On November 7, LWVUS provided comments to an Environmental Protection Agency (EPA) Listening Session regarding the need to place regulations on carbon pollution from existing power plants. The EPA has been holding Listening Sessions across the country on this important issue and many state and local Leagues around the country have been participating in this important process.


November 7, 2013 

U.S. EPA Headquarters
William Jefferson Clinton East Room 1153
1201 Constitution Ave. NW
Washington, DC 20460 

Comments for EPA Public Listening Session on Reducing Carbon Pollution from Existing Power Plants

Support.  The League of Women Voters of the United States (LWVUS) strongly urges the EPA to limit carbon pollution from existing power plants to achieve at least a 20 percent reduction below 1990 levels by 2020. We believe that taking steps to reduce this dangerous greenhouse gas are essential to protect our children and future generations from the effects of climate change. We commend the EPA for holding this listening session, and others like it across the country, to allow public comment on proposing standards for existing power plants.

Importance.  Burning coal accounts for about half of the electricity generated in the U.S. and carbon pollution from U.S. power plants accounts for 40 percent of the CO2 emissions that contribute to climate change.1 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. We have a moral obligation to our children and future generations to address the cause of climate change beginning with CO2 emissions from existing power plants.

Need for extending standards to existing power plants. The EPA has made an important first step by proposing a rule to cut carbon pollution from new sources, but the EPA must now work to extend this standard to existing sources. Reducing emissions from existing power plants 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.  Because of the need for immediate action, we believe that the EPA should speed up its consideration of these vitally important rules, and certainly should allow no slippage in the current timetable.

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.2   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.3

Economic consequences.  Failing to take timely action to curb carbon pollution has serious economic consequences.

1.  Extreme weather events, including drought, hurricanes, like superstorm Sandy, and floods, are costing billions of dollars in damages in this country alone.4

2.  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.5

3.  The longer we allow CO2 concentrations to rise, the more drastic the eventual cuts in emissions — and the higher the associated costs — will be.

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.6

Urgency. The U.S. must take aggressive action to reduce greenhouse gas emissions from all sources, with emissions reduction targets of at least 20 percent below 1990 levels by 2020 and 80-100 percent below 1990 levels by 2050.  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.



1 U.S. Department of Energy, at http://fossil.energy.gov/programs/powersystems/pollutioncontrols/Retrofitting_Existing_Plan ts.html

2   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.

3 http://co2now.org/

4 National Oceanic and Atmospheric Administration, at http://www.noaanews.noaa.gov/stories2012/20120119_global_stats.html

5 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

6 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