Ensure Your Members & Supporters Are Represented
We are ensuring our nation's bedrock environmental laws are utilized to safeguard health. You can use the docket information below to send a letter from your organization, group, or business or you are welcome to join onto our organizational letter for each protection.
The EPA should strengthen multiple safeguards to improve the health of Wisconsinites.
Power Plant Carbon Safeguard
Deadline: August 8, 2023
Docket ID Number: EPA–HQ–OAR–2023–007
Submission Portal: https://www.regulations.gov/commenton/EPA-HQ-OAR-2023-0072-0001
Full Proposal Details: Federal Register
Please send any edits or questions to Laura Lane at firstname.lastname@example.org. Links will be full APA citations in the final letter submitted.
On behalf of our members and supporters, our (insert #) organizations urge the EPA to set the strongest possible safeguards on carbon pollution by early next year. While the agency’s current proposal is a good start, we ask the EPA to strengthen it in three ways: 1) require power plants to reduce their emissions more quickly, 2) apply the pollution safeguards to a wider number of gas plants, and 3) ensure communities have input on how the pollution safeguards are implemented at power plants.
The power sector is the second-largest contributor to overall climate pollution in the U.S., but currently, carbon emissions from existing fossil fuel power plants are unregulated. The strongest possible climate pollution safeguards on power plant emissions are essential to limit the climate crisis and protect Americans’ health and well-being.
Carbon pollution from the fossil-fuel industry drives climate change and leads to poor air quality and increasingly negative health outcomes, including respiratory disease, heart disease, and insect-borne infectious diseases. According to the National Institute of Environmental Health Sciences, poor air quality as a result of climate change can harm respiratory and cardiovascular systems. These health impacts include hypertension, coronary artery disease, heart attack, and stroke. Climate change creates more unhealthy smog, which is associated with diminished lung function, increased hospital admissions and emergency department visits for asthma, and increases in premature deaths.
Climate change also leads to more frequent and intense extreme weather events, including hurricanes, heat waves, wildfires, and flooding. In 2022, the U.S. experienced 18 storms that cost $1 billion or more. According to NOAA, the storms, droughts, and wildfires totaled more than $165 billion and led to at least 474 deaths. At one point in 2022, more than 60% of the continental United States was under official drought conditions.
In addition, cutting carbon pollution and limiting climate change is an issue of environmental justice and health equity. In 2021, the EPA released a peer-reviewed study that showed communities of color are expected to see more loss of life, health, and employment from climate change than the U.S. population as a whole. The report found that African Americans are 40% more likely to die from higher temperatures than the general population if climate change is kept to 2 degrees Celsius. Black children are 34% more likely to experience asthma exacerbated by climate change. Hispanic and Latin American, and Native Americans are 43% and 37% more likely to live in places where climate change threatens job opportunities.
By setting the strongest possible safeguards on carbon pollution from power plant emissions, the EPA can protect the health and well-being of all Americans, especially those who have historically been overburdened by pollution and may continue to live on the front lines of fossil fuel plants. There is no time to lose. The recent United Nations Intergovernmental Panel on Climate Change (IPCC) report made clear that the window to prevent the worst impacts of the climate crisis is rapidly closing. These safeguards must be finalized by early next year. Thank you for the opportunity to provide input.
American Academy of Pediatrics - Wisconsin Chapter
Valeria Hairston, MD
Cream City Medical Society
Senior Midwest Policy Manager
Green Neighbor Challenge
Abby Novinska-Lois, MPH, Executive Director
Joel Charles, MD, MPH, Board Chair
Healthy Climate Wisconsin
JONAH of Chippewa Valley
Director of Development
MEDiC Student-Run Free Clinics
Steven Goldstein, MD
New York Clinicians for Climate Action
Kaitlin Sundling, MD, PhD
Member and Medical Advisor
University of Wisconsin Workers' COVID Response Working Group
Add Your Organization
Dear Administrator Regan,
As organizations committed to ensuring Wisconsin addresses climate change and reduces pollution across every sector of our economy, we write to express our support for the Biden administration’s proposed rules that will slash carbon pollution from existing coal plants as well as both new and existing gas plants.
These proposed rules are a very promising signal of the Biden administration’s continued commitment to climate action, but they still must be strengthened to cover more power plants, expedite the timeline for complying with the emissions reductions standards, and conduct deeper outreach with communities – especially those near polluting power plants and disproportionately harmed by climate disruption.
To meet their climate and environmental justice commitments, the EPA can and must also take a holistic approach to addressing air, water, and climate pollution. They will need to carry out additional, critical rulemakings and strengthen current draft rules to bolster the administration’s economy-wide approach to tackling the climate crisis.
To complement the EPA’s critical power plant carbon standards, the agency must move quickly to strengthen and/ or implement the following rules:
National Smog Standard (no EPA action taken)
Closing Startup, Shutdown, and Malfunction Loopholes (more action needed)
Regional Haze Rule (more action needed)
Mercury and Air Toxics Standards (proposed, but needs to be strengthened)
National Soot Standard (proposed, but needs to be strengthened)
Effluent Limitation Guidelines (proposed, but needs to be strengthened)
These remaining rules are public health standards that, if strengthened, would force polluting industries to clean up their act and prevent tens of thousands of deaths and hundreds of thousands of illnesses each year from air and water pollution. Additionally, they will have the secondary benefit of cutting climate pollution and beginning to rectify decades of environmental injustice.
Keeping U.S. Climate Action on Track
To bridge the gap between current U.S. climate targets and our current trajectory, which is expected to fall at least 10% short of the necessary 2030 emissions reductions, and to advance President Biden's critical climate and environmental justice commitments, we strongly urge the EPA to take decisive action to reduce pollution and promote clean electricity in the power sector within the next two years. This should include:
Setting additional EPA pollution standards that reduce conventional air and water pollutants and improve public health: The EPA has long-standing legal authority to regulate sources of air, water, and other pollution under key environmental laws, including the Clean Air Act, the Clean Water Act, and the Resource Conservation and Recovery Act.
Implementing the Inflation Reduction Act (IRA) effectively, efficiently, and equitably: The IRA’s climate and clean energy provisions can bring down power sector carbon emissions to 66 percent below 2005 levels by 2030. But these reductions will only be realized if EPA implements the programs effectively and efficiently, with timely federal guidance on tax credits and grant programs and the distribution of funds in a way that maximizes carbon reductions and transitions to clean energy sources.
Wisconsin will Uniquely Benefit from Climate Action, Clean Energy Transition
Strong action from the EPA will allow Wisconsin to more successfully carry out Governor Evers’ Clean Energy Plan – an economy-wide strategy to cut emissions, create jobs, and improve health. Recent analysis shows that carrying out the state’s climate plan would create over 40,000 new jobs and boost new cleantech and energy investments in the state, which are promising industries that are already rapidly growing in Wisconsin.
As organizations representing tens of thousands of people across Wisconsin, we urge the EPA to move quickly to prevent more pollution from the power sector that disproportionately harms low-income, Black, and Brown communities. We must accelerate the cleanup of power sector pollution and ensure critical clean air and water standards are not left vulnerable to the Congressional Review Act. Our state will not achieve its climate goals without significantly and urgently cutting pollution from the power, transportation, and industrial sectors. As noted, the EPA has clear authority to do more to slash pollution through these rulemakings.
Thank you in advance for your consideration of our recommendations. We look forward to continuing to work with your agency on advancing bold climate action in our state and beyond.
Courtney Bourgoin, Senior Midwest Policy Manager
Abby Novinska-Lois, Executive Director
Healthy Climate Wisconsin
Add Your Organization