Testimony submitted to: 

U.S. Environmental Protection Agency (EPA-HQ-OAR-2013-0602) 

In support of U.S. EPA's Clean Power Rule 

Submitted by David J. White, National Wildlife Federation 

July 29, 2014 

Thank you for this. opportunity to submit testimony in support of EPA's proposed Clean Power 

Rule. My name is pavid White, ansJ I am the Director of the Gulf of Mexico Restoration 

Campaign for the Na1ional Wildlife Federation. I live in St Petersburg, Florida, but my work 

covers the entire Gulf Coast. The goal of the Gulf Campaign is to ensure the recovery of fish and 

wildlife populations and the communities of the entire Gulf Coast following the BP Oil Spill 

disaster in April 2010. 

As devastating as the oil spill was, climate change and ocean acidification from carbon pollution 

are still the largest threats facing our coastal fish and wildlife resources, marine ecosystems, 

and coastal communities. If we fail to dramatically reduce carbon pollution, accelerating 

climate change and ocean acidification could eventually undermine all of our restoration 

efforts, waste literally tens of billions in restoration dollars, escalate degradation of important 

coastal ecosystems, and increase threats to entire coastal communities. 

About 10 million people live along the Gulf Coast. These communities face increasing challenges 

from annual natural disasters such as hurricanes and severe coastal flooding, and from longterm hazards such as storm-induced erosion, land subsidence and sea-level rise. In just the past 

10 years, eight of the costliest hurricanes in American history caused an estimated $225 billion 

in damages to Gulf States. Hurricanes Katrina and Rita in 2005 caused the loss of 217 square 

miles of Louisiana's coastal wetlands, destroying important nesting, wintering and foraging 

areas for countless birds, including ducks and other waterfowl, wading birds, and migrating 

songbirds. 

The estuaries and coastal systems of the Gulf Coast-such as the Mississippi River Delta, Mobile 

Bay, Galveston Bay, Tampa Bay, and the Mississippi Sound -provide critical nursery habitat for 

80-95% of the commercial and recreational fish species in the Gulf, and support nationally 

important oyster and shrimp industries. Many of these areas have been recognized as estuaries 

of national significance by EPA's National Estuary Program, and they are particularly vulnerable 

to climate change. 

From Florida to Texas, increasing erosion of coastal barrier islands undermines storm protection 

for coastal communities, degrades beaches that support the local tourism economy, and affects 

numerous species like Kemp's Ridley and loggerhead sea turtles. Just about all wildlife species 

that occur along the coast are at increasing risk from habitat loss from rising sea levels 

associated with climate change. While these coastal habitats might naturally move inland as 

sea levels rise, the current rate of increase is likely to be too fast for these natural processes to 

occur. Efforts to resist increasing coastal erosion by building sea walls and other "hard" 
infrastructure will prevent inland migration of coastal habitats and lead to even more loss of 

coastal wetlands. 

Coral reefs are among the most biologically important ecosystems in the Gulf, supporting high 

levels of biodiversity, and providing significant economic value through tourism and fishery 

habitat. Oyster and coral reefs in the Gulf provide many human services, including reducing 

shoreline erosion and storm surge, creating habitat for many other species, and improving 

water quality by filtering nutrients and sediments. 

These habitats have declined as a result of increased water temperature, and increasing ocean 

acidity from carbon pollution. Ocean surface waters have become 30% more acidic as they 

absorb large amounts of atmospheric carbon, adversely affecting shell-building organisms like 

corals, krill, oysters, clams, and crabs and threatening the entire marine food chain. 

Clearly, our changing climate is already altering the physical, chemical and biological 

characteristics of our oceans, coasts and adjacent watersheds. Increasing air and water 

temperatures, changing precipitation patterns, rising sea level, and ocean acidification will 

increasingly confound efforts to restore or sustain coastal ecosystems. Actions taken now to 

significantly reduce carbon pollution will reduce future impacts from storms and sea-level rise, 

significantly decreasing the expense of response and recovery. We owe it to future generations 

to make these necessary reductions in carbon pollution now. 

Thank you for this opportunity to express our strong support for EPA's historic action to combat 

climate change by setting limits on carbon pollution from existing power plants. 

David J. White, Esq. 

Director, Gulf of Mexico Restoration Campaign 

National Wildlife Federation 

1700 Fairway Avenue South, Suite 100 

St Petersburg, Fl 33712 

(727) 362-6345 (office) 

(727) 365-9794 (cell) 

whited@nwf.org