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 of the League of Women Voters of Pennsylvania 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 of an 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 L WVPA 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%) 

of our bituminous coal generates over half of the electricity in our country. We produce 56% of 

Pennsylvania's energy from coal while we export 30% of it to other states. 1 At the same time we 

understand that coal-powered generating plants are responsible for approximately 30% of carbon 

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 of asthma 

attacks, respiratory disease, and hundreds of thousands of missed work and low activity days. 

The costs of these 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 of our residents while meeting the challenges of climate change. The L WVP A urges the 

EPA to continue to take action in regulation of methane emissions as prescribed in the Climate 

Action Plan, March 2014 Strategy to Reduce Methane Emission? as a reflection of the rapidly 

growing natural gas operations in Pennsylvania. Natural gas is primarily methane. 

1 !_l_l!i) _ \\ \\ \\_.jY!U -,~JI,Ji! ]_jl~l::_L~-~J_l_ln _ _i_l_rdll'-tl'_\ -pr\j_l\k _:-·- :>_Ul<_t )_L H()p J l_d\t_~_,_!.)j_}__l_l_f 2 ll tl p: \\ \\ \\ '\\ ll ill' i IU ~~-"-~· .g'. •\ "i [(:<., de !iJ u_l_t __ lj 1_~;:- _ _,..; lr:llt:g;- tl_l ,r_..:_<ju~~t'_l!_lt..:l hdnl'_ ~ L'lll..l':-:j_~_)_ ___ ~Q_!_-l-1) 3_.<~H __ r!_l)~_!l ,pJ r 
*Please note the link we have provided for the July 10, 2014 Compendium of Scientific, 

Medical and Media Findings Demonstrating Risks and Harms of Fracking. * 

hl!p:. conccT!Kd hc'a1Jbm·. ort1 '\\n-con_ts:!lt'_Llfll oads.no 14/07-t·H P'\ Y -1: rae king-Com pcndi um. pd r 

*Also a link to a Colorado investigation into a spike in fetal abnormalities near natural gas 

drilling sites* hUp_;!.\v '' \\ .alkrnct.oJ:g!g1 vimnmcnticQigrado-in vcstigatcs-spikc-fcta1-ahnorma1iticsn ''"r' 11:1 lLlral-g_cl'cdriijin_g: ~i lc) C!k.LJ- LJilf)_~Lii,'ll'i(J. \ \_ m:_<_l& _r_d: I_~ S[<;:_c 11 c ''-S.ic:tJ.er_2l16 ~ S& (• 2 7 

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 of methane into 

our atmosphere. About 30% of all 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 of CH4 on climate change is more than 20 times greater 

than C02 over a I 00-year period." 5 

In 2012 when EPA proposed the first-ever standards to control industrial carbon pollution from 

power plants, the League joined with its environmental and social justice allies in collecting the 

largest number of comments ever submitted in review of an EPA regulation. More than three million 

comments were presented in support of the 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 of the 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 of Women Voters of Pennsylvania 

717-234-1576 

226 Forster Street, Harrisburg, PA 17102-3220 

3 IJllf:_ thittf--P!\~gt·l.'>'>.drs_~ l·litnall'_ =t)_j_~ __ ]_0_ ,L~--~7_1l_RlJ I] t'r:Kkirt.;._~_i_[l_~• .. _.:_ll1 __ , .. th_:l_lll' 

4 I:ItJ! l l_1_i n!-..pt\ 1_~.:r ~,,.._ .llrg__ c ltlli<!l~-~tli_+_W) _ _;_u __ }-+"' I _l RO t~b<_t_ndtl_l.l_l'_d_-Jl_t:Jl !]_~_l_\ ~l!l i_;t~\\ c I b-··:>Jl __ t;_\_~_- !_l\~_LI};_lJl~~· 5 ilttp: o.._'p,Lg_(l\ c[;_1~1~t_]_~'\~_b,l!_lg_..._: ~hgcmi'>c-ion.., _ _g'cl)_t.;_~-~~h:LbJUl_l_ 6 h! tp. \\ ''· \\ J \\ __ ~ =' l'·_g_ ~~~_l!ltl"!ll cr~ \ in 1 tHltl' !llitlj1!_-_,!_l~SJ~:P:-_<_!nJ_ .. j1(l) I tll i(;n -con}t:_~~l