Thank you for letting me speak today. My name is Katherine Toan, I am an

environmental and natural resources attorney here in Colorado, practicing largely in oil and gas. I am here today to discuss the immediate and long term consequences of the EPA's proposed rule. I am here to support the proposed rule, and to additionally urge the federal government to end its policy of "temporal discounting" when considering future human lives in the context of climate policy more generally. Climate change is rapidly escalating towards an existential crisis for humanity, one that scientists have predicted will cause long-term agricultural instability, water shortages, disease, population shifts and coastal abandonment, storms, fires, global scale species loss, and of course all of this leads to massive political disruption, conflict, and war. We are already seeing the early signs of some of these, and they will be layered onto our already daunting geopolitical challenges such as overpopulation, natural resources scarcity, economic inequality, and weapons proliferation. The threat or magnitude of human suffering can hardly be exaggerated, and is all the more grotesque and unimaginable from where we sit: the most privileged and wealthy generation in history, condemning our children so we can set our air conditioners at 68 without having to pay Y2 penny more per kilowatt

hour.

Climate change is, I believe, not only the most serious problem facing humanity today, but also one of the most intractable and complex. Like cigarettes, the thing that brings pleasures today - and that seems completely impossible to give up - is building to catastrophic effect in the future, and like smokers, we are inclined to enjoy the moment at the expense of our very likely future. Our future, probably. Our children's future, definitely.

Our increases in energy consumption over the last 100 years or so have been without parallel in human history, and has allowed us to achieve a level of human dignity and achievement similarly unparalleled. We put a man on the moon, sent Voyager beyond the influence of our star, and connected the world into one instantly available at our fingertips. I could be in China tomorrow, just because. Maybe some of the fossil fuels industry here wish I would go.

Cheap fossil fuels have allowed us to do many foolish things as well. We push motorized vehicles across desert soils and tundras that take hundreds of years to heal. We spread our houses across the landscape, eating farmland and requiring

even more from our vehicles. We built cities in deserts and flooded them with millions of people demanding water to be pumped from rivers a hundred miles away, and then we built golf-courses and artificial lakes to entertain them. While our highest achievements will always be possible, this careless and wanton devastation would not be possible if the cost of climate change were factored into the price of fossil fuels. In 1970, if when we enacted the Clean Air Act, we had had the strength of character to require the old plants to keep up with new technology in a timely manner, our problems today would be smaller. Coal would have been more expensive, yes, but that expense is what incentivizes the investments in renewable energy research, development, and infrastructure.The problem we are discussing today is new technology vs. old technology; the

problem is not "coal" versus "natural gas." Technology exists for new coal plants with emissions reductions of 40% over the average currently existing plant. Natural gas burns cleanly at the plant, but that does not account for upstream fugitive emissions, emissions which are often not detected but flow invisibly into the air, and include co-pollutants with direct human toxicity such as benzene and other VOCs. Furthermore, unlike coalmines, natural gas well pads spread out over our landscape in a patchwork of development in and around population centers, disrupting humans and ecosystems alike over hundreds of thousands of acres. Modern fracking is only a decade old, and we know far too little about the costs to be making so many long-term infrastructure investments in it. For just one example, despite industry denials (and the EPA leaving its investigation in Pavillion, Wyoming), we have evidence of groundwater contamination, groundwater that Colorado will need desperately as our climate becomes drier and less predictable.

It is our existing infrastructure, including our legal and economic subsidies for these lethal, addictive fuels, that prevents us from making larger, currently achievable advances in renewable energy technology. These rules are simply an important stepforward towards a future where energy security and environmental security coexist. Please stop discounting the future. The economics of today allow this rule, but

the economics of tomorrow demand it.