coal producer in the nation. Seventy-five percent (75%) ofour bituminous coal generates over half ofthe electricity in our country. We produce 56% of Pennsylvania's energy from coal while we export 30% ofit to other states. 1 At the same time we understand that coal-powered generating plants are responsible for approximately 30% ofcarbon emissions. Carbon pollution has been identified as the greenhouse gas that significantly contributes to climate change. That same carbon pollution is responsible for premature deaths, higher risks ofasthma attacks, respiratory disease, and hundreds ofthousands ofmissed work and low activity days. The costs ofthese emissions, relative to climate impact, are increasingly daunting for states and the taxpayers. According to the American Lung Association, dirty air intensified by climate change, disproportionately affects low income communities, as well as children, seniors and those who work or play outdoors. The proposed rule for existing power plants is only a first step in fulfilling our obligation to protect the health ofour residents while meeting the challenges ofclimate change. The LWVPA urges the EPA to continue to take action in regulation ofmethane emissions as prescribed in the 

### Climate Action Plan, March 2014 Strategy to Reduce Methane Emission? as a reflection ofthe rapidly growing natural gas operations in Pennsylvania. Natural gas is primarily methane.

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### 27 According to the Intergovernmental Panel on Climate Change, methane as a greenhouse gas is more than eighty (80) times as potent as carbon dioxide over a twenty-year timeframe. 3 Well heads, pipes, valves, compressors and even abandoned wells4 are releasing increasing volumes ofmethane into our atmosphere. About 30% ofall methane emissions are derived from natural gas and petroleum systems. Best practices and appropriate regulation must be enacted and enforced to reduce all greenhouse gases. EPA must assume responsibility for setting standards to minimize risk. "Pound for pound, the comparative impact ofCH4 on climate change is more than 20 times greater than C02 over a I00-year period." 5 In 2012 when EPA proposed the first-ever standards to control industrial carbon pollution from power plants, the Leaguejoined with its environmental and socialjustice allies in collecting the largest number ofcomments ever submitted in review ofan EPA regulation. More than three million comments were presented in support ofthe proposed rules for new power plants and urging EPA to take the next step and set the carbon standards for existing plants. We are again here to add our voice in defense ofthe Proposed Rule Change. This proposal is reasonable. It is an essential step in addressing climate change. We have a moral obligation to do this, to protect our children and to provide future generations with a cleaner, safer, and more stable environment. We trust you will refer to our national air quality position6 based on study and consensus by local Leagues across the nation. It is from this foundation that our comments have been constructed for your listening today and hopefully your action in the very near future. Susan Carty President League ofWomen Voters ofPennsylvania 717-234-1576 226 Forster Street, Harrisburg, PA 17102-3220

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