To: Environmental Protection Agency 

From: Elizabeth A. Comeauxl 

RE: Proposed New Rules on Air Emissions from Existing Power Plants 

Date: July 29, 2014 (Denver) 

Thank you for the opportunity to express support for taking on the challenge of 

limiting the extent to which existing power plants can dump their climate-disrupting air 

pollutants into the atmosphere. I am a Colorado attorney and a member of the 

coordinating committee of the Loretto Earth Network, a faith-based public education 

network reaching almost a thousand regular newsletter subscribers and many thousands 

more through overlapping circles with whom we continually engage. 

We commend you on beginning this important work. 

We suggest you consider some of the following practical realities as you sift 

through the many public comments you are receiving: 

1. The proposed rules seriously underestimate our nation's capacity to move 

quickly to a fully renewable energy economy.2In the face of the climate 

emergency, which exponentially accelerates as we speak, these rules should 

shape the more realistic direction of rapid conversion to renewables. 

2. The proposed rules seem to ignore the continuing climate impact of using 

natural gas as a bridge fuel. Those studies that say it burns cleaner in the 

power plants need to expand their consideration to include the climate impact 

1663 Steele St #901, Denver, CO 80206. 

2 Mark Z, Jacobson (Stanford engineering professor) and others, "100% Wind, Water, Sunlight (WWS) 

All-Sector Energy Plans for the 50 United States," July 17, 2014, available at 

http://web.stanford.edu/group/efmh/jacobson/Articles/FUSStatesWWS.pdf. For an earlier set of solutions, 

see Arjun Makhijani, Ph.D., Carbon-Free and Nuclear-Free: A Roadmap for U.S. Energy Policy, 2007, 

available at http://www.ieer.org/carbonfree/ 
of the industrial process of extracting natural gas, accelerating in highly 

populated areas especially in Colorado, in all applications. For example, a 

cradle-to-grave assessment of natural gas demonstrates the largely unreported 

fact that there is no overall improvement from a climate perspective, when 

natural gas is substituted for coal.3Keep in mind that the long-term public 

costs of coal are only recently being quantified (Harvard estimates $500 

billion per year), despite its many years of steady use as a fuel in the U.S.4 

The explosion in natural gas production in recent years has barely been 

studied for its air-emissions health impacts, and early peer-reviewed studies 

are concerning.5These factors support a direction for the future that does not 

encourage reliance on natural gas, another climate-harming source of 

emissions. 

3. The Fukishima experience has educated us to the risks of nuclear generation 

facilities in the most technologically sophisticated societies. Who could have 

predicted the terrible tsunami that devastated the Japanese and sent nuclear 

pollution into the Pacific Ocean and the atmosphere? Currently, the explosion 

of natural gas production in population centers is associated with an increase 

3Robert W. Howarth and others, "Methane and the Greenhouse-Gas Footprint of Natural Gas from Shale 

Formation," March 13, 2001, ("Cornell Study"), available at 

http://www.eeb.cornell.edu/howarth/Howarth%20et%20a1%20%202011 .pdf. For a study reaching the 

opposite conclusion only in the specific application of electric generation and only because natural gas 

EGU's being of more recent construction use more current technology, see 

http://pubs.acs.org/doi/ahs/10.1021/es200930h 

4Paul R. Epstein, Jonathan J. Buonocore, Kevin Eckerle, Michael Hendryx, Benjamin M. Stout III, Richard 

Heinberg, Richard W. Clapp, Beverly May, Nancy L. Reinhart, Melissa M. Ahern, Samir K. Doshi, and 

Leslie Glustrom. 2011. Full cost accounting for the life cycle of coal in "Ecological Economics Reviews." 

Robert Costanza, Karin Limburg & Ida Kubiszewski, Eds. Ann. N.Y. Acad. Sci. 1219: 73-98. 

5As only one example, consider the work of the research team in Paonia, Colorado, led by Dr. Theo 

Colborn, available at http://endocrinedisruption.org/ . 

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in earthquakes never before seen.6This increasing risk, as well as the aging of 

nuclear facilities and its long-term waste disposal quandary, argues against 

encouraging nuclear facilities as backups for coal powered electricity 

generation. 

Therefore, we strongly urge the EPA to strengthen incentives and requirements to 

move the country into the renewable energy era. Sunlight is abundant all over the globe 

and available for power generation using current technologies, as amply illustrated by 

Germany's performance.7According to a recent publication out of Stanford University, 

rapid mobilization throughout the U.S. is affordable and can be completed, replacing 80- 

85% existing energy by 2020 and 100% by 2050, relying solely on wind, water, and 

sunlight.8Amory Lovins, physicist at the Rocky Mountain Institute, has been making 

information along these lines available to the public for years.9It is also significant that 

the renewable energy industry competes well with the fossil fuel industry in creating and 

maintaining jobs — jobs which tend to be more local and stable than corresponding jobs in 

fossil fuels.1° 

Our country needs to face up to existing policies that make it difficult for 

industries and financial markets of the past era to adapt quickly to the new economic 

6For a "tip of the iceberg" notation of the phenomenon, see interview of USGS seismologist Dr. Elizabeth 

Cochran at 

http://therealnews.com/t2/index.php?option=comconte nt&task=v iew&id=31&Itemid=74&jumival =11413 

Germany is currently providing almost one-third to one-half its electricity requirements through solar, and 

it is not a particularly sunny country. See http://thinkprogress.org/climate/2014/07/08/3456934/renewableone-third-germanv/and http://www.iflscience.com/technology/germany-now-produces-half-its-energy - 

using-solar . 

8Mark Z, Jacobson, footnote 1 above. 

9See, for example, http://www.rmi.orP/ReinventingFire 

19See, for example, http://www.sustainablebusiness.com/index.cfm/go/news.display/id/25475and 

Intp://cleantechnica.com/2013/03/20/over-3-times-more-greenjobs-per-million-than-fossil-fuel-or-nuclearjobs/ . 

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reality forced on all of us by the climate emergency." Unless we find elegant and 

equitable solutions to these existing policies, their inertial momentum will continue to 

drive us headlong into the climate emergency. For policies that you can adapt within 

your field of authority, I encourage you to do so. If collaboration with other federal 

agencies and institutions is necessary, please undertake the collaboration to get this more 

comprehensive job done! 

In sum, we urge you to revise the proposed rules toward the more realistic 

direction of immediate transition to energy generation exclusively from renewables, and 

away from any further entanglement in fossil fuel burning and nuclear waste-generation. 

Thank you. 

11Mark Hertsgaard, "Giving up Fossil Fuels To Save the Planet: The $28 Trillion Writedown," Bloomberg 

Business Week (June 26, 2014), available at http ://w ww .bu sine ss wee k.com/articles/2014-06-26/cl imatechange-and-the-two-thirds-imperative#r=hpt-ls . Also see Ambrose Evans-Pritchard, "Fossil Industry Is 

the Subprime Danger of this Cycle," The Telegraph, July 9, 2014, available at 

http://www.telegraph.co.uk/finance/comment/ambroseevanspritchard/10957292/Fossil-industry-is-thesubprime-danger-of-this-cycle.html 

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