EPA Docket Center 

Mail code 28221T, Attn: Docket ID No. EPA-HQ-OAR-2013-0602 

1200 Pennsylvania Ave NW 

Washington, DC 20460 

Statement for EPA Public Hearing 

Denver, Co July 29, 2014 

My name is Michael Hendryx. I am a Professor in the School of Public Health at Indiana University, 

Bloomington. I would like to thank the EPA for recognizing and responding to the issue of climate 

change, and especially for recognizing the critical contribution that burning coal and other fossil fuels 

makes to the climate change problem and to poor public health. However, the rule as proposed is 

incomplete and fails in my view for two interrelated reasons. First, it fails to recognize the public health 

problem created not only by fossil fuel combustion, but also by the extraction, processing and 

transportation of fossil fuels. Second, the proposed state-specific emission goals provide insufficient 

weight to the contributions that renewable fuels must make to reducing climate change and adverse 

public health impacts. 

First, regarding the problem of extraction, processing and transportation: coal, natural gas and other 

fuels do not simply appear at power plants ready for use. Coal mining is itself a highly polluting industry 

that uses fossil fuel-based explosives and machinery, destroying landscapes and fouling local air and 

water. Millions of tons of coal are transported using oil and diesel burning engines in trucks, barges and 

trains. Coal is processed at local facilities that generate water and air pollution. Over the past eight 

years, my colleagues and I have published over 25 research papers in peer-reviewed journals that 

document serious public health problems for people who live near coal mining and processing sites. 

People in these communities are more likely than those in non-mining communities to suffer from 

cancer, heart and lung disease, and poor birth outcomes including higher rates of birth defects. We 

have documented that residential communities near surface coal mining and processing sites have 

elevated levels of particulate matter in ambient air. The dust collected from these residential areas 

contains silica, aluminum, molybdenum and other metals, and chemical compounds including polycyclic 

aromatic hydrocarbons. In one study, we found that levels of ultrafine particulate matter collected from 

coal mining communities was comparable to that found in large urban settings. Laboratory studies 

indicate that the particulate matter causes vascular dysfunction, and promotes tumor-like changes in 

human lung cells. 

Second, regarding renewables, the proposed rule includes only modest goals for state-specific 

renewable energy generation. My state of Indiana, for example, is expected to generate only 7% of its 

energy from renewables by the year 2029. Arizona, a state with enormous solar energy potential, is 

expected to generate only 4% from renewables. In contrast, consider that Germany has provided as 

much as 50% of its country's electricity needs using solar power. In the absence of more ambitious but 

achievable renewable energy goals, the EPA's proposed rule, deliberately or not, will result in states 

continuing to rely on coal, burnt more efficiently perhaps, and on increased use of natural gas. Burning 

coal more cleanly does nothing to address the pollution caused by coal mining and the subsequent 

health problems created in mining communities. Increasing evidence also points to the highly polluting 

nature of natural gas extraction, especially in the form of hydraulic fracturing. To ignore the 

contributions to climate change and poor public health caused by fossil fuel extraction of both coal and 

natural gas is a serious oversight in the proposed rule. 
In conclusion, I applaud the EPA's efforts to address the problems caused by our continued overreliance 

on fossil fuels. I urge the EPA to increase the goals for renewables. I caution the EPA that we cannot 

simply replace coal with natural gas, or replace coal burnt in dirtier plants with that same coal burnt in 

slightly cleaner plants, without considering the climate change and public health costs of the full 

production cycles of these fuels (extraction, processing, transportation, combustion, and disposal), not 

simply the costs of their combustion.