January 13, 2018


Mr. Scott Pruitt, Secretary

Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460


RE: Docket ID No. EPA–HQ–OAR–2017–0355


Dear Secretary Pruitt:


Climate Action RI is a grassroots organization composed of citizens concerned about the declining quality of the environment at local, regional, national, and international levels. We are a local affiliate of 350.org. We write to express our alarm at the proposal to repeal the Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (hereafter referred to as the Clean Power Plan or CPP). We oppose the repeal for a number of reasons.


Repeal of the Clean Power Plan will add to the already high level of CO2 in the atmosphere. Three years ago, in 2014, the concentration of CO2 exceeded 400 parts per million, a dangerously high level.  For a comprehensive consideration of the damage this is likely to produce, the IPCC has prepared a summary of its Fifth Assessment Report for policymakers. This report and the overwhelming consensus of the scientific community affirm that the use of fossil fuels, including in the generation of electrical energy, are the largest contributor to this problem. Recently, Emmanuel Macron, President of France, stated that the world is losing the battle against climate change. It is urgent that we reduce our production of greenhouse gas emissions, which do “endanger public health, now and in the future,” as the CPP states. The generation of energy with renewable sources is a key component in doing so.


Removing limits on carbon emissions will increase already high rates of respiratory diseases (e.g., asthma and bronchitis) caused by particulate matter in the air. Combustion of fossil fuels releases small particulates, and these irritate lungs and contribute to cardiovascular disease: [RI DEM]. (Climate change is also projected to increase rates of asthma: see for example this model from a study of the New York metropolitan regionThe CDC notes that asthma rates are rising every year and that asthma “cost the US about $56 billion in medical costs, lost school and work days, and early deaths in 2017.” [https://www.cdc.gov/vitalsigns/asthma/index.html]

Fossil fuels damage the environment at every stage of their development, extraction, transportation, and use. Fracking has been linked to a rise in the incidence of earthquakes in Canada [Science]. The disposal of wastewater from fracking and oil drilling has links to an increase in earthquakes in Oklahoma and elsewhere [USGS]. Fracking has also been linked to contamination in groundwater, including sources of drinking water [link]. The Keystone Pipeline leaked 210,000 gallons in South Dakota in November 2017 [NY Times report]. Removing regulations on fossil fuels removes an obstacle to their use, and the more they are used, the more damage they do.

Renewable sources of energy are limitless, and the technologies that allow us to take advantage of them become more affordable each year. Fossil fuels, in contrast, have a finite supply. The more we use, the more we hasten the time when there will be no more and we will have to turn to renewables in any case. A managed transition to a future that we know is coming makes economic sense as well as humane sense.

Hitherto, US energy industries have focused on short-term gains for their shareholders. But it is not the government’s responsibility to cater to the shareholders of energy companies. Rather, it is the responsibility of the United States government to serve all the people of the United States. The repeal of the Clean Power Plan threatens the short-, medium- and long-term health and safety of the people of the United States. It also ties the nation to an energy economy with a time limit. Lastly, it hastens the expensive, far-reaching and lethal crises that will result from climate change. It is essential that the Clean Power Plan remain in place.



Members of Climate Action Rhode Island/350 RI

Executive Board:

Christine Rayner, President

Justin Boyan, Vice President

Terry Bontrager, Secretary

Kendra Anderson, Treasurer