Comments to the US Environmentai Protection Agency on the proposed 

Carbon Pollution Emission Guidelines for Existing Stationary Sources: 

Electric Utility Generating 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; fu:_giona!Archit,=:_.~t@gmaiL<::om 

29 July 2014 

Good afternoon EPA leaders and staff! My name is Jim Schulman, and I am an active member of the DC Sierra 

Club Zero Waste Committee. I am also the Treasurer and a member of the Board of Directors of the Building 

Materials Reuse Association. The BMRA is the leading proponent for the deconstruction and building material 

reuse industries. Community Forklift, a used building materials business in the Hyattsville, MD area which I 

founded, is a typical BMRA member. Community Forklift is a net negative carbon emitter due to the fact that the 

extraction of virgin raw materials and energy for manufacturing~~ot used in the processing of the large 

quantity of salvaged building materials sold there. I believe that building material reuse is a significant element 

of our energy future, and that building materials ought to be designed and manufactured for multiple useful 

lives. 

The BMRA itself is a proud member ofthe American 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 efforts to regulate greenhouse gas (GHG) emissions from power plants. 

The ASBC has also urged the State Department to disapprove construction of the Keystone XL pipeline to pump 

tar sands 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 of the Clean Power Plan, not 

representing any organization, but as a citizen: 

• The inclusion of the option for states to work together in regional groups is extremely important. It 

reflects the economic and ecological realities of the retail-wheeling of power {and pollution) across state 

lines. 

• I appreciate that coai ash waste disposal reductions could be a major side benefit ofthis standard. it wiii 

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 for states to minimize overall emissions is a route I hope 

some states will take to address the emiss.ions "costs of sprawl" and unnecessary ag waste burningC!rl?,j\.:\'e. 

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e ! am extremely pleased to see that there is not a strong emphasis in this plan on carbon-capture and 

storage (or enhanced oil recovery for that matter), since EPA has identified the high-cost of retrofitting 

existing plants for this purpose. The long-term efficacy of carbon capture and storage is, I believe, 

unproven. 

• Because the generation of energy from burning waste has proved to be less efficient than burning fossil 

fuels, i hope that the proposed standard wili also lead to a reduction in waste-to-energy projects, 

otherwise known as incineration. This would be a major enhancement to US environmental protection. 

• As a resident of the Capitol Hi!! neighborhood of Washington, DC, I urge that the proposed standard be 

amended to include in its scope the regulation of existing government owned or operated 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 of Columbia-based facilities from this Standard! There is no 

question in my mind that the Architect of the Capito! should be required to comply with national EPA 

regulations. 

e 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 of cleaning our air. We need 

to reduce the burning of fossil fuels- not merely make burning them more efficient. 

As a nation I have every confidence that we can break our addiction to dirty electricity and gas-powered 

automobile use, but we have been unsuccessfully trying to apply the equivalent of a nicotine patch for a 

generation. It is time to go cold turkey and implement this flexible carbon reduction pian. 

Thank you for this opportunity to share my views. 

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