Statementof Meleah Geertsma Attorney, Midwest Program Natural Resources Defense Council
Public Hearing on the Environmental Protection Agency's Proposed Carbon Pollution Standard for New Power Plants Chicago, Illinois, May24, 2012



### Good morning and thankyou forthe opportunityto commenttoday on behalfofthe Natural Resources Defense Council and our 1.3 million members and activists. NRDC supports the EPA's proposed carbon pollution standard for new electric power plants, the first national limits on carbon dioxidefrom this top-emitting sector. Controlling carbon pollution from power plants is critical to addressing climate change and its impacts on health, including here in the Midwest. Climate Change and Heat-Related Death in the Midwest Region 

### Climate change is having and will continue to have serious impacts on the Midwest. At the most basic level, climate change will increase temperatures, particularly in urban areas which act as "heat sinks." Last summersaw brutally hot temperatures throughoutthe nation, with Chicago and many othercities at orexceeding record temperatures on multiple days. This year is 

### offto a record-smashing start as well, with March logging in as the hottest March since record-keeping began back in 

### 1885.As Chicagoans knowall too well, these extreme heat days don'tjust cause temporary discomfort, but can kill people- especially the elderly and young children who are particularly susceptible to heat stress. NRDC this week released "Killer Summer Heat," a report based on peer-reviewed published studies, which estimates the growth in health-related deaths due to excessive heat caused by climate change in the nation's

### 40 largest cities 1 

### The report shows thatthe Midwest in particular is vulnerable to increases in heat. By the end ofthis century, numerous cities throughoutthe Midwest and in neighboring states will see thousands and thousands ofadditional heat-related deaths due toclimate change. Indeed, Louisville, Detroit and Cleveland top the list at approximately 

### 19,000, 18,000and 

### 17,000 additional deaths, respectively. Chicago comes in at about 

### 6,400additional deaths. Other Midwest cities topping the national list are Columbus, Minneapolis, and St. Louis. All told, the region is set to lose approximately

### 75,000 lives from excessive heat alone, about halfofthe nationwide total, and it will get worse ifwe don'ttake action nowto set limitson carbon pollution. In addition, as my colleague Thorn Cmar will discuss, extreme storms and otherweather events will pummel the Midwest as a result ofclimate change, resulting in billions ofdollars in damage to infrastructure and homes, as well as public health costs. For these reasons, it is imperative that EPA move swiftlytofinalize its standards for C02 from power plants.

1The full report details are available online atwww.nrdc.org/globalwarming/killer-heat.



### 1The Power Plant C02 NSPS Power plants together produce more than 2.3 billion tons ofcarbon dioxide each year. This is about40 percent ofthe country's total C02 emissions, and more than athird ofall U.S. greenhouse gas emissions. As EPA determined after reviewing mountains ofscientific data and analysis, greenhouse gases endangerthe public health and welfare. EPAtherefore has adutyto control greenhouse gases from power plants underSection 111 ofthe Clean AirAct, and NRDC supports the agency's effortsto date. In particular, we supportthe following aspects of EPA's proposed standard: Establishing asingle category consisting ofboth natural gas-fired combined cycle generating units and coal-fired steam generating units. These units perform the same function ofbase-load and intermediate-load power generation, and so are properly considered together. EPA has asked for comment on the treatmentofsimple cycle gas turbines. We will address this further in written comments. Setting the newsource standard no higherthan 1000 lbs/MWh. Indeed, we believe the standard should be set below 1000 lbs/MWh forseveral reasons. First, modern new NGCC plants can meet atighter level at no additional cost. Second, new coal-fired EGUs employing carbon capture and storage technology (CCS) can also meet atighter level, especially in light ofthe 3Dyear averaging provisions that EPA has proposed. We notethat several plants recently proposed in Illinois and Indiana as CCS projects show thatthis control option is feasible now, and will only become moreso in the upcomingyears.

Impacts ofthe NSPS on Electricity Production and Prices It is also importantto notethat, contrary to claims by companies and groups opposing EPA's action, the standard will not act as a "de facto ban" on constructing new conventional coal plants or result in job losses and higher utility bills. Rather, as EPA has demonstrated, the proposed new source standard actually will impose no additional costs on the industry oron electric rate-payers, and will have no adverse impacts on jobs. This is because, as numerous powersectorexperts have recognized, market realities have already driven decisions on new power plants away from coal. In the state of Michigan, this shift can be seen in the cancellation in December 2011 ofaconventional coal plant proposal by Consumers Energy. The company has noted in the press that its choice was influenced by low natural gas prices, and it intends to build two newwind farms to help serve future demand. American Municipal Power similarly cancelled a plan to build aconventional coal plant in Ohio in November2009, citing primarilythe skyrocketing costs ofconstruction that made the plant uneconomical in light ofless expensive alternatives such as natural gas and wind power.



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