Testimony to US EPA Federal Register 

New Source Performance Standards 

Docket ID: EPA-HQ-OAR-2011-0660 

May 24, 2012 Washington D.C. 

Good afternoon. My name is Sarah Mullkoff. I hail from the State of Michigan where I've lived my entire 

life, and work out of the Great Lakes Office for the National Wildlife Federation on clean energy and 

climate campaigns, and also with theRE-AMP network. NWF boasts over 170,000 supporters in the state 

of Michigan, and over four million nationally. RE-AMP is a network of 144 organizations and 

foundations partnered across eight Midwest states working on comprehensive policy to reduce our 

greenhouse gas emissions. 

I ~ake great prid&-m~arry a strong identity with where I'm from- the place trademarked by 

precious natural resources like the cleanest freshwater beaches, pristine forests and ripe agricultural 

land. It' s also the home of fresh cherry pies and peach cobblers, family past time that summer has never 

forgotten. 

As part of my outdoor heritage in enjoying this state, I contribute considerable time investing into the 

land, tending to the homestead style plot at my home garden; the two community garden plots, as well 

as help on my boyfriend's four acre farm in Detroit. 

In addition, I also help volunteer at our community food bank, the Greater Lansing Food Bank, which 

currently covers to the three counties in the center of the state: Ingham, Eaton, and Cl intons through 

food gatherer, distribution programs and various gardening programs. One of the programs through The 

Garden Project, the Gleaning program, rescues excess edible produce from Michigan State University 

and area farmers to distribute to a vast network of recipients. Many of these include traditional 

Michigan crops, such as apples, pear, peaches cherry and other berries. 

This year, extreme weather has hit more severely than ever before, and Michigan crops are being 

adversely affected. While the Gleaners program I just mentioned usually collects about 250,000-

350,000 pounds of produce from the area, this season that will be diminished to about 150,000 due to 

extreme loss apple and other fruit trees lost this year. That half as much as they've been able to collect. 1~1 

--\VtO-'S~" <~ rQL.)Ptt. ~tc-·• }'{N~. 

The string of weather events including unseasonably warm weather in March switching drastically to a 

late April freeze has wiped out a significant source of Michigan's entire fruit crop. Once tress start to 

come out of their dormancy with warmer weather, which was jumpstarted in March, the prematurely 

bloom. After several overnight freezes in late April though, their vulnerability at the young age seriously 

stunts the rest of their development and ability to bear fruit later in the summer. The lack of crop will 

inevitably have tremendous economic impacts on farmers' business, markets, and work. According to 

the US Department of Agriculture, damage of the extreme weather events are accounting for $223.5 

millions lost, with the highest declines pointing to 90% apple 90% sweet cherry loss and 95% peach loss. 

The loss of fruit trees and impacts.of bizarre weather are not just an anomaly this year. The warmer and 

wetter weather this year emphasizes that there is increased levels of carbon dioxide in the atmosphere, 
\._ --1•·c)· LU,; a,J#ti-f'~ lf.(\.01 ~ <:.J f"YI'( 

and it continues to exacerbate-:'7 Cumulative impacts of climate change causing air pollution, specifically 

those released from coal-burning power plant smokestacks are going to continue to result in higher 

average temperatures and extreme weather, thus also continue to adversely affect agriculture. 

The new proposed standard, the New Source Pollution Standard, takes an important step to alleviate 

these concerns for the future. I strongly support this as an important measure to ensure that power 

plants must reduce their carbon pollution by using sound and advanced technology. This proven :~ess 

will also provide assurance that the carbon limits will not have an adverse impact on our econom'l7\.he 

new carbon rule will also take a critical step to set new modernized standards on our oldest power 

plants generating electricity and modernize our economy. f-.-

It is critical that the EPA commits to finalize and publish this carbon rule this year. Next, it is critical that 

the EPA also tackle emissions from existing coal-fired plants to continue to decrease our nation's 

greenhouse gas emissions. These steps will help ensure that important decisions on clean air are set in 

place fef'decades te--come (X"<-\WI.. '\.!") fv+vn_ llCnvt 'ft-./(_ C,'fi1/'#-> c 1 ~ · 

Earlier this ~ spl=iflg we planted 100 fruit trees on the farm in Detroit including apple, pear, cherry, paw 

paw, and chestnuts. While we fortunately missed the blight that affected the fruit trees 

aforementioned, I see this orchard and their early blooms as symbolic towards the future. As long as the 

EPA chooses to set strong standar~s on air pollution today and finalize the rule this year, I can rest 

assured that the tree grow he~/~that we'll be able to harvest ample pecks of produce for 

decades to come. \"<>VL"'- h.u-L~ a.(v.v 17 pk ~ 

Thank you for your time with hearing my comments today. I can be reached by email at 

mullkoffs@nwf.org.