Statement of Me leah 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, May 24, 2012 

Good morning and thank you for the opportunity to comment today on behalf of the 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 dioxide from 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 summer saw brutally hot temperatures throughout the nation, with Chicago and many other cities 

at or exceeding record temperatures on multiple days. This year is off to a record-smashing start as 

well, with March logging in as the hottest March since record-keeping began back in 1885. As 

Chicagoans know all too well, these extreme heat days don't just 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 that the Midwest in particular is vulnerable to increases 

in heat. By the end of this century, numerous cities throughout the Midwest and in neighboring states 

will see thousands and thousands of additional heat-related deaths due to climate change. Indeed, 

Louisville, Detroit and Cleveland top the list at approximately 19,000, 18,000 and 17,000 additional 

deaths, respectively. Chicago comes in at about 6,400 additional 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 half of the nationwide total, and it will get 

worse if we don't take action now to set limits on carbon pollution. 

In addition, as my colleague Thorn Cmar will discuss, extreme storms and other weather events will 

pummel the Midwest as a result of climate change, resulting in billions of dollars in damage to 

infrastructure and homes, as well as public health costs. 

For these reasons, it is imperative that EPA move swiftly to finalize its standards for C02 from power 

plants. 

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

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The Power Plant C02 NSPS 

Power plants together produce more than 2.3 billion tons of carbon dioxide each year. This is about 40 

percent of the country's total C02 emissions, and more than a third of all U.S. greenhouse gas 

emissions. As EPA determined after reviewing mountains of scientific data and analysis, greenhouse 

gases endanger the public health and welfare. EPA therefore has a duty to control greenhouse gases 

from power plants under Section 111 of the Clean Air Act, and NRDC supports the agency's efforts to 

date. 

In particular, we support the following aspects of EPA's proposed standard: 

Establishing a single category consisting of both natural gas-fired combined cycle generating 

units and coal-fired steam generating units. These units perform the same function of base-load 

and intermediate-load power generation, and so are properly considered together. EPA has 

asked for comment on the treatment of simple cycle gas turbines. We will address this further 

in written comments. 

Setting the new source standard no higher than 1000 lbs/MWh. Indeed, we believe the standard 

should be set below 1000 lbs/MWh for several reasons. First, modern new NGCC plants can 

meet a tighter level at no additional cost. Second, new coal-fired EGUs employing carbon 

capture and storage technology (CCS) can also meet a tighter level, especially in light of the 3Dyear averaging provisions that EPA has proposed. We note that several plants recently proposed 

in Illinois and Indiana as CCS projects show that this control option is feasible now, and will only 

become more so in the upcoming years. 

Impacts of the NSPS on Electricity Production and Prices 

It is also important to note that, 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 or on electric rate-payers, and will have no 

adverse impacts on jobs. 

This is because, as numerous power sector experts 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 of a conventional 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 new wind farms to help serve future demand. American Municipal Power similarly 

cancelled a plan to build a conventional coal plant in Ohio in November 2009, citing primarily the 

skyrocketing costs of construction that made the plant uneconomical in light of less expensive 

alternatives such as natural gas and wind power. 

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