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PSR Comments to the EPA on Greenhouse Gases

Date:  February 5, 2014

Docket ID number: EPA-HQ-OAR-2013-0495

Re: Standards of Performance for Greenhouse Gas Emissions From New Stationary Sources: Electric Utility Generating Units

Submitted by: Physicians for Social Responsibility, 1111 14th St, NW, Suite 700
Washington, D.C., 20005


We submit the following comments on behalf of Physicians for Social Responsibility (PSR), a national non-profit 501 (c) (3) scientific and educational organization representing over 30,000 physicians, health care professionals, and concerned citizens in 24 chapters and 14 medical student chapters throughout the United States.
PSR was founded over 50 years ago by physicians who evaluated the evidence and concluded that nuclear war would be a catastrophe for which there would be no medical response and would threaten the very existence of civilization. Invoking a fundamental principle of medicine, notably prevention is the only option for conditions for which there is no treatment or cure, the founders saw that it was their professional responsibility to prevent nuclear war. This message spread from the U.S. to physician colleagues throughout the world who with PSR formed the International Physicians for Prevention of Nuclear War, which was awarded the 1985 Nobel Peace Prize as recognition of the importance of this preventive medical message.

We believe that global climate change is such a threat. Again, the evidence leads us to the conclusion that preventive steps are essential if we are to prevent this impending catastrophe.

We embrace the fundamental statement of the Intergovernmental Panel on Climate Change (IPCC) set forth in their Fifth Assessment Report, “Warming of the climate system is unequivocal ...” and that , “continued emissions of greenhouse gases will cause further warming and changes in all components of the climate system.”

Preventing climate change by minimizing the emission of greenhouse gases (GHGs) is necessary to prevent this catastrophe. This problem is illustrated clearly in several recent reports including the Fifth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC) and Turn Down the Heat: Why a 4° C Warmer World Must be Avoided.1, 2

Therefore, Physicians for Social Responsibility strongly supports the regulations proposed by the United States Environmental Protection Agency that will limit carbon dioxide emissions by new power plants as the Agency seeks to fulfill its mission to protect human health. We further recognize that the proposed regulations are but a small initial step in the right direction that will be inadequate in and of themselves.

General Comments

As a health-oriented organization, PSR will confine its comments to those aspects of the proposed rules that are most directly related to health. Thus, we will not comment on many of the technical aspects of the proposed rule that are outside of the scope of interest and expertise of our organization. We recognize that climate is an essential determinant of health, as defined by the World Health Organization (WHO) which states that “Health is a state of complete physical and mental and social well-being and not merely the absence of disease or infirmity.” Although climate change has serious implications for disease and infirmity, major disruptions in social systems will produce additional and substantial adverse effects included in the WHO’s definition of health.

PSR applauds EPA for making what we consider to be a long overdue step in the formidable task of regulating GHG emissions in the United States. We recognize the fact that this will be an arduous task and that the proposed rule(s) will inevitably face challenges that are legal, political, or emotional in origin. We urge the Agency to rely exclusively on the best scientific evidence available when it promulgates rules. Any other rationale would be unethical and ultimately not in the interest of Americans or indeed other citizens of the world. As we continue to lay claim to the title of the world’s most advanced nation from a scientific and technical perspective, we believe that we have an obligation to lead the way to a sustainable energy future by limiting GHG emissions.

A recent study reported that the average lifetime for atmospheric CO2 is between 30,000 and 35,000 years, and that between 17% and 33% of the CO2 in the air today will still be in the atmosphere 1,000 years from now.3 This extraordinarily long lifetime illustrates the importance of prompt action to curb carbon dioxide emissions. Therefore, PSR considers the proposed rule to be an initial step toward an energy future that does not rely on burning fossil fuels. From a pragmatic perspective, we recognize that fossil fuels will continue to be used in the short-term as energy sources, and that a proposed rule must be capable of withstanding the challenge that the proposed limits are arbitrary. The choice of emission limits that are equivalent to natural gas combined cycle electrical generating units (EGUs) currently in operation would appear to meet such a challenge, but are not ideal.
Here are some of the expected health effects of global warming that we must seek to avoid:

  • Heat-related deaths will increase due to heat stroke and indirectly from exacerbation of chronic respiratory and heart diseases.  Approximately 70,000 Europeans died during the 2003 heat wave due to direct heat effects.4
  • Heat, drought, and crop failure go together. Climate change has already had adverse effects on the yield of maize and wheat.5 In response to the 2013 US drought, food prices rose 10% in July, 2013. (
  • Progress toward the reductions in malaria, a focal point of the UN Millennium Development Goals, is threatened by the expanded range of the disease-bearing mosquito, due to climate change.  New data demonstrate increases in the prevalence of this disease, a leading worldwide cause of death among children less than age 5.6
  • Dengue, or “breakbone” fever, estimated to affect 390 million, will become much more common, with 5-6 billion at risk by 2085.7
  • Viral encephalitis, including West Nile disease, which reached new highs in the US in 2012, will increase in prevalence. (
  • Climate-related violence between groups and individuals is likely to increase.8
  • Flooding associated with sea level rise and intense storms is projected to result in the creation of increased numbers of climate refugees. (www.ipcc.chFourth Assessment)

Comments on specific aspects of the proposed rule

Carbon Capture and Storage technology

The new standards that would be required of EGUs that use coal as the energy source presume successful use of carbon capture and storage technology (CCS). We are not optimistic that carbon capture and storage (CCS) technology, required by the new standards, is safe and effective on a large scale. Among the problems posed by CCS is the underground injection of massive amounts of carbon dioxide, with the risk of leaks and earthquakes, as is occurring in Oklahoma.  Earthquakes from the injection process over time can actually break the reservoir seal and cause leakage.9

In addition, under this rule, new EGUs with CCS technology are allowed to “phase in” this technology over a seven year period.  This loophole should be abolished:  No new EGUs should be built until both the CCS technology and permanent storage capacity at that site are proven to be fail-proof.

PSR has major health-related concerns related to any plan that fosters the continued use of coal. Our concerns are reflected in great detail in the 2012 book titled The Silent Epidemic: Coal and the Hidden Threat to Health published by the peer-reviewed MIT Press.10   The following represents but a fraction of the health-related problems that would persist:

  • Epidemiological research has shown that residents of counties where coal is mined have worse health than residents of counties where mining is minimal.11
  • Rail transport of coal poses hazards to communities related to accidents, denial of access by first responders due to intersections blocked by trains, fugitive dust from coal trains and diesel exhaust emissions by locomotives.10     
  • Disposal of coal combustion waste, currently unregulated, contaminates water supplies and affects air quality. Dam failure is particularly worrisome.10  
  • Even the best pollution control devices still permit the emission of large amounts of fine particles along with oxides of sulfur and nitrogen. All of these have major adverse health effects and contribute to the four leading causes of death among Americans: heart disease, malignant neoplasms, respiratory disease, and stroke.10
  • Mercury emissions from coal combustion lead to widespread deposition of this neurotoxin, contaminating water and fish and eventually causing damage to brain development.
  • Coal processing and washing poses risks to water supplies, as demonstrated by recent chemical spills in West Virginia.

Rule concerning natural gas-burning EGU’s

EPA requests comments on the following proposed standards:

  • 1,000 lb CO2 /MWh for new stationary combustion turbines with heat input rating greater than 850 MMBtu/h.
  • An emission limit of 1,100 lb CO2 /MWh for new stationary combustion turbines with a heat input rating less than or equal to 850 MMBtu/h and for those units who sell less than one third of their electricity on the grid.

The new standards will provide further encouragement for utilities to burn natural gas. Although carbon dioxide emissions per Btu are lower with natural gas than coal and emission-related health effects are less, natural gas fueled EGUs are also problematic.

Plants burning natural gas should be held to the same standard of 1,000 pounds of CO2 per megawatt-hour (lb CO2/MWh-gross) for any sized EGU that is new.  There is no health reason to reduce standards on units producing less than 850 mmBtu/hr.  Again, the cost efficiency of investing in energy efficiency which will ultimately improve our overall emissions is far more economical than allowing plants smaller than 110 MW to comply with a looser carbon standard.  Likewise a newly built EGU that sells less than one third of its natural gas to the grid should still be held accountable to the standard of 1,000 lb CO2/MWh-gross.  

The increased use of natural gas is being driven by the market as the cost has dropped with the marked increase in use of hydraulic fracturing.  Any element that reduces the burning of natural gas should be pursued for the benefit of reducing numerous health impacts of climate change.

In addition, there are numerous threats to unregulated hydraulic fracturing. The following points illustrate some of our concerns about its use:

  • Hydraulic fracturing poses risks to water supplies.   
  • Methane leaks from natural gas wells and distribution networks release significant amounts of methane into the atmosphere.12-17 The current IPCC Fifth Assessment reports a global warming potential for methane that exceeds that of carbon dioxide by factors of 86 and 34 at 20 and 100 years after emission. Thus, the global warming effects of the natural gas industry are likely to be greater than those associated with burning coal to produce electricity.18 The latest study done in Colorado shows double the rate of methane release at the wellhead than is used in calculations to estimate the effect of fugitive gas on climate change
  • Hydraulic fracturing results in serious air pollution due to hydrocarbons and ozone in the well fields and surrounding areas.17

We are concerned by this increase in the reliance on burning natural gas that will follow implementation of the proposed rule. We believe strongly that the Agency should be more forceful in its regulations aimed at gas-fueled EGUs.

The basis for this position is derived from data in the most recent IPCC Assessment. In that report, the climatologists make extensive references to models of future climate scenarios based on work done by the National Oceanographic and Atmospheric Administration’s (NOAA) Geophysical Fluid Dynamics Laboratory. The modelers used four input functions they refer to as Representative Concentration Pathways (RCPs). Each RCP specifies the summed concentrations and effects of all greenhouse gases between the present and the year 2100 in terms of energy gain by the planet or radiative forcing (measured in Watts/m2). Carbon dioxide is the major driver of climate change in each case. Thus RCP2.6 is a concentration pathway that yields an added radiative forcing of 2.6 W/m2 in the year 2100. It is an optimistic scenario that includes a peak effect part way through the century with a subsequent reduction in greenhouse gases due to efforts to control emissions. Temperatures stabilize after that year. This is the pathway that predicts the smallest impact on the climate and thus health. RPC4.5 and RPC6.0 depict intermediate effects while RPC8.5 depicts a scenario that is close to a worst case with CO2 concentrations of about 950 parts per million, just over twice the present concentration, by 2100. At that time, the model predicts a temperature increase of about 5° C with no end in sight, and oceans that are 0.73 meters higher than they are now and rising at a rate that may be on the order of one half inch per year.

The RPC2.6 is the only scenario that clearly predicts avoiding an additional 4°C increase in global temperatures as urged by the World Bank. In order to achieve this outcome, aggressive prompt reductions in GHG emissions are required. Other RPC scenarios do not predict avoiding this temperature increase unless one postulates temperatures that are at the low end of the 90% confidence limit for these scenarios.

Given the fact that the proposed rule only applies to EGUs built in the future, leaving currently existing units to emit unregulated amounts of carbon dioxide, PSR is convinced that the lowest emission standards proposed by the Agency, discussed above, will not provide adequate protection from climate-related adverse health effects.

Therefore, Physicians for Social Responsibility regards the proposed rule as a minimal step in the right direction. We urge the Agency to speedily move to regulate GHG emissions from existing sources, including EGUs and those related to the natural gas industry. In addition, we support future rule-making that would further reduce GHG emissions by EGUs built in compliance with the proposed rule.

On behalf of Physicians for Social Responsibility,

Alan H. Lockwood, MD, FAAN, FANA, Senior Scientist, PSR and Emeritus Professor of Neurology, University at Buffalo
Robert Gould, MD, President, PSR
Catherine Thomasson, MD, Executive Director, PSR

Reference List

1. Stocker T, Dahe Q, Plattner G-K, et al. Working Group I Contribution to the Fifth Assessment Report Climate Change 2013: The Physical Science Basis. Geneva, Switzerland: IPCC, 2013
2. Potsdam Institute for Climate Impact Research and Climate Analytics. Turn Down the Heat: Why a 4º C Warmer World Must be Avoided. Washington, DC: International Bank for Reconstruction and Development/The World Bank, 2012
3. Archer D. Fate of fossil fuel CO2 in geologic time. J Geophys Res 2005;110:C09S05.
4. Robine JM, Cheung SL, le RS et al. Death toll exceeded 70,000 in Europe during the summer of 2003. C R Biol 2008;331(2):171-178.
5. Lobell DB, Schlenker W, Costa-Roberts J. Climate Trends and Global Crop Production Since 1980, E-published ahead of print. Science 2011.
6. Murray CJ, Rosenfeld LC, Lim SS et al. Global malaria mortality between 1980 and 2010: a systematic analysis. Lancet 2012;379(9814):413-431.
7. Hales S, de WN, 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.
8. Hsiang SM, Burke M, Miguel E. Quantifying the influence of climate on human conflict    Science 2013;341(6151):1235367.
9. Mark D. Zoback and Steven M. Gorelick. Earthquake triggering and large-scale geologic storage of carbon dioxide PNAS 2012 ; published ahead of print June 18, 2012, doi:10.1073/pnas.1202473109
10. Lockwood AH. The Silent Epidemic: Coal and the Hidden Threat to Health. Cambridge, MA: The MIT Press; 2012.
11. Hendryx M, Ahern MM. Relations between health indicators and residential proximity to coal mining in West Virginia. Am J Public Health 2008;98(4):669-671.
12. Jackson RB, Down A, Phillips NG et al. Natural Gas Pipeline Leaks Across Washington, DC. Environmental Science and Technology 2014.
13. Miller SM, Wofsy SC, Michalak AM et al. Anthropogenic emissions of methane in the United States. Proc Natl Acad Sci U S A 2013;110(50):20018-20022.
14. Mays KL, Shepson PB, Stirm BH, Karion A, Sweeney C, Gurney KR. Aircraft-based measurements of the carbon footprint of Indianapolis. Environ Sci Technol 2009;43(20):7816-7823.
15. Hsu Y-K, VanCuren T, Park S et al. Methane emissions inventory verification in southern California. Atmospheric Environment 2010;44:1-7.
16. Phillips NG, Ackley R, Crosson ER et al. Mapping urban pipeline leaks: methane leaks across Boston. Environ Pollut 2013;173:1-4.
17. Karion A, Sweeney C, Pétron G et al. Methane emissions estimate from airborne measurements over a western United States natural gas field. Geophysical Research Letters 2013;40(16):4393-4397.
18. Howarth RW, Ingraffea A. Should Fracking Stop? Nature 2011;477:271-273.

Page Updated February 6, 2014