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.

~~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

~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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