EPA letter 2015 re Clean Power Plan - Mayor -
Office of the Mayor
October 27, 2015
Gina McCarthy
EPA Administrator
Environmental Protection Agency 1200
Pennsylvania Avenue, N.W.
Washington, DC 20460
Re: Clean Power Plan Rule
Dear Administrator McCarthy:
We, the undersigned elected representatives of Southeast Florida, write to you to express our strong
support for the Clean Power Plan, the new Environmental Protection Agency ("EPA") rule restricting
power plant carbon dioxide emissions pursuant to § 111(d) of the Clean Air Act, 42 U.S.C. § 7411(d).
The rule is critical to the citizens of Florida. Any delay in implementing the rule poses a serious threat
to the health, safety, and welfare of our residents.
We believe the Clean Power Plan, which will reduce greenhouse emissions from fossil- fueled power
plants, will mitigate the harm that climate change is having on Florida's fragile environment. That
harm includes damaged coastal areas, disrupted ecosystems, more severe weather events, and longer
and more frequent droughts.
No other state is more vulnerable to climate change than Florida, surrounded on three sides by the
Gulf of Mexico and the Atlantic Ocean, crisscrossed by rivers and speckled with lakes. Southeast
Florida is particularly vulnerable to the predicted effects of climate change due to its extensive
coastline, flat landscape, porous geology, and burgeoning coastal development. In South Florida,
Miami-Dade, Broward, and Palm Beach counties collectively have populations approaching 6 million
residents. Millions of these residents live on or near the shoreline. Our safety depends on thousands
of miles of canals for drainage and flood control.
Re: Clean Power Plan Rule
Page 2 of 3
Extreme high tides have become increasingly frequent and dramatic due to rising sea levels, over-
topping seawalls, pushing up through storm water systems and contributing to flooding in
communities far from the waterfront and coastal canals. King tides earlier this year were more severe
and expansive than measured during any storm event in the last 20 years even though there was no
accompanying rain. Emergency evacuation routes were flooded and businesses closed their doors in
Broward County. Although South Miami is not on the coastline, we are experiencing higher levels of
flooding, presumably due to rising sea levels which translate into less ability for stormwater to drain
into bays and canals.
Extreme high tides are damaging property and infrastructure and hastening beach erosion which
effects all Floridians as hurricane insurance and ancillary costs from such storms rise as the result of
less buffering from the beach ecosystems being increasingly eroded. In November 2012, extreme
high tides in nearby Broward County, coupled with a persistent onshore wind, contributed to severe
sand loss and beach scouring, battering 2,300 feet of shoreline and causing four blocks of State Road
A1A, an emergency evacuation route, to collapse into the Atlantic Ocean. Temporary and permanent
reconstruction costs reportedly exceeded $10 million.
Regionally in South Florida, it has been estimated that $3 billion in property value is at risk with one
foot of sea level rise. A storm surge could magnify this figure significantly. Rising sea levels threaten
evacuation routes, energy infrastructure, and water and wastewater infrastructure. Fort Lauderdale, a
city of some 165,000 residents, recently estimated that upgrades to the City's storm water system
alone, would reach $1 billion to address rising sea levels. Our City is much smaller, 13,700 residents,
but the impact is similar, as rising sea levels prevent historical gravity flows of our stormwater system.
Rising seas are driving saltwater contamination into South Floridas wellfields. For
instance, models developed in collaboration with the U.S. Geological Survey (USGS) predict a loss
of 35 million gallons per day in water supply capacity by 2060 (40% of Broward’s coastal wellfield
capacity), due entirely to sea level rise which causes salt water intrusion into drinking water sources.
Pumps to necessary replace existing gravity water control structures within the regional flood control
system are estimated to each cost $50 million. Existing pump systems are also now inadequate.
Modeling performed by the USGS indicates that by 2060, increases in groundwater levels caused by
rising seas will require some existing pumps to run 24 hours a day to maintain flood control
elevations.
Clearly, the effects of climate change on South Florida communities will require massive investments
in clean energy and innovative engineering solutions in the coming decades. We believe that the EPA
rules are a significant step in protecting our communities and addressing the extremely serious
environmental and resulting economic challenges that we are facing.
Re: Clean Power Plan Rule
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We are aware that several states and industry groups have requested that EPA stay the Clean Power
Plan during the upcoming litigation, and that it is likely that parties to that litigation will make
similar requests in court. The harms our communities are currently facing (and will face in the future)
from climate change are real and increasing. We urge you to resist any attempts to stay the Clean
Power Plan, which could delay the necessary cuts in carbon dioxide emissions, which are directly
linked to global warming and thus, sea level rise. This Plan is a critical and necessary step in
addressing a very serious and growing problem in America and the World.
Sincerely,
Phillip K. Stoddard
Mayor