League Comments on Proposed Repeal of EPA's Clean Power Plan

January 10, 2018

U.S. EPA Headquarters
1201 Constitution Ave. NW
Washington, DC 20460
Docket ID: EPA-HQ-OAR-2017-0355-0002

Comments for EPA Public Hearing on Repealing the Clean Power Plan

Opposition to Repeal. The League of Women Voters of the United States strongly supports the Clean Power Plan previously finalized by the Environmental Protection Agency (EPA). We believe that taking steps to repeal this life-saving measure to protect our children and future generations from the effects of climate change is misguided. While we commend the EPA for holding this public hearing, to allow public comment on the plans for the regulation moving forward, we reject the premise set by the EPA that the regulations were an overreach of powers. If anything, the EPA should be working to strengthen and more realistically recognize the role that greenhouse gasses play in climate change and reduce their impact on our environment and public health.

Importance of Clean Power Plan. Burning coal accounts for about half of the electricity generated in the U.S. and carbon pollution from U.S. power plants account for 40 percent of the CO2 emissions that contribute to climate change.^[i] Carbon pollution that causes climate change is responsible for increased air pollution that can cause thousands of deaths 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 of Americans live in counties that have unhealthy levels of dirty air. Dirty air, exacerbated by the 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 of missed 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 of those around us. We have a moral obligation to our children and future generations to address the cause of climate change by cutting CO2 emissions from existing power plants. Setting sensible carbon pollution standards for all power plants is the right thing to do.
 

Increasingly dangerous CO2 levels. The level of CO2 in the atmosphere now far exceeds the natural range from the previous 800,000 years, according to ice core records.^[ii] In the pre-industrial world, the atmospheric concentration of CO2 averaged about 285 parts per million (ppm). At the time of the UN Earth Summit in 1992, atmospheric CO2 was about 355 ppm. In April 2012, the level reached 396 ppm. And April saw the 326th straight month with global temperatures above the 20th century average.^[iii]

Economic consequences. The United States can have a healthy economy and a healthy environment. Choosing to roll back actions to curb carbon pollution will have serious economic consequences.

1. The longer this administration ignores the crippling effects of climate change the more devastating the impact will be on our economy as we recover from extreme weather events that cost us billions of dollars.^[iv]
2. Extreme weather events, including drought, hurricanes, and floods, cost the United States $53 billion in economic damages in 2016.^[v]
3. Climate change-related events such as heat waves, high levels of ozone pollution, and outbreaks of vector-borne diseases have already had a significant impact on health care costs.^[vi]
4. In the absence of a coherent clean energy policy, the U.S. is falling behind in
   developing and bringing to market the emerging technologies that sustain economic growth.^[vii]

Need for stronger standards. The Clean Power Plan is a monumental step forward for the protection of public health. Repealing the regulation means more sick kids, more expensive hospital visits and thousands of premature deaths that could be prevented. The EPA estimated that the Clean Power Plan will prevent 90,000 asthma attacks and 300,000 missed work and school days by 2030. And the Trump Administration estimated that the CPP will prevent 4,500 premature deaths every year by 2030. Overall, the Clean Power Plan will provide health and climate benefits of up to $54 billion by cutting other pollution from power plants that trigger asthma attacks and worsen respiratory illnesses.

The Clean Power Plan will also accelerate the transition to a clean energy economy which is already underway. We should be striving to place displaced coal industry workers into markets that are growing, not declining. These workers have helped to keep the power on in this country and their contributions should not be understated. However, coal jobs have been on the decline over the last three decades because of the move to natural gas energy sources. Jobs within the clean energy industry have seen rapid growth with solar and wind jobs growing at a rate of 12 times faster than the rest of the U.S. economy.^[viii] We can, and should, develop sound policies that address the economic challenges in America’s coal country and simultaneously protect the health and safety of all Americans. We owe that to our coal miners and their families.

States, cities, and businesses across the country are moving forward with clean energy solutions that reduce air and carbon pollution and grow the clean energy economy, creating good-paying American jobs. They understand the economic, environmental and health benefits of clean energy solutions and acutely understand the risks associated with dirty energy sources.

Continuing to support the Clean Power Plan instead of repealing it is critical to addressing the growing danger that 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.

Urgency. The American public supports the EPA when it comes to strong regulations that will protect the health and well-being of our children and our communities. The American public does not support the repeal of this life-saving regulation. The U.S. must take aggressive action to reduce greenhouse gas emissions from all sources, with emissions reduction targets of at least 35 percent below overall 2005 levels by 2030. Reaching these targets will require current power plants to dramatically reduce their carbon emissions, and the League of Women Voters urges the EPA to require those steps as quickly as possible.

The Clean Power Plan is the biggest and most ambitious action the U.S. has ever taken to tackle climate change and it should not be repealed.

_{[i] U.S. Department of Energy, at http://fossil.energy.gov/programs/powersystems/pollutioncontrols/Retrofitting_Existing_Plan ts.html}

_{[ii] High-resolution carbon dioxide concentration record 650,000-800,000 years before present, Nature, May 2008, at http://www.nature.com/nature/journal/v453/n7193/abs/nature06949.html.}

_{[iii] http://co2now.org/}

_{[iv] https://news.nationalgeographic.com/2017/09/climate-change-costs-us-economy-billions-report/}

_{[v] https://www.americanprogress.org/issues/green/news/2017/01/19/296860/u-s-communities-clobbered-by-53-billion-in-extreme-weather-and-climate-disasters-in-2016/}

_{[vi] Six Climate Change-Related Events in the United States Accounted for About $14 Billion in Lost Lives and Health Costs, Kim Knowlton et al, Health Affairs, November 2011, at http://content.healthaffairs.org/content/30/11/2167.abstract}

_{[vii] How to Power the Innovation Lifecycle: Better Policies Can Carry New Energy Sources to Market, Center for American Progress, June 2010, at http://www.americanprogress.org/issues/2010/06/innovation_lifecycle.html}

_{[ http://www.businessinsider.com/solar-energy-job-growth-2017-1viii]}