Testimony 

EPA's Proposed Rule 

"Standards of Performance for 

Greenhouse Gas Emissions from New 

Stationary Sources: Electric Utility 

Generating Units" 

Docket Number EPA-HQ-OAR-2013-0495 

Presented by Lucia Oliva Hennelly 

Environmental Defense Fund 

On behalf of 

Adrian Shelley, Executive Director 

Air Alliance Houston 

February 6, 2014 Public Hearing 

Washington, D.C. 

Good morning. My name is Lucia Oliva Hennelly. I work with Environmental Defense 

Fund, a non-partisan environmental organization with more than 750,000 members 

nationwide. 

I am here today as a member of the diverse Latino community in the United States, to 

support EPA in regulating carbon pollution from new power plants with the strongest 

possible rules. Carbon pollution has disproportionate negative impacts on our Latino 

communities, and as the fastest-growing population in this country, Latino voices on this 

issue must be heard. 

I am delivering comments on behalf of someone who could not be here today, Adrian 

Shelley, Executive Director with our partner organization, Air Alliance Houston, because 

carbon pollution impacts Latino communities everywhere, not just in Washington. 
As the I-iouston region's leading air guality and public health nonprofit, we at Air 

Alliance Houston are mindful of the effects that carbon pollution has on our local 

communities. 

For two years running, Harris County has been the fastest growing county in the nation, 

and Houston is the most diverse major city in America. It is a majority-minority city, and 

more than a third of its residents are Latino. 

Harris County is also ground zero for the environmental justice movement. Although 

everyone in Harris County could suffer from the effects of climate change, we can 

expect our low-income communities of color, including many Latinos, to suffer 

disproportionately. There are several reasons for this. 

First, these communities are in the most vulnerable locations. Many of our 

environmental justice communities are on Houston's East End and along the Houston 

Ship Channel. These communities are on the front lines of any potential sea level rise or 

major hurricanes, both exacerbated by climate change. The primary cause of climate 

change is carbon pollution, and the primary source of carbon pollution is fossil-fuel fired 

power plants. This is what makes the proposed standards we are discussing today so 

important. When they are finalized, they will put the first-ever national limits on the 

amount of carbon pollution that power plants can emit. That's a major step toward 

protecting our communities from the damage caused by climate change. In Houston, 

these are communities that are surrounded by our city's petrochemical industry: 

refineries, chemical plants, tank farms, and the like. Some estimates have suggested 

that 1,400 tanks in Houston are at serious risk should a 25 foot storm surge occur. 

Those tanks threaten our most vulnerable residents. It should also be noted that 

these are lower-income residents, including many Latinos, who are less likely to 

have flood insurance. 
Second, the public health impacts of climate change will disproportionately impact our 

environmental justice communities. Climate change will lead to such adverse effects as 

rising sea levels, extreme weather events, heat, and drought. Many of these impacts will 

weigh more heavily on Houston's vulnerable populations. Climate change, exacerbated 

by carbon pollution, will also lead to an exacerbation of ambient air pollution, 

particularly ozone. Our environmental justice communities already suffer worse air 

quality than most of Houston and, under the threat of climate change, they can expect to 

suffer more, as some of my colleagues have shared with you today. 

Third, the health of environmental justice communities is already compromised. Our 

surveys of Houston Ship Channel residents show that they suffer more health problems 

than the rest of Texas. Fully 27% suffer from asthma or another respiratory disease, 

compared to 12.7% of Texans at large. Similarly, 5.6% of Ship Channel residents 

report having cancer, as compared to 3.7% of Texans. Texas also has the most 

uninsured residents of any state in the nation. Our surveys indicate that 51 % of 

Ship Channel residents do not have healthcare coverage. 

Houston has been called "the energy capitol of the world." At Air Alliance Houston, we 

do not believe we are accurately measuring the true cost of the energy we produce. It can 

be measured in billions of dollars of corporate profit, or it can be measured in years 

and live lost within our vulnerable populations. We refuse to weigh dollars against 

lives, and we are unsympathetic to claims that bringing our nation's carbon 

emissions under control is not economically feasible. 

For more than a century, Houston has been home to great technical advances in the 

energy economy. We have great faith in our business community. It has risen to 

challenges in the past and it will do so again. We call on the EPA to regulate carbon 

pollution from new power plants with the strongest possible rules, and on the business 
community to embrace regulations that will lead us all into the clean, healthy energy 

economy of the future. 

Thank you for the opportunity to comment. Please contact us if you have questions or 

wish to discuss these matters further. 

Adrian Shelley, Executive Director, Air Alliance Houston; 713-528-3779, 

adrian@airalliancehouston.org