Hello, my name is Christopher Mayo, and I am a Legal Fellow at the 

Center For Biological Diversity. Here are some of our preliminary 

thoughts on the proposed rule and overall administration climate plan. 

The proposed rule is a significant step toward the mitigation of climate 

change, but is inadequate to address the immensity of the problem. 

This rule is neither stringent nor prompt enough to avoid the worst 

impacts of global climate disruption. Science has demonstrated that we 

must lower our economy-wide emissions to 50 percent below 1990 

levels by 2020, giving us a medium chance of keeping warming to two 

degrees Celsius. The 2030 goal of achieving reductions and the lenient 

State targets will fail to prevent climate change's worst effects. Green 

house gases build up over decades and centuries to create a strong 

cumulative effect. Waiting 15 years to achieve any meaningful 

reductions is unacceptable. 

Using 2005 emission levels as a baseline is a mistake for multiple 

reasons. First, the 2005 baseline will take credit for reductions that 

have already occurred, as emissions have declined since their height in 

2005. Second, the international community has agreed to use 1990 as 

the appropriate baseline, and we should follow suit. Scientists base the 

required reduction amounts on 19901evels, so it only makes since to 

use these levels as the baseline for reductions. 

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The proposed rule should more strongly encourage the reliance on 

renewable energy. Shifting away from fossil fuels is the only way to 

successfully mitigate climate change. While industry representatives 

say that such a shift is impossible, this is simply not the case. Green 

Peace has found that the U.S. could generate over 70 percent of its 

electricity from renewable energy by the year 2030. The EPA's target for 

the use of renewables is far below our capacity. Some states are already 

producing more renewable energy than EPA projects. This rule should 

encourage further growth of renewable energy, not maintain the status 

quo. Coal-dependent states should not get a free pass. The 

implementation of renewable energy in these states should be seen as a 

gateway to new industry, not a blockade to financial success. 

Increased use of natural gas power generation will not result in 40 

percent emissions reductions. Methane leakage can happen at any 

point in the supply line, and the leakage rate is higher than EPA uses in 

its formulas. Leaked methane is up to 100 times more harmful than 

carbon dioxide emissions. Increased use of natural gas would also 

mean an increase in fracking, further endangering the public. The 

technology-forcing requirements of the Clean Air Act should be 

enforced by requiring increases in efficiency at existing natural gas 

plants. 

Finally, generating power using biomass from trees should not be 

considered. This is a highly inefficient and carbon-intensive process 

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which will most likely increase atmospheric CO2 concentrations for 

decades and centuries to come. The assumption that biomass CO2 has 

no effect on the climate is scientifically indefensible and illogical, and 

neither states nor the EPA should use this assumption in their 

calculations. While biomass from trees may be, under stringent 

circumstances, renewable, most current industry practices are anything 

but clean or climate friendly. 

Thank you. 

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