Comment made byJohn F. Nagle (nagle(c/!cmu.edu, 412-268-2764) EPA hearing in Pittsburgh 7/31/14. Docket ID No. EPA-HQ-OAR-2013-0602 Ithank the EPA for giving me the opportunity to commenton its proposal for GHG reduction from EGUs and Ithankthis panel for agreeing to listen during this two day marathon. I appreciate the hard work and due diligence that the EPAhas put into producing a well crafted proposal, although it is a bitdaunting. I am an emeritusprofessor at CMU in the fields ofphysics andbiology. Tenyears ago Itaught a course entitled Energy and Environmental Issues. At that time one could still make a case, albeit a weak one, that man-made global warmingmight not be occurring, so my course encouraged debate among students. That was a lopsided debate even then. I'mpleased that EPA'sproposal emphasizes the scientific consensus. Recently, CMU bestowed the prestigious $50K Dicksonprize onJaredDiamond for his book entitled Collapse. That book serves as a warning to us today. Itdescribes several civilizations that collapsed, sometimes by its people not being able to recognize an existential threat. Fortunately, science recognizes the threat ofglobal warming, and I'mpleased that the EPA proposal emphasizes that. However, many ofDiamond's civilizations collapsed because they did not have the will to deal with the threat that was staring them in the face. That is the challenge we have today. Itis importantto recognize that it took hundreds ofyears for those collapses to play out,just like the impending irreversible collapse ofthe West Antarctic ice cap. The EPAdocument well appreciates the long term nature ofthe existential climate threat. Action must be taken to limit GHG before it becomes too late to prevent the consequences ofglobal warming mentioned in the EPA document. Inresponse to the EPA solicitation for specific comments, Ihave a baker's dozen. As there isn'ttime to read all 13, I will place my written comments inthe record. The general thrust ofmy comments is to urge EPA to adopt the strongestpossible regulations that will reduce further increases in GHG the most and the fastest. So, for the BSER, I like Option I for mostreductionand Option 2 for faster reduction. Natural gas is notthe long term solution, even discounting my concern about getting frackcd. so Idefinitely concur with EPA that the BSER should include Building Blocks 3 and 4. Considering that the projected electricity price increase from this plan is less than 7%, Ithink it is quite affordable. Indeed, we should be willing to pay a lot more, especially as EPA's estimate ofhealth co-benefits is even greater than the cost ofGHG reduction. Even though I am concernedthat the proposal does not go far enough, fast enough, it is certainly a step in the right direction that will encourage more rational planning that mighthelp avert collapse ofthe sort described in Diamond'sbook. So, I generally support the EPA proposal and offer my specific comments on it. Specific items: I. p. 34836. I.A.2.a et seq. Ioppose limiting the application to only the first two building blocks. We need RE instead offossil fueled EGU and we need to promote energy reduction. (I'mconstantly turning oJTthe lights all:er my family') 2. p.34853. Sec. IV and V: Ibelieve EPA has the legal mandate and the authority to limit the emission ofGHG. It certainlyhas the moral responsibility to do so.

I3. p. 34857&76. VI.B.2&3: Given that NGCC are 46% more efficientthan gas conversion or co-firing, I agree with the proposal that these two strategies should be not be allowed to meet GHG reduction in the BSER. We shouldbe investing in the best available EGUs, even ifthere are stranded costs. 4. p. 34866, VI.C.2.c: I believe the EPA should decide on a 75% NGCCtarget utilization rate, as this will cut GHGthe most, and fastest. 5. Regarding the extra cost ofmore aggressive plans, let me commentthat the current EPAproposal is only projectedto raise electric powerprice by 6-7% (Sec. X.D, p. 34934). Given the existential threat from GHG, this is apaltry price increase to pay, especially whenthe health co-benefits are larger than the costs. 6. p. 34871, VI.C.3.b.2: Ithink we have to support nuclear powerdespite its problems. 7. p. 34875, VI.C.4.c. and see VILE. In response to the EPA suggestion, I concur that an annual incremental savings rate of2% should be considered. This will result in better construction codes that will have a positive impact for many years. 8. p. 34877, VI.C.5.c. Natural gas is not the solution to GHGreduction. Among otherproblems, it would encourage even more fracking. Encouragingthe building ofany newfossil fuel EGUjustkicks the can down the road. Not sure I understand how this affects the "basis". IfnewNGCC are not included in the projected basis, then the basis wouldbe higher and their use as replacement would then meet the reduced guideline with ease, and that would not be good. 9. p. 34878, VI.D.2. I agree with the EPA thatrestricting the BESRto Building Blocks I & 2 would not be good. RE (BB-3) and ER (BB-4) are vital and should

eventake precedence ifit were not for complying with the letter ofthe CAA. The subsequent argument for the four BB BESRin VI.E.5.b is compelling. I viewthe counterarguments in E.6.b.(iv) as obstructionist and hope they will not prevail. I0. Regarding Section VIII, I am concerned that some states will be recalcitrant about complying. Regarding the requested comment on p. 34095, VIII.B.2.b, it does

seem like a good ideato update the plan with a second submittal in 2025 and to have state program implementation milestones (B.2.d) and to make noncompliance consequences (B.2.e) more than a slap on the wrist. II. Regarding Option I vs. Option 2, Ipreferthe greater GHGreduction ofOption 1 andthe faster implementation ofOption 2. My main concern is that we are doing too little, too late to avert the existentialthreat ofglobal warming. 12. Regarding State vs. Regional compliance approach, in principal, I think regionalism is ideal, but I am concerned that it is more difficult to get anything done that involves several states, but Iwould be happy to be proved wrong. 13. Regarding the 3% discount rate you use: Consideringthe amount ofcash that is available and few decent interestrates available and the still high unemployment rate, investmentin GHGreduction nowmakes a lot ofsense when the discount rate is probably even lower than 3%. GHGreduction would be favorable for the economy, and itis a good long term investment.

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