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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 ofWomen Voters ofthe United States strongly supportsthe 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 generationsfrom the effects of climate change. We commend the EPAfor 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 ofthe electricity generated in the U.S. and carbon pollution from U.S. power plants accounts for 40 percent ofthe C02 emissions that contribute to climate change.' Carbon pollution that causes climate change is responsible for increased air pollution that can cause thousands ofdeaths 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 ofAmericans live in counties that have unhealthy levels ofdirty air. Dirtyair, exacerbated bythe 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 ofmissed 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 ofthose around us. We have a moral obligation to our children and future generationsto address the cause ofclimate change by cutting C02 emissions from existing power plants. Setting sensible carbon pollution standardsfor allpower plants is the right thing to do. Increasingly dangerous C02 levels. The level of C02 in the atmosphere nowfar 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 about285 parts permillion (ppm). Atthe time ofthe 

### UN Earth Summit in 1992, atmospheric C02 was about 355 ppm. In Apri12012, the level reached 396 ppm. And April sawthe 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 weatherevents, including drought, hurricanes, like superstorm Sandy, and floods, are costing billions ofdollars in damages in this country alone.' 2. Climate change-related events such as heatwaves, high levels ofozone pollution, and outbreaks ofvector-borne diseases have alreadyhad a significant impact on health care costs5 3. The longerwe allow C02 concentrations to rise, the more drasticthe eventual cuts in emissions -and the higherthe associated costs -will be. 4. In the absence ofacoherent clean energy policy, the U.S. is falling behind in developing and bringing to marketthe emerging technologies that sustain economic growth-'
Need forstrongerstandards. The EPA made an importantfirst step by proposing a rule to cutcarbon pollutionfrom newsources, and now comes forward with a proposalto cutcarbon pollution from existing sources. We applaud EPAfortakingthese steps and we strongly supportthese proposals. Butwe also encourageyou toworkwith state stakeholdersto be more aggressivewhen determining final actions to reduce this deadlyform ofpollution. The League would like to see a35 percent reduction in carbon pollution by 2030. Reducing emissionsfrom existing power plants is critical to addressing the growing dangerthat 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 ofthe need for immediate action, we believe thatthe EPA should speed up its consideration ofthesevitally important rules, and certainly should allow no slippage in the currenttimetable or in the interim steps called for in the plan.
In addition, the League believes that the EPAproposal should be strengthened by providing for greater use of renewable energy and energy efficiency in displacing carbon emissions from power plants. The state-by-statetargets in the proposal are not based on policies already adopted by each state. Instead, the EPA approach underestimates the use ofrenewables and conservation and, forsome states, assumes less use of renewables and conservation in 2030 than is already in place today or less than has alreadycommitted to by the state.

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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 ofour children and our communities. The U.S. must take aggressive action to reduce greenhouse gas emissions from all sources, with emissions reduction targets ofat least 35 percent belowoverall 2005 levels by 2030. Reaching these targets will require current power plants to dramatically reduce their carbon emissions, and the League ofWomen Voters urges the EPAto 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 record650,000-800,000years beforepresent, Nature, May 2008, at httpl/www.nature comlnatureljournallv4531n7193/abslnaturs06949 html

http llco2noworg/
4 Nallonal Ocean.c and AtmosphencAdmtntslration at http_I/\\1\NW.noaanews noaa gov/stones2012120120119_globat_stats.htmt

Stx Climate Change-RelatedEvents rn the Umted StatesAccounted torAbout$14 Btl/ion m LostLives andHealth Costs. Ktm Knowlton et at, Health Affairs, November 2011, at http 1/contenthealthaffairsorg/content/3011112167 abstract 6 Howto Powerthe lnnova/1on Lrfecyc/e_ BetterPolicres Can Carry NewEnergy Sources to Market. Centerfor Amer1can Progress, June 2010, at http.llwwwamencanprogress org/1ssues/2010/06/innovatlon _t1fecycle html