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NRDC Comments filed on the Carbon Pollution Standard
on Monday, June 25, 2012.

Power plants are the nation's largest source of the dangerous carbon pollution that drives global warming. In response to lawsuits from NRDC and others, EPA proposed Carbon Pollution Standards for New Power Plants on April 13, 2012. Here are NRDC's comments on the proposed standards, filed on June 25, 2012:

In these comments, NRDC and other groups (Sierra Club, Environmental Defense Fund, Earthjustice, National Wildlife Federation, and Environmental Law and Policy Center) explain why the Clean Air Act requires EPA to limit carbon pollution and how EPA's proposal goes a long way to fulfilling that obligation for new power plants. We explain how EPA can make the standards more robust and more effective, and why EPA needs to move forward to curb the carbon pollution from existing power plants too.

This second set of comments, filed jointly with Sierra Club and Earthjustice, explains how to calculate the economic benefits of reducing carbon pollution. For too long, industry has gotten away with polluting the climate for free. In these comments, we elaborate on the Social Cost of Carbon, a method to estimate the full set of costs that carbon pollution imposes on society (from heat waves and new diseases to fiercer storms and extreme weather).

In the third set of comments, we offer suggestions to make Carbon Capture and Storage (CCS) an effective, long-term technology for reducing carbon emissions. We believe that EPA needs to make sure captured carbon will be safely stored permanently, and will not leak back into our air or water later.

The final document is a shorter, non-technical expression of the urgency of cutting carbon pollution, signed by more than thirty national and regional groups, including NRDC.

These formal comments are supplemented by comments from more than 2.25 million Americans -- a record number -- who have raised their voices to support EPA and demand action to curb the carbon pollution from both new and existing power plants.

last revised 6/27/2012

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