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EPA’s Clean Power Plan Good for Our Air, Economy, and Resiliency

On July 31 and Aug. 1, the Environmental Protection Agency (EPA) held listening sessions in Pittsburgh. The officials took comments from the public on the EPA’s proposed Clean Power Plan, which will regulate carbon dioxide emissions from electrical generating units.

While the plan is not perfect, GASP supports it in essence. The proposal, when fully enacted by 2030, will prevent thousands of premature deaths and up to 150,000 asthma attacks in children per year, slow down global warming, lessen the cost of electricity, and make our nation a leader in the next generation of clean technology.

Learn more by visiting EPA’s web pages on the issue, and read our comments below. You can also submit your own comments, directly from EPA’s web site, but must do so by Oct. 16.

August 1, 2014

Via Electronic Submission

Re: Comments on Docket ID No. EPA-HQ-OAR-2013-0602

Dear Environmental Protection Agency:

The Group Against Smog and Pollution, also known as GASP, submits these comments in support of the Clean Power Plan. While the details of the plan are rather complicated, the big picture is simple to comprehend. Global warming threatens our nation, and CO2 causes much of the warming. The EPA has the authority and the mandate to regulate CO2, and this proposal does just that.

Many commenters have praised the reduction of CO2 and mitigating global warming, and we applaud the EPA for taking this strong step, by addressing emissions from our nation’s largest single source of CO2. This action will be a model to countries around the world and we should take pride in leading the fight. But as a nonprofit based in southwestern Pennsylvania that’s also fought for 45 years to reduce emissions that have short-term, or even immediately toxic effects, such as particulate matter, sulfur dioxide, nitrogen oxides, air toxics, and other pollutants, we are especially excited to see the co-benefits of reducing these pollutants that this rule will provide.

Pittsburgh is known for its smoky past. Many outsiders still have that image of the city. While Pittsburgh no longer turns on street lights at noon to see through the smoke, we do suffer from high levels of ozone and fine particulate matter. Perhaps “The Blue Ozone Haze City” or “The City With High Levels of Microscopic Particulates” just aren’t catchy enough to have become our new nickname. Our air quality slowly improves year after year, but so does our knowledge of the danger of these pollutants. GASP works to reduce emissions from our backyard air pollution sources, such as three nearby coke works (including the largest coke works in the nation), several steel mills, heavy diesel traffic, and many more. We also need relief from upwind sources. We are victims of emissions from power plants in Ohio, in Indiana, in Illinois, and beyond. This rule addresses the entire electricity-generating sector, nationwide, and thus reduces the ability for some to say “Why should we clean up when our neighbors aren’t?” And what do we get by enacting this plan? By 2030, there will be over 50 thousand less tons per year of fine particulates, and over 400 thousand tons per year less sulfur dioxide and nitrogen oxides. These reductions will prevent thousands of premature deaths, half a million missed school and work days, and up to 150 thousand in asthma attacks in children every year.

The plan is to be commended for its flexibility. States can use a variety of strategies to meet state-specific goals, and states can also choose to work with neighboring states to create regional plans, if that makes sense to them. The proposal is the result of over a year of direct engagement with stakeholders, and in many ways it’s just the next logical step along a path the states started long ago.

Forty-seven states already have demand-side energy efficiency programs. Almost 4 out of every 5 states utilize renewable energy portfolio standards or goals. This proposal builds on the tested, proven successes already achieved by many states. The proposal will save far more in health benefits than its estimated cost. The cost of doing nothing was calculated by the White House Council of Economic Advisers to be 19 times more per year. 19 times more. We cannot afford to wait any longer.

What other changes might we see by 2030, beyond much cleaner air and a more stable climate? More creative hydropower projects, like the several that already exist on legacy dams and reservoirs in the region (and the many more being considered). Solar panels on the top of every municipal water tower, county court house, and public works garage. More energy-efficient light bulbs being sold for $1 in thrift stores, like a local electric utility did here recently. More companies using electric power at night to reduce spikes in demand (and to save their company lots of money). Geothermal power projects like in the South Side Library, a 105-year old building that added the technology during a renovation. Vertical axis wind power turbines like the one at Phipps Conservatory, just a few miles from here, or on farms, or in small towns, delivering power to themselves and their neighbors. I see flexibility, efficiency, resiliency, and jobs. Homes, neighborhoods, towns, and cities that are smarter and stronger.

Thanks to the Green Building Alliance’s leadership, Pittsburgh is home to one of the nation’s few 2030 Districts. 2030 Districts are voluntary, collaborative efforts where building owners in urban cores agree to slash energy and water use and transportation emissions. We will see states create incentives for more 2030 Districts like Pittsburgh’s. Finally, we will see lots and lots of jobs. Pittsburgh has reinvented itself before and is now poised to take advantage of how this proposal will spur innovation in multiple sectors—from producing cleaner energy, to transmitting it, to using it more efficiently. New techniques and technologies will be needed, ensuring that our nation will be on the leading edge of this advance.

Long-term, this proposal will lessen the negative effects of climate change. Short-term, it will spur growth and innovation, secure our position as a leader in future technologies, and save lives.

Thank you for the opportunity to comment.

Jamin Bogi Policy and Outreach Coordinator Group Against Smog and Pollution 5135 Penn Avenue Pittsburgh, PA 15224

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