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July 30, 2014 

U.S. EPA Headquarters 

William Jefferson Clinton East 

1201 Constitution Ave. NW 

Washington, DC 20460 

Comments for EPA Public Hearing on Reducing Carbon Pollution from Existing 

Power Plants 

SuPPort. The League of Women Voters of the United States strongly supports the Clean 

Power Plan proposed by the Environmental Protection Agency (EPA). We believe that 

taking steps to reduce this dangerous greenhouse gas are essential to protect our 

children and future generations from the effects of climate change. We commend the 

EPA for holding this public hearing, and others like it across the country, to allow public 

comment on the proposed standard for existing power plants. The League does believe, 

however, that the EPA proposal can and should be strengthened to better and more 

realistically recognize the tremendous potential for renewable energy and energy 

conservation in cutting carbon emissions. 

Importance. Burning coal accounts for about half of the electricity generated in the U.S. 

and carbon pollution from U.S. power plants accounts for 40 percent of the C02 

emissions that contribute to climate change.' Carbon pollution that causes climate 

change is responsible for increased air pollution that can cause thousands of deaths 

every year if it continues to remain unchecked. We must protect public health by 

extending limits like the ones placed on arsenic, lead, mercury and soot, to carbon 

pollution. 

According to the American Lung Association, nearly half of Americans live in counties 

that have unhealthy levels of dirty air. Dirty air, exacerbated by the climate change 

caused by carbon pollution, is responsible for premature deaths, respiratory disease and 

a higher risk of asthma attacks. It also disproportionately affects low income 

communities, as well as children, seniors and those who work or play outdoors. It can 

also lead to hundreds of missed work and low activity days. 

International and national scientific reports have shown that inaction will only increase 

the impacts and threats that climate change brings to our communities across the 

country. From increased health risks to devastating extreme weather events, climate 

change is threatening the lives of those around us. We have a moral obligation to our 

children and future generations to address the cause of climate change by cutting C02 

emissions from existing power plants. Setting sensible carbon pollution standards for all 
power plants is the right thing to do. 

Increasingly dangerous C02 levels. The level of C02 in the atmosphere now far 

exceeds the natural range from the previous 800,000 years, according to ice core 

records-' In the pre-industrial world, the atmospheric concentration of C02 averaged 

about 285 parts per million (ppm). At the time of the UN Earth Summit in 1992, 

atmospheric C02 was about 355 ppm. In Apri12012, the level reached 396 ppm. And 

April saw the 326th straight month with global temperatures above the 20th century 

average.' 

Economic consequences. Failing to take timely action to curb carbon pollution 

has serious economic consequences. 

1. Extreme weather events, including drought, hurricanes, like superstorm 

Sandy, and floods, are costing billions of dollars in damages in this country 

alone.' 

2. Climate change-related events such as heat waves, high levels of ozone 

pollution, and outbreaks of vector-borne diseases have already had a 

significant impact on health care costs5 

3. The longer we allow C02 concentrations to rise, the more drastic the 

eventual cuts in emissions -and the higher the associated costs -will 

be. 

4. In the absence of a coherent clean energy policy, the U.S. is falling behind in 

developing and bringing to market the emerging technologies that 

sustain economic growth-' 

Need for stronger standards. The EPA made an important first step by proposing a rule to 

cut carbon pollution from new sources, and now comes forward with a proposal to cut carbon 

pollution from existing sources. We applaud EPA for taking these steps and we strongly 

support these proposals. But we also encourage you to work with state stakeholders to be 

more aggressive when determining final actions to reduce this deadly form of pollution. The 

League would like to see a 35 percent reduction in carbon pollution by 2030. 

Reducing emissions from existing power plants is critical to addressing the growing 

danger that climate change poses to the health and welfare of U.S. citizens and people 

around the world, as acknowledged by both leading climate scientists and the EPA 

Because of the need for immediate action, we believe that the EPA should speed up its 

consideration of these vitally important rules, and certainly should allow no slippage in the 

current timetable or in the interim steps called for in the plan. 

In addition, the League believes that the EPA proposal should be strengthened by 

providing for greater use of renewable energy and energy efficiency in displacing carbon 

emissions from power plants. The state-by-state targets in the proposal are not based on 

policies already adopted by each state. Instead, the EPA approach underestimates the 

use of renewables and conservation and, for some states, assumes less use of 

renewables and conservation in 2030 than is already in place today or less than has 

already committed to by the state. 
. . . 

We urge you to more accurately estimate the potential for use of renewable energy and 

to strengthen the state-by-state targets accordingly. Similarly, energy conservation can 

realistically play a larger role in displacing carbon emissions and that should be 

recognized in the state estimates as well. 

Urgency. The American public supports the EPA when it comes to strong 

regulations that will protect the health and well-being of our children and our 

communities. The U.S. must take aggressive action to reduce greenhouse gas 

emissions from all sources, with emissions reduction targets of at least 35 percent 

below overall 2005 levels by 2030. Reaching these targets will require current power 

plants to dramatically reduce their carbon emissions, and the League of Women 

Voters urges the EPA to require those steps as quickly as possible. 

US Department of Energy at http //fossil energy qovlproaramslpowersystemslpolluttoncontrols/RetroftlllnQ Ex,sttr;g Plants html 

2 Htgh-reso/u/ton carbon dioxtde concentration record 650,000-800,000 years before present, Nature, May 2008, at 

http l/www.nature comlnatureljournallv4531n7193/abslnaturs06949 html 

http llco2now org/ 

4 

Nallonal Ocean.c and Atmosphenc Admtntslration at http_I/\\1\NW. noaanews noaa gov/stones2012120120119 _globat_stats.htmt 

Stx Climate Change-Related Events rn the Umted States Accounted tor About $14 

Btl/ion m Lost Lives and Health Costs. Ktm Knowlton et at, Health Affairs, November 

2011, at http 1/contenthealthaffairs org/content/3011112167 abstract 

6 

How to Power the lnnova/1on Lrfecyc/e_ Better Policres Can Carry New Energy Sources to Market. Center for Amer1can Progress, June 2010, at 

http.llwww amencanprogress org/1 ssues/20 1 0/06/innovatlon _t1f ecycle html