Testimony on EPA's Proposed Rule for 

"Standards of Performance for Greenhouse Gas Emissions for 

New Stationary Sources: Electric Utility Generating Units" 

Docket Number EPA-HQ-OAR-2011-o66o; FRL-9654-7 

Presented by Robert Collier 

Research Analyst 

Environmental Defense Fund 

May 24, 2012 Public Hearing 

Chicago, IL 

Thank you for the oppmtunity to testify today. My name is Robert Collier and I am here on 

behalf of Environmental Defense Fund (EDF), a non-partisan environmental organization with 

more than 750,000 members nationwide and 37,000 members in Illinois. EDF is dedicated to 

working toward innovative cost-effective solutions to environmental problems, building on a 

foundation of sound science, economics, and law. 

The proposed standards are an important step towards addressing the massive quantities of 

climate destabilizing pollution emitted from U.S. power plants, one of the largest sources of 

greenhouse gases (GHG) in the world. By halving the lifetime carbon emissions from new coalfired power plants relative to a traditional coal plant, these historic clean air standards will 

provide long overdue and urgently needed protections for our health and climate while 

strengthening our Made in the U.SA. clean energy economy. 

Urgency of action: human health and climate impacts 

Climate change presents a clear threat to the U.S. and to the world. The United States Global 

Change Research Program, started in 1989 as a Presidential initiative under George H.W. Bush, 

has determined that if carbon pollution is not reduced, it is likely that American communities 

will experience increasingly severe climate impacts. 

Since the 1980s, Midwesterners have been experiencing intense heat waves more frequently 

than any other time except the Dust Bowl era.i Data from the insurance industry reveals that in 

2011 Americans saw 12 climate disasters causing at least a billion dollars of damage each, a 

record number of such events (see appended graphic). Among these disasters were two major 

floods in the Upper Midwest and the Mississippi River and a blizzard that paralyzed the region 

and brought Chicago to a standstill. ii Although any particular individual extreme weather event 

cannot be directly connected to climate change, changes in frequency and intensity can be 

connected-and these are precisely the type of impacts projected to affect American 

communities with increasing frequency and severity as climate-destabilizing emissions continue 

to accumulate in the atmosphere. 

Unless· our country takes aggressive action to reduce GHG emissions, climate impacts are 

projected to worsen. Severe heat waves such as the unprecedented 1995 event in Chicago could 

happen as often as every other year.iii Furthermore, warmer temperatures will also lead to 

rising levels of dangerous smog pollution, which is known to cause heightened risk of 

respiratory infections, more asthma attacks, and more premature deaths. 
Delay is not an option 

In the interest of the health and prosperity of our citizens, ecosystems, and economies, we 

simply cannot afford additional delay. Each year U.S. power plants discharge over 2.3 billion 

tons of carbon dioxide pollution, an amount that exceeds total carbon emissions of 

industrialized nations such as Russia, Japan, and Germany (see graphic below). Since power 

plant infrastructure is extraordinarily long-lived-- the average retirement age of a coal plant is 

so years -- building just one inefficient, emission-intensive plant today locks us into millions of 

tons of future climate pollution. 

U.S. Power Generation GHG Emissions Surpass Emissions 

from Most Countries 

(Million Metric Tons C02 Equivalent) 

Soon»: 

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UNFCCC • Slxlll ~-~~~,._. OllfiiiiiiiiiiiOnll commu!Xallonl tam~ nat lnCIUcMd In~ liD IIW carw.Gan,- are.~~~ou .. O..trw.11Dfy c... lor IIW period 111110-2008 (r.-.ct~ng ~ 1 ~). 

Midwestern states and the City of Chicago have led the way 

During the past several years, states across the nation have adopted GHG emission standards 

for new fossil fuel fired power plants that have laid the groundwork for a strong national 

standard. Right here in the Midwest, communities are working together to lower carbon 

pollution and slow the serious impacts of a changing climate. For example, in 2007 Minnesota 

enacted the Next Generation Energy Act, which requires increases in power sector greenhouse 

gas emissions from any new large coal-fired power plants built in Minnesota or the import of 

electricity from such a facility located out-of-state to be offset by equivalent emission reductions. 

The City of Chicago is taking immediate action both to mitigate additional impacts and adapt to 

changes already underway. With the Climate Action Plan launched in 2008, the City set on a 

path to reexamine the existing fleet of coal-fired power plants throughout the state, promote 

energy efficiency and renewable sources of energy, and adapt to climate changes already set in 

motion by reducing ozone-forming air pollution, managing the heat-island effect, and preparing 

the city for more intense beat waves.iv,v 
Shifting market dynamics are influencing utility sector business decisions 

These standards are aligned with market forces that are already driving utilities to develop 

cleaner technologies. An April 2 012 World Resources Institute report explains that "lower 

natural gas prices, declining growth in electricity demand, rising coal prices, and increased costcompetitiveness of renewables" are shaping business decisions in the utility sector.vi 

Leaders within the utility industry recognize the importance and achievability of EPA's proposed 

standards. For instance, Ralph Izzo, CEO of Public Service Enterprise Group, issued the 

following statement immediately after EPA released the proposal: 

"The Agency's action establishes a logical and modest standard for new electric 

power plants and provides the industry with much needed regulatory certainty. 

The EPA provides aframeworkfor the industry to confront this problem in a 

cost effective manner."uii 

Diverse voices of support 

In addition to the scores of citizens testifying today, over 1.2 million Americans have 

spoken out by submitting written comments in support of EPA's historic proposed health 

protections. Groups that represent millions of Americans from all walks of life have also 

released strong supportive statements: 

• "Catholics United welcomes the EPA's greenhouse gas rule ... Care f or creation is a 

central moral concernfor many people offaith.''uiii 

• BlueGreen Alliance: "Today's rule ensures that new power plants will be built 

cleaner a nd more efficient, creating jobs and reducing greenhouse gas emissions 

and ensuring that the nation is competitive in the 21st century economy.'u 

• ~s the nation's largest online Latino advocacy group, Presente is very 

pleased that EPA has announced these new standards to protect our health by 

limiting carbon pollution that causes global warming ... This is a critical issue for 

Latino communities who will feel the impacts of climate change closely and directly 

whether from worsening smog, harsher summers, or worsening drought.''x 

• "The American Public Health Association welcomes a new standard for new 

power plants released today by the U.S. Environmental Protection Agency that will 

strengthen the Clean Air Act, reduce carbon pollution and protect public health. "xi 

New clean air standards are a critical step in the right direction 

Under EPA's standards the nation's energy needs can be met through a diverse, efficient mix of 

power sources, including renewable energy, efficient natural gas power plants, combined heat 

and power, and improvements in the efficiency of our energy use. The standards also provide a 

pathway for the development of carbon capture and sequestration for coal plants. The New 

Source Performance Standards for carbon pollution will provide power companies with 

regulatory certainty for prudent, long-term investments in cleaner, homegrown energy that puts 

Americans to work. The technology we need is available today. Working together, America can 

build the energy generation infrastructure we need to protect our health and strengthen our 

economy. 
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(i) Billion Dollar Weather/Climate Disasters 

1980- November 2011 

NOMINESOISINCOC 

80 81828384 85 8687 88 8990919293 94 95 96 97 98 99 00 01 02 0304 05 06 07 080910 11 

Years (1980 - Nov. 2011) NCDC;"'-'Ya..~(PCS) 

Source: NOAA, http: //www.noaanews.noaa.gov /stories2on/2o111207 novusstats.html 

i U.S. Global Change Research Program, Global Climate Change Impacts in the United States, Regional 

Climate Impacts: Midwest (2009), available at 

htto://www.globalchange.gov/images/cir/D<lUmjdwest.pdf. 

ii Press release, Insurance Information Institute, "Private-Sector Insurers To Pay More Than $32 Billion 

In Claims From Natural Disasters In 2011," December 30, 2011, available at 

http://www.iii.org/press releases/priyate-sector-jnsurers-to-pay-more-than-32-billion-in-claims-fromnatural-disasters-in -2011-.html. 

iii U.S. Global Change Research Program, Global Climate Change Impacts in the United States, Regional 

Climate Impacts: Midwest (2009), available at 

http://www.globalchange.gov/images/cir/D<lflmjdwest.pdf. 

iv Chicago Climate Action Plan, Clean & Renewable Energy Sources, available at 

http://www.chicagoclimateaction.org/filebin/pdfjfinalreport/CleanRenewableEnergy.pdf. 

v Chicago Climate Action Plan, Adaptation, available at 

http://www.chicagoclimateaction.org/filebin/D<lf}finalrei)Ort/Adaptation.wf. vi James Bradbury, World Resources Institute, "U.S. Electricity Markets Increasingly Favor Alternatives to 

Coal," April 2012, available at 

http://wf.wri.org/factsheets/factsheet us electricity markets favor alternatives to coal.pdf. VIi Press release, Public Service Enterprise Group, "Statement by PSEG Chairman and CEO Ralph Izzo on 

the EPA's Proposed Carbon Pollution Standards," March 27, 2012, available at 

http://pseg.com/info/media/newsreleases/20I2/2012-03-27.isp. 

viii Press release, Catholics United, "Catholics United Applauds Greenhouse Gas Health Standard,., March 

27, 2012, available athttp://www.catholics-unjted.org/content/press-release-catholics-united-applauds-

~eenhouse-gas-health-standards. 
ix Press release, BlueGreen Alliance, "BlueGreen Alliance Applauds New Clean Air Protections," March 28, 

2012, available at http: //www.b uegree lli ance.on~ ews/latest/bga applauds new clean air

protections. 

x Press release, Voces Verdes, "Latinos Can 'Breathe Easier' Thanks to EPA's Proposed Carbon Pollution 

Standard," March 27, 2012, available at http: //www vocesyerdes.o~ FINAL FINAL VOCES 3-26-

12 Carbon Rule Release.pdf. 

xi Press release, American Public Health Association, "American Public Health Association cheers new 

clean air standard for power plants," March 27, 2012, available at 

http://www.apha.org/about/ news/pressreleases/2012/epa+greenhouse+gas+rules.htm.