I\udubon 

Environmental Protection Agency 

Proposed Carbon Emissions Rule 

Docket ID No. EPA- HQ-OAR-2011-0660 

National Audubon Society 

1150 Connecticut Avenue NW 

Washington, DC 20036 

202-861-2242 

My name is Taldi Walter, Assistant Diilector of Legislative Affairs, on behalf of the National 

Audubon Society and our members, thank you for the opportunity to comment on the 

proposed carbon rule today. Audubon is the oldest conservation organization in the country 

and is supported by half a million members, 460 chapters, and 23 states offices. Audubon is 

committed to conserving and restoring natural ecosystems, focusing on birds, other wildlife and 

their habitats, for the benefit of humanity and the earth's biological diversity. 

I want to express our strong support for the U.S. Environmental Protection Agency's historic 

efforts to put limits on carbon dioxide and other greenhouse gas pollutants from new power 

plants. 

According to the Energy Information Administration, power plants are the largest source of 

carbon pollution, accounting for approximately 40 percent of carbon emissions. Without action, 

power plant emissions will continue to contribute to the unsustainable rate at which the planet 

is warming. 

Climate disruption is harming natural systems across the globe, posing the greatest threat to 

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 of one-fourth to one-third of all species on earth. With such an unprecedented rate of 

change, many species cannot adapt. 

Audubon is greatly concerned about the impacts of climate change on avian species. Birds have 

long served as key indicator species of ecosystem health. Birds also help control insects, 

rodents, and pests that can destroy crop foods. Additionally, one-third of all human food comes 

from plants that are pollinated by birds, butterflies and other insects. Lastly, bird watching, 

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hunting, and other outdoor activities enjoyed by more than 80 million Americans, support over 

2.6 million jobs. 

While some birds may adapt to a warming planet, other species are highly adapted to particular 

habitats throughout the hemisphere, making adaptation at numerous latitudes throughout the 

globe impossible. Here are some examples of how global warming is affecting birds: 

• Audubon's 2009 Birds and Climate: Ecological Disruption in Motion Report, authored by 

Audubon scientists using decades of Christmas Bird Count data, found that birds are 

shifting their winter ranges northward an average of 35 miles; more than 60 of the 305 

observed species have moved their range in excess of 100 miles north. This is a clear 

indication that climate change is already impacting birds on a global scale. 

• As rising sea levels inundate coastal wetland habitats, species like the American 

Oystercatcher will 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 a vital food source 

after a long migration from wintering habitats to spring nesting grounds. If food 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, or the Eastern Meadowlark, a declining grasslands 

bird, have very few options for emigration when favored habitats vanish. 

• We are already seeing the impacts of frequent droughts, as the breeding grounds for 

numerous waterfowl species dry up in the prairie pothole regions of the West. 

Audubon commends the EPA for its leadership on this critical issue and we fully support the 

proposed rule. 

Thank you for considering these comments.