Commentstothe US Environmentai Protection Agency on the proposed Carbon Pollution Emission Guidelines for Existing StationarySources: 

### Electric UtilityGenerating Units Docket ID

### #: EPA-HQ-OAR-2013..0602

Submitted by James Schulman, AlA Treasurer, Building Materials Reuse Association 631 ESt. NE, Washington, DC 20002 

### 202/544-0069;

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### 29 July 

### 2014 Good afternoon EPA leaders and staff! My name is Jim Schulman, and I am an active member ofthe DC Sierra Club Zero Waste Committee. I am also theTreasurer and a member ofthe Board of Directors ofthe Building Materials Reuse Association. The BMRA is the leading proponentforthe deconstruction and building material reuse industries. Community Forklift, a used building materials business in the Hyattsville, MD area which I founded, is atypical BMRA member. Community Forklift is a net negative carbon emitter due to the fact thatthe extraction ofvirgin raw materials and energy for



## manufacturing~~ot used in the processing ofthe large quantity ofsalvaged building materials sold there. I believe that building material reuse is a significant element ofour energy future, and that building materials oughtto be designed and manufactured for multiple useful lives. The BMRA itself is a proud member oftheAmerican Sustainable Business Council. The ASBC currently represents over 175,000 large and small triple-bottom line businesses in America. The ASBC was extremely pleased to be able to host EPA Administrator Gina McCarthy as a keynote speaker at its Annual Business Summit last year. The ASBC is highly supportive ofthe EPA's effortsto regulate greenhouse gas (GHG) emissions from power plants. The ASBC has also urged the State Departmentto disapprove construction ofthe Keystone 

### XL pipeline to pump tarsands oil from Canada. In general, the BMRA and ASBC are supportive of EPA's significant and comprehensive efforts to regulate gases that contribute to climate change. I speak now regarding some particulars ofthe Clean Power Plan, not representing any organization, but as a citizen:

• The inclusion ofthe option for states to worktogether in regional groups is extremely important. It reflects the economic and ecological realities ofthe retail-wheeling ofpower {and pollution) across state lines.

• I appreciatethat coai ash waste disposal reductions could be a majorside benefit ofthis standard. itwiii reduce the toxicity of citizens' land, air, 

### &water over and above smokestack emission reductions.

• I also note the reference in the plan to the consideration that EPA wil! give to possible GHG reductions from land use and agricultural waste management improvements. Acknowledging that better land use and waste management planning can be ways forstates to minimize overall emissions is a route I hope some states will take to address the emiss.ions "costs ofsprawl" and unnecessary ag waste burningC!rl?,j\.:\'e. 

### 1e ! 

### am extremely pleased to see that there is notastrong emphasis in this plan on carbon-capture and storage (or enhanced oil recoveryforthat matter), since EPA has identified the high-cost of retrofitting existing plants forthis purpose. The long-term efficacy ofcarbon capture and storage is, I believe, unproven.
• Because the generation ofenergy from burningwaste has proved to be less efficientthan burningfossil fuels, 

### i hope thatthe proposed standard wili also lead to a reduction in waste-to-energy projects, otherwise known as incineration.This would be a major enhancementto US environmental protection.
• As a resident ofthe Capitol Hi!! neighborhood ofWashington, DC, I urge thatthe proposed standard be amended to include in its scope the regulation ofexisting government owned oroperated power plants, like the Capital Power Plant. That facility still occasionally burns coal near where we are today. Please do not exempt Federal or any unused District ofColumbia-based facilities from this Standard! There is no question in my mind thatthe Architect ofthe Capito! should be required to comply with national EPA regulations.

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### Ultimately, iffossil fuel generating capacity, including natura! gas, keeps growing along with the efficiency with which it is produced the US will fail to achieve the objective ofcleaning our air. We need to reduce the burning offossil fuels- not merely make burningthem more efficient. As a nation I have every confidence that we can break our addiction to dirtyelectricity and gas-powered automobile use, butwe have been unsuccessfullytryingto applythe equivalent ofa nicotine patch for a generation. It is time to go cold turkey and implementthisflexible carbon reduction pian. Thank you forthis opportunityto share myviews.

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