Comment made by John F. Nagle (nagle(c/!cmu.edu, 412-268-2764) 

EPA hearing in Pittsburgh 7/31/14. Docket ID No. EPA-HQ-OAR-2013-0602 

I thank the EPA for giving me the opportunity to comment on its proposal for GHG 

reduction from EGUs and I thank this panel for agreeing to listen during this two day 

marathon. I appreciate the hard work and due diligence that the EPA has put into 

producing a well crafted proposal, although it is a bit daunting. 

I am an emeritus professor at CMU in the fields of physics and biology. Ten years 

ago I taught a course entitled Energy and Environmental Issues. At that time one could 

still make a case, albeit a weak one, that man-made global warming might not be 

occurring, so my course encouraged debate among students. That was a lopsided debate 

even then. I'm pleased that EPA's proposal emphasizes the scientific consensus. 

Recently, CMU bestowed the prestigious $50K Dickson prize on Jared Diamond for 

his book entitled Collapse. That book serves as a warning to us today. It describes 

several civilizations that collapsed, sometimes by its people not being able to recognize 

an existential threat. Fortunately, science recognizes the threat of global warming, and 

I'm pleased that the EPA proposal emphasizes that. However, many of Diamond'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. It is important to recognize 

that it took hundreds of years for those collapses to play out, just like the impending 

irreversible collapse of the West Antarctic ice cap. The EPA document well appreciates 

the long term nature of the existential climate threat. Action must be taken to limit GHG 

before it becomes too late to prevent the consequences of global warming mentioned in 

the EPA document. 

In response to the EPA solicitation for specific comments, I have a baker's dozen. As 

there isn't time to read all 13, I will place my written comments in the record. The 

general thrust of my comments is to urge EPA to adopt the strongest possible regulations 

that will reduce further increases in GHG the most and the fastest. So, for the BSER, I 

like Option I for most reduction and Option 2 for faster reduction. Natural gas is not the 

long term solution, even discounting my concern about getting frackcd. so I definitely 

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%, I think it is 

quite affordable. Indeed, we should be willing to pay a lot more, especially as EPA's 

estimate of health co-benefits is even greater than the cost of GHG reduction. Even 

though I am concerned that 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 

might help avert collapse of the sort described in Diamond's book. 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. I oppose limiting the application to only the first two 

building blocks. We need RE instead of fossil fueled EGU and we need to 

promote energy reduction. (I'm constantly turning oJTthe lights all:er my family') 

2. p.34853. Sec. IV and V: I believe EPA has the legal mandate and the authority to 

limit the emission of GHG. It certainly has the moral responsibility to do so. 

I 
3. p. 34857&76. VI.B.2&3: Given that NGCC are 46% more efficient than 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 should be investing in 

the best available EGUs, even if there are stranded costs. 

4. p. 34866, VI.C.2.c: I believe the EPA should decide on a 75% NGCC target 

utilization rate, as this will cut GHG the most, and fastest. 

5. Regarding the extra cost of more aggressive plans, let me comment that the 

current EPA proposal is only projected to raise electric power price by 6-7% (Sec. 

X.D, p. 34934). Given the existential threat from GHG, this is a paltry price 

increase to pay, especially when the health co-benefits are larger than the costs. 

6. p. 34871, VI.C.3.b.2: I think we have to support nuclear power despite 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 of 2% 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 GHG reduction. Among 

other problems, it would encourage even more fracking. Encouraging the 

building of any new fossil fuel EGU just kicks the can down the road. Not sure I 

understand how this affects the "basis". If new NGCC are not included in the 

projected basis, then the basis would be 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 that restricting the BESR to Building 

Blocks I & 2 would not be good. RE (BB-3) and ER (BB-4) are vital and should 

even take precedence if it were not for complying with the letter of the CAA. The 

subsequent argument for the four BB BESR in VI.E.5.b is compelling. I view the 

counterarguments in E.6.b.(iv) as obstructionist and hope they will not prevail. 

I 0. 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 idea to 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, I prefer the greater GHG reduction of Option 1 

and the faster implementation of Option 2. My main concern is that we are doing 

too little, too late to avert the existential threat of global 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 I would be happy to be proved wrong. 

13. Regarding the 3% discount rate you use: Considering the amount of cash that is 

available and few decent interest rates available and the still high unemployment 

rate, investment in GHG reduction now makes a lot of sense when the discount 

rate is probably even lower than 3%. GHG reduction would be favorable for the 

economy, and it is a good long term investment. 

2