To: Environmental Protection Agency

From: Elizabeth A. Comeaux l 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. 2 In 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. 3 Keep 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. 5

These 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

3 Robert 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 4 Paul 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. 5 As 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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2in earthquakes never before seen. 6 This 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. 7 According 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. 8 Amory Lovins, physicist at the Rocky Mountain Institute, has been making information along these lines available to the public for years. 9 It 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

6 For 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=com conte 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, andit 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-energ y - using-solar . 8 Mark Z, Jacobson, footnote 1 above. 9 See, for example, http://www.rmi.orP/ReinventingFire 19 See, for example, http://www.sustainablebusiness.com/index.cfm/go/news.display/id/25475 and Intp://cleantechnica.com/2013/03/20/over-3-times-more-greenjobs-per-million-than-fossil-fuel-or-nuclearjobs/ .

3reality 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.

11 Mark 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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