# :~~': AMERICAN LUNG ASSOCIATION®

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Kathryn A. Forbes, CPA Chair National Board of Directors Ross P. Lanzafame, Esq. Past Chair John F. Emanuel. Esq. Vice Chair Penny J. Siewert Secretary/Treasurer Harold P. Wimmer National President and CEO

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### Testimony from Janice E. Nolen Assistan , ational Policy 

### American Lung Association To the U.S. Environmental Protection Agency On the 

### Carbon Pollution Emissions Guidelines for Existing Stationary Sources: Electric UtilityGenerating Units Docket ID No. EPA-HQ-OAR-2013-0602

July29, 2014 Atlanta, GeorgiaGood morning. I am Janice Nolen, Assistant Vice President, National Policy, forthe American Lung Association. I appreciate the opportunityto provide comments todaythat are a brief summary on afew topics. We will submit more detailed comments in writing. The American Lung Association strongly supports EPA's commitmentto reducing carbon pollution from existing electricity generation to protect human health. The Clean Power Plan provides aflexible partnershipthatenables states to reduce carbon pollution coming from electricity sources within each state and at the same time reduce other life-threatening pollutants. Climate change threatens human health. In May, the National Climate Assessment provided only the latest analyses to reportthe risks from the rising temperatures, increased air pollution, drought, wildfires, and extreme weather events. But many citizens have assumed that these threats were all sometime in the distantfuture. The National Climate Assessment ripped up that rationalization, spelling out clear evidence thatthe U.S. has suffered the damage from the changing climate for some time. Cleaning up carbon pollution is essential tofighting those damages and will help public health immediately. Steps to reduce carbon pollution will cut emissions ofothertoxic air pollutants, including nitrogen oxides, sulfur dioxide, and mercury. These pollutants are harmful in and ofthemselves. Nitrogen oxides irritates the lungs, triggers asthma and increases the risk ofinfections.1 Sulfur dioxide triggers asthma attacks and increases the risk of hospitalizations and emergency room visits.2 Notonly dothese pollutants harm health directly, butthey are the precursors to ozone and particulate matter, the mostwidespread and among the most dangerous pollutants. Cutting carbon pollution will cutthese two. For millions of people, the immediate impact ofthe Clean Power Plan will come from the reduction ofozone and particulate matter. Ozone and particulate matter pollution cause difficulty breathing, asthma attacks, and premature death, and have been linked to low birth weight in newborns. Particulate matter causes heart attacks and strokes, and we now knowthat particulate matter causes lung cancer. Particulate matter may also increase the risk of infant mortality. 3

1 U.S. EPA. Integrated Science Assessment for Oxides of Nitrogen, 2008. 'U.S. EPA, Integrated Science Assessmentfor Sulfur Dioxide, 2008. 3 U.S. EPA. Integrated Science Assessmentfor Particulate Matter, 2009. 2To adequately protect public health, we need greater reductions in carbon pollution and in the other pollutants than what EPA has outlined in this proposal. We urge EPA to strengthen the plan and, therefore, the proposed targets forthe states. Strongertargets will provide greater immediateand long-term public health benefits. EPA needs to ensure thatthefinal guidelines will provide critical relieffor people who live near the power plants and who have suffered from these pollutantsfor decades. Those communities are often lower in income and higher in populations with existing lung diseases and other chronic diseases. They need these reductions to come fromthe smokestacks nearby. The Lung Association urges EPA to shorten the time for putting these measures in place, but does notsupport setting weaker standards to accommodate that shortertimeframe. Five years would be reasonable and provide more timeto implementthan other large measures adopted by EPA in the past, including the NOx SIP call. The Lung Association is concerned aboutthe inclusion ofbiomass as an acceptable alternative energy source. The American Lung Association does notsupport biomass combustion for electricity production, a categorythat includes wood, wood products, agricultural residues or forest wastes, and potentially highlytoxic feed stocks, such as construction and demolition waste. 

### Ifbiomass is combusted, state-of-the-art pollution controls must be required. We appreciate EPA's commitmentto "quantifiable, non-duplicative, permanent, verifiable, and enforceable" state plans.4•Those tests are noteasy forthe states to meet norfor EPA to enforce. EPA must be clearthatthe final standards must be enforceable notjust by EPA, but by citizens, including groups likethe American Lung Association. State plans should also include enforceable provisions forthose whom the states have determined will implementthese commitments. States must demonstratetheircommitmentto adequate resources and authorityto meetthese goals. EPA must clearly spell outthe timing and process to enforce a federal planforstates thatfail to meetthe requirements. Thank you.

4 79 FR 34838 3