Don Parsons 

State Representative, HD44, GA 

Chair, House Energy, Utilities and Telecommunications Committee 

3167 Sycamore Lane, Marietta, GA 30066 

repdon@donparsons.org 

RE: EPA Docket Center, Room 3334, EPA WJC West Building, 1301 Constitution Ave. NW., 

Washington, DC 20004, Attn: Docket ID No. EPA-HQ-OAR-2013-0602. 

My name is Don Parsons. I am a Georgia State Representative from Marietta, Georgia. I chair 

the Energy, Utilities and Telecommunications Committee in the Georgia House of 

Representatives. 

Thank you for the opportunity to present my thoughts on the proposed rule. I appreciate much of 

the work done by the EPA. There is no doubt in my mind that the air we breathe today is cleaner 

than if the EPA had not been established. 

From the time I was in the fourth grade until I graduated from college, my family and neighbors 

breathed polluted air, our cars and streets were covered in a black grit every morning and we 

dealt with the strong and pungent odor of chlorine and other chemicals on a daily basis. This 

was in the Kanawha Valley of West Virginia, once only second to the Ruhr Valley of Germany in 

the production of chemicals and chemical products. I know that sometimes industry does not do 

the right things for the people affected by its actions, and sometimes the people need some 

help. 

However, I also know that those chemical plants provided the jobs for most of the people in that 

valley. The fathers of most of my classmates worked in some capacity for Union Carbide, 

Westvaco, Monsanto, DuPont or some other chemical plant. Those plants were the economic 

engine of the valley. The coal that was used in those plants provided jobs for miners from 

throughout the region, and provided a livelihood for their families. And the management of those 

companies demanded excellence in the public school systems, and although I did not realize it 

at the time, this nation as well as that region were beneficiaries of that. 

These are some of the the components of the proposed rule change that, unfortunately, the EPA 

and the current administration in Washington, DC are apparently not taking into consideration. I 

don't know whether or not the Ruhr Valley in Germany is still the number one chemical 

producing area of the world, but I'm pretty sure the Kanawha Valley is not number two. And if 

this proposed rule is adopted, more and more of those miners of West Virginia, southwest 

Virginia, Virginia, Kentucky, Pennsylvania, and from across this nation will not have jobs, with no 

way to provide a livelihood for their families. These are good, hardworking people who have 

done nothing to deserve that their livelihood be taken away from them. What they have done is 

to provide the resource to build the factories, the skyscrapers, the tanks, warships, vehicles and 

airplanes that have made this country what it is, and defend it against those who hate it for what 

it is. I seriously doubt that anybody was complaining about carbon emissions from the burning of 

coal for the production of warships and aircraft on D-Day. 

In its Executive Summary, the EPA states, "We project job gains and losses relative to coal and 

natural gas production, and demand side energy efficiency sectors. In 2020, we project job 
growth of 25,900 to 28,000 job-years in the power production and fuel extraction sectors, and 

we project an increase of 78,800 jobs in the demand-side energy efficiency sector." I don't see 

how a reduction in the use of coal can possibly result in a job growth of 28,000 jobs in the fuel 

extraction sector. 

The EPA makes very prominent references to the President's Climate Action Plan, which 

according to the EPA "recognizes that climate change has far-reaching harmful consequences 

and real economic costs". It goes on to say, "The Climate Action Plan details a broad array of 

actions to reduce GHG emissions that contribute to climate change . . ." To that I offer the 

following. When the health and welfare of people are adversely affected by the actions of man, 

some positive action is sometimes justified when very limited negative economic activity might 

occur. However, for action as drastic as the proposed rule to be put into place, an action that will 

place severe economic hardships on citizens of this nation based upon unproven theories of 

climate change, that is a completely different thing, and should not be considered, should not be 

accepted and should not be approved. 

In closing, the EPA in its summary states, "The CAA, as interpreted by the courts, identifies 

several factors for the EPA to consider in a (Best System of Emission Reduction) BSER 

determination. These include technical feasibility, costs, size of emission reductions and 

technology (e.g., whether the system promotes the implementation and further development of 

technology). I would ask the a EPA to consider what Senator Manchin has proposed, and that is 

give industry time to develop the technology needed to allow the use of coal to meet the desired 

standards. I do not own one clump of coal. I have no financial interests in it whatsoever. But, I 

know what a great source of energy it is. I know that we have vast reserves of it. And I know that 

we should not penalize the coal industry and the families that depend on the mining of it just to 

enact standards that are not perfected. 

Thank you