EPA Docket Center (Air Docket) 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue 

Washington, D.C. 20460 

RE: Docket ID No. EPA-HQ-OAR-2011-0660; FRL-9668-9 

May 24, 2011 

Good Afternoon, my name is Pamela M. Ortner, MS, RN; I am the Michigan 

Environmental Health Nurse Advocate for Health Care Without Harm. Health Care 

Without Harm is an international coalition of more than 430 organizations in 52 countries, 

working to transform the health care sector worldwide, without compromising patient 

safety or care, so that it is ecologically sustainable and no longer a source of harm to 

public health and the environment. I appreciate this opportunity to comment on the 

proposed carbon pollution standard that would limit carbon pollution from new power 

plants. HCWH supports the Environmental Protection Agency's efforts to protect the 

public's health through the implementation of this rule. 

This first-ever national industrial carbon pollution standard for new power plants is 

essential to protect public health. By advancing several clean air safeguards that address 

carbon, mercury, soot, smog and other toxic pollutants, the EPA is holding big polluters 

accountable and protecting our kids and families from deadly, dangerous air pollution. 

As of today, more than I Million comments have been generated in support of the EPA 

Carbon Rule, a historic number; health providers and advocates, community members, 

environmental advocates and industry leaders have added their voice of support to this 

rule. I have brought over 300 cards supporting the rule from nurses and community 

members from Michigan that I have collected. 

Carbon pollution is most dangerous for children and the most vulnerable of our 

population. Rising temperatures are likely to increase smog pollution, which will be a 

trigger for asthma attacks and can cause permanent damage to and reduce to the function 

of a child's lungs. Asthma is a chronic, often debilitating condition that has no cure. 

During an asthma episode, the airways become constricted and swollen, the chest feels 

RE: Docket ID No. EPA-HQ-OAR-2011-0660; FRL-9668-9, Pamela Ortner, MS, RN I 
tight and it is difficult to breathe. Data from the Centers for Disease Control and 

Prevention and from the American Lung Association detail the prevalence and costs of 

asthma in the United States. In 2008, more than 688,000 children had to go to the 

emergency room because of asthma. The total estimated incremental direct cost of 

asthma in the United States is more than $53 billion a year. We carmot forget the personal 

cost. As a nurse for over 35 years, I will never forget the face of a child with asthma 

gasping for air. The economic impact does not end with medical costs. Parents, most 

often mothers, must find a way to stay home with their child who is ill which can be a 

financial hardship, but if the home does not have air conditioning, the child will still be 

exposed to unhealthy air. According to the Centers for Disease Control and Prevention, 

asthma episodes keep children out of school (about l 0.5 million lost school days in 2008) 

and takes adults out of the workplace (accounting for more than 14 million lost work 

days in 2008). An estimated 7 million children and over 17 million adults in the United 

States have asthma. As you know, my state of Michigan, as in many other states is 

suffering My state of Michigan home to more than 225,000 children and more than 

744,000 adults with asthma. The estimated incremental direct cost of asthma in Michigan 

to children and adults is almost $2 billion. Children, however are not the only ones 

negatively impacted. Exposure to carbon dioxide increases the likelihood that seniors 

with health problems would be hospitalized. The elderly, those most likely to have heart 

and lung ailments, those who already have diminished lung capacity and those who are 

poor and live in more highly polluted areas will be disproportionately affected. 

There is little scientific debate about the harmful effects of climate change. The proposed 

rule will save lives, protect the health of millions and bring about an action that is long 

overdue. We can and must act to ensure we protect the most vulnerable among us. 

Thank you. 

Pamela Ortner, MS, RN 

Health Care Without Harm 

Michigan Environmental Health Nurse Advocate 

RE: Docket ID No. EPA-HQ-OAR-2011-0660; FRL-9668-9, Pamela Ortner, MS, RN 2