# I\udubon

Environmental Protection Agency Proposed Carbon Emissions Rule Docket ID No. EPA- HQ-OAR-2011-0660 NationalAudubon Society 1150Connecticut Avenue NW Washington, DC 20036 202-861-2242
My name is Taldi Walter, Assistant Diilector of Legislative Affairs, on behalfofthe National Audubon Society and our members, thankyou forthe opportunityto comment on the proposed carbon ruletoday. Audubon is the oldest conservation organization in the country and is supported by halfa million members, 460 chapters, and 23 states offices. Audubon is committed to conserving and restoring natural ecosystems, focusing on birds, otherwildlifeand their habitats, forthe benefit of humanity and theearth's biological diversity. Iwant to express our strong supportforthe U.S. Environmental Protection Agency's historic effortsto put limits on carbon dioxide and other greenhouse gas pollutants from new power plants. According to the Energy Information Administration, power plants arethe largest source of carbon pollution, accountingfor approximately40 percent ofcarbon emissions. Without action, power plant emissions will continue to contributeto the unsustainable rate at which the planet is warming. Climate disruption is harming natural systems across the globe, posing the greatestthreatto birds and other wildlife in modern history. More than 80 percent of plant and animal species have shown changes associated with climate change. Unabated, climate change could lead to the loss ofone-fourth to one-third ofall species on earth. With such an unprecedented rate of change, many species cannot adapt. Audubon is greatly concerned aboutthe impacts ofclimate change on avian species. Birds have long served as key indicatorspecies ofecosystem health. Birds also help control insects, rodents, and peststhat can destroy crop foods. Additionally, one-third ofall human food comes from plants that are pollinated by birds, butterflies and other insects. Lastly, bird watching, 

# 4hunting, and other outdoor activities enjoyed by more than 80 million Americans, support over 2.6 million jobs. While some birds may adaptto a warming planet, other species are highly adapted to particular habitats throughout the hemisphere, making adaptation at numerous latitudesthroughout the globe impossible. Here are some examples of how global warming is affecting birds:

• Audubon's 2009 Birds andClimate: Ecological Disruption in Motion Report, authored by Audubon scientists using decades ofChristmas Bird Count data, found that birds are shifting their winter ranges northward an average of35 miles; morethan 60 ofthe 305 observed species have moved their range in excess of 100 miles north.This is aclear indication that climate change is already impacting birds on aglobal scale. • As rising sea levels inundate coastal wetland habitats, species like the American Oystercatcherwill be impacted as flooding makes submerged aquatic vegetation used for nesting and foraging unavailable.

### ~ • Many bird species have very exact migration, reproduction, breeding, nesting,thatching,**~timelines.** This evolutionary synergy is matched to specific local conditions, to maximize resources such as hatching insects in the spring that are avital food source after a long migration from wintering habitats to spring nesting grounds. Iffood sources and hatch dates do not match, hatchlings may not survive. As temperatures warm, this • synchronicity between migration and food supplies may be compromised.

• Birds that live in very limited, specialized habitats such as the Red Crossbill, which depends on high altitude habitats, orthe Eastern Meadowlark, adeclining grasslands bird, have veryfew optionsfor emigration when favored habitats vanish. • We are already seeing the impacts offrequent droughts, as the breeding grounds for numerous waterfowl species dry up in the prairie pothole regions ofthe West. Audubon commends the EPA for its leadership on this critical issue and we fully supportthe proposed rule. Thankyou for consideringthese comments.