:~~': AMERICAN LUNG ASSOCIATION® ~ Fighting for Air 

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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www.lung.org 

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 Utility Generating Units 

Docket ID No. EPA-HQ-OAR-2013-0602 

July 29, 2014 

Atlanta, Georgia 
Good morning. I am Janice Nolen, Assistant Vice President, National Policy, for the American 

Lung Association. I appreciate the opportunity to provide comments today that are a brief 

summary on a few topics. We will submit more detailed comments in writing. 

The American Lung Association strongly supports EPA's commitment to reducing carbon 

pollution from existing electricity generation to protect human health. The Clean Power Plan 

provides a flexible partnership that enables 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 report the 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 distant future. The National Climate Assessment ripped up 

that rationalization, spelling out clear evidence that the U.S. has suffered the damage from the 

changing climate for some time. 

Cleaning up carbon pollution is essential to fighting those damages and will help public health 

immediately. Steps to reduce carbon pollution will cut emissions of other toxic air pollutants, 

including nitrogen oxides, sulfur dioxide, and mercury. 

These pollutants are harmful in and of themselves. Nitrogen oxides irritates the lungs, triggers 

asthma and increases the risk of infections.1 Sulfur dioxide triggers asthma attacks and 

increases the risk of hospitalizations and emergency room visits.2 

Not only do these pollutants harm health directly, but they are the precursors to ozone and 

particulate matter, the most widespread and among the most dangerous pollutants. Cutting 

carbon pollution will cut these two. For millions of people, the immediate impact of the Clean 

Power Plan will come from the reduction of ozone 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 know that 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 Assessment for Sulfur Dioxide, 2008. 3 U.S. EPA. Integrated Science Assessment for Particulate Matter, 2009. 

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To 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 for the states. Stronger targets will provide greater 

immediate and long-term public health benefits. 

EPA needs to ensure that the final guidelines will provide critical relief for people who live near 

the power plants and who have suffered from these pollutants for 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 from the smokestacks nearby. 

The Lung Association urges EPA to shorten the time for putting these measures in place, but 

does not support setting weaker standards to accommodate that shorter timeframe. Five years 

would be reasonable and provide more time to implement than other large measures adopted 

by EPA in the past, including the NOx SIP call. 

The Lung Association is concerned about the inclusion of biomass as an acceptable alternative 

energy source. The American Lung Association does not support biomass combustion for 

electricity production, a category that includes wood, wood products, agricultural residues or 

forest wastes, and potentially highly toxic feed stocks, such as construction and demolition 

waste. If biomass is combusted, state-of-the-art pollution controls must be required. 

We appreciate EPA's commitment to "quantifiable, non-duplicative, permanent, verifiable, and 

enforceable" state plans.4• Those tests are not easy for the states to meet nor for EPA to 

enforce. EPA must be clear that the final standards must be enforceable not just by EPA, but by 

citizens, including groups like the American Lung Association. State plans should also include 

enforceable provisions for those whom the states have determined will implement these 

commitments. States must demonstrate their commitment to adequate resources and 

authority to meet these goals. EPA must clearly spell out the timing and process to enforce a 

federal plan for states that fail to meet the requirements. 

Thank you. 

4 79 FR 34838 

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