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Catherine Thomasson's Testimony at EPA Carbon Pollution Hearing

On the proposed “Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units”
Docket ID No. EPAHQ-OAR-2011-0660

Physicians for Social Responsibility
Catherine Thomasson, MD
Executive Director

I am submitting this testimony on behalf of the 40,000 members and e-activists of Physicians for Social Responsibility as the Executive Director.  I would like first to applaud the Environmental Protection Agency and the Administration for proposing the first federal rule to address the largest public health threat of this century, global warming.  PSR is also supportive of this action in response to the U.S Supreme Court’s decision identifying greenhouse gas pollution as a threat to our health and welfare. 

My comments outline the severe public health threats from global warming, some of which we are already seeing. Global warming will continue to speed up without regulations to control greenhouse gas emissions.  As electricity production via burning of fossil fuels is the leading source of greenhouse gas emissions it is appropriate for the EPA to propose this initial rule limiting carbon dioxide emissions from plants to be built in the future. 

PSR also recommends a target of 850 pounds of CO2 per megawatt‐hour (lb CO2/MWh gross) rather than 1000 pounds as there is technology that can support this target.

Temperature-related Heat waves will intensify in both duration and magnitude impacting most those incapable of cooling, the poor, the elderly, children and those with chronic diseases.[1] Humidity rises too with increase in temperature making it hard to compensate for the heat and its health impact greater. Heat waves capable of killing thousands, like the 2003 event in Western Europe, could come as often as every other year.[2]


Ozone--  Nitrous oxides react with volatile organic compounds in the presence of sunlight and heat to produces ground-level ozone (smog), which cause various respiratory problems.  The more heat the more ozone.  Ozone can cause asthma attacks, coughing, and wheezing and shortness of breath.  Some say it is like getting sunburn in the lungs. Children, senior citizens, and people with lung diseases are particularly vulnerable to the health effects of ozone. Breathing unhealthy levels of smog can even send healthy people to the hospital. In addition, studies in Los Angeles shows that exposures to ambient ozone resulted in adverse birth outcomes based on the findings of lower birth weight and intrauterine growth retardation in regions with high ozone.  These effects were worse when pregnant women were exposed more during the 2nd and 3rd trimester and correlate with higher ozone and carbon monoxide levels.[3]

To bring this close to home, 10 counties in Maryland already have high ozone days.  In 2006, the worst county, Prince Georges, had nearly 1 month (29 days) of high ozone levels followed by Harford (23 days) and Baltimore County (22 days). On these days we should be recommending that our children not play outdoors for long periods of time and children with asthma may have recommendations to stay home![4]

Pollen counts are on the rise as increasing carbon dioxide levels increases ragweed pollen production significantly and out of proportion to plant size providing yet another trigger for asthma attacks.[5] One out of nine children in America has asthma and increasing ozone and pollen will drive the number higher.[6]

Wildfires—Increase in wildfires is occurring in drought impacted locations in the west.  With further warming this will increase as the beetle infested forests are dying. This markedly increases particulates which has a major impact on rates of myocardial infarction, asthma and chronic lung disease.

Extreme Weather Events- James Hansen has statistically analyzed frequency of extreme weather events and has concluded that current weather outliers events are human induced.[7]  4 out of 5 Americans have been impacted in the last 10 years by an extreme weather event. More severe and prolonged hurricanes, more frequent tornadoes and heavy precipitation events are already occurring and will increase.[8]  Flooding, loss of housing, economic and job loss with resultant loss in health insurance markedly affects health.  Flooding causes risk of drowning, blunt trauma and infectious disease.  It also increases mold another significant source of allergens and thus asthma.  

Food insecurity and extreme weather- More frequent droughts along with increased evaporation of moisture from the ground requiring additional irrigation for crops or crop failure is strongly predicted.  In addition, increase in heavy rainfall and flooding will impact local food production will suffer.  Worldwide this will be true hence prices will rise.  Impacts on our low income vulnerable populations will occur and with worse nutrition, health especially fetal and child growth and development will suffer.

Groundwater- Groundwater sources of drinking water near coastal areas will become contaminated with saltwater with increasing storm surges and sea level rise.  Not only is there increase in salinity but also reduction in flushing of water as there is back up from the ocean.  This can increase concentrations of nitrates and other pollutants in groundwater.[9] Miami is already having trouble with flooding at high tide during a full moon even without a storm.[10]  In addition, there is further demand for groundwater for irrigation dropping the water table and increasing the concentration of contaminants in well water.

Snowmelt-Reduction in snowpack in the western United States and in many other regions of the world will markedly reduce the summer source of drinking water, river flows for in stream fish as well as water for irrigation and food crops.

Sea Level Rise— Estimates of 20-60 cm increases in the next century is projected but increase of 17 cm has already occurred in the last century.  This is already impacting coastal communities where 16 of the 23 largest cities in the world are located. Storm surge increases effect of sea level rise exponentially, increasing land erosion and threatening public health and civic infrastructure.[11]  Wave force and height are now documented to be increasing on the Pacific Coast increasing rates of injury and infrastructure damage.

Infectious Diseases

Vector-borne disease—Spread of arbovirus infections such as West Nile virus have increased with rising temperature especially warmer winters.[12]  There is already increase in global incidence of dengue fever, which is spreading in endemic proportions in Texas and the Florida Keys.[13] Schistosomiasis the most common parasitic disease worldwide, fascioliasis, alveolar echinococcosis, leishmaniasis, Lyme borreliosis, tick-borne encephalitis, and hantavirus infections are all projected to increase as a result of global climate change.[14],[15]  Increasing rates of malaria in higher latitudes and elevations due to warmer temperatures which increase the range are documented.  In addition, the mosquito vector hatches earlier, smaller and lives longer with warmer temperatures.

Water-borne disease--With rising ocean temperatures toxic algae blooms are increasing as well as increased risk of cholera, carried on temperature-sensitive marine copepods.


Physicians for Social Responsibility strongly endorses this rule to reduce the serious public health threat of global warming due to greenhouse gas emissions.

[1] Belmin J, Auffray JC, Berbezier C, et al. Level of dependency: a simple marker associated with mortality during the 2003 heat wave among French dependent elderly people living in the community or in institutions. Age Ageing. 2007;36(3):298-303.

[2] Kosatsky T. The 2003 European heat waves. Euro Surveill.2005;10(7):148-149.

[3] Salam, M, et al. “Birth Outcomes and Prenatal Exposure to Ozone, Carbon Monoxide and Particulate Matter: Results from the Children’s Health Study.” Environ Health Perspectives. 113, 2005: 1638-44.

[4] Robert Wood Johnson Foundation/University of Wisconsin Population project.  Accessed 2/12/12

[5] Ziska LH, Gebhard DE, Frenz DA, Faulkner S, Singer BD, Straka JG. Cities as harbingers of climate change: common ragweed, urbanization, and public health. J Allergy Clin Immunol. 2003;111(2):290-295.

[6] O’Neill MS, Ebi KL. Temperature extremes and health: impacts of climate variability and change in the United States. J Occup Environ Med.  009;51(1):13-25.

[7]  J. Hansen, M. Sato, R. Ruedy, Climate Variability and Climate Change: the New Climate Dice. Accessed 5/23/12

[8] Solomon S, Qin D, et al. Technical summary. In: Solomon S. Climate Change 2007: The Physical Science Basis: Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. New York, NY: Cambridge University Press; 2007.

[9] Wilson, Alicia, et al. Storm-driven Groundwater Flow in a Salt Marsh. Water Resources Research. 47, 2011.

[10] Leonard Berry, Phd. Impacts of Sea Level Rise on Florida’s Domestic Energy and Water Infrastructure. Testimony to US Senate Committee on Energy and Natural Resources. April 19, 2012.

[11] Anthony Janetos, Vulnerability of Energy Infrastructure to Sea-Level Rise and Climate Variabiity and Change”, Testimony to the Senate Energy and Natural Resources Committee. April 19,2012

[12] Weaver SC, Reisen WK. Present and future arboviral threats. Antiviral Res. 2010;85(2):328-345.

[13] Hales S, de Wet N, Maindonald J, Woodward A. Potential effect of population and climate changes on global distribution of dengue fever: an empirical model. Lancet. 2002;360(9336):830-834.

[14] Mas-Coma S, Valero MA, Bargues MD. Effects of climate change on animal and zoonotic helminthiases. Rev Sci Tech 2008; 27: 443–57.

[15] Gray JS, Dautel H, Estrada-Peña A, Kahl O, Lindgren E. Effects of climate change on ticks and tick-borne diseases in Europe. Interdiscip Perspect Infect Dis 2009; 2009: 593232.

Page Updated August 9, 2013