Today I will give this testimony on behalf of the Natural Resources Defense Council at the Environmental Protection Agency’s public hearing in Washington on its proposed carbon pollution standard for new electric power plants. This is the first national limit on carbon dioxide emissions from new fossil fuel-fired electric generating units.
Already, more than 1 million citizens across this country – a record number in EPA’s history – have raised their voices in comments to support action to curb the dangerous carbon pollution from our fleet of power plants. Hundreds of supporters are travelling to the public hearings in Washington and Chicago today to make their views known in person.
Scientists tell us that carbon pollution imposes staggering health costs. Carbon pollution contributes to more severe heat waves and worsens smog pollution, which trigger more asthma attacks and other life-threatening illnesses. Carbon pollution contributes to increasingly extreme weather, including more devastating storms and floods, rising sea levels, and many other threats to life, limb, and property.
Case studies of six extreme weather events over the last decade – heat waves, wildfires, floods, smog episodes, hurricanes, and disease outbreaks – demonstrated health costs of more than $14 billion. A new study by the Rocky Mountain Climate Organization and NRDC shows that the number of extreme rainstorms – storms dumping more than three inches of rain in a day – has doubled over the last 50 years in eight Midwestern states, causing huge flooding losses. And more than 150,000 Americans could die early between now and the end of the century in heat waves intensified by climate change, according to a new analysis NRDC released yesterday.
The Supreme Court has found in two landmark cases, Massachusetts v. EPA and American Electric Power v. Connecticut, that it is EPA’s job under the Clean Air Act to protect the American people from dangerous carbon pollution, including the carbon pollution from the nation’s fleet of new and existing power plants. EPA's “new source performance standard” for new power plants under Section 111(b) is a critical step towards providing that protection.
Power plants have long topped the list of categories of industrial stationary sources that contribute significantly to air pollution that endangers public health and welfare. The Supreme Court held in Massachusetts that greenhouse gases are air pollutants subject to the Clean Air Act, and that EPA must set standards to limit their emissions if it makes a science-based determination that these pollutants may reasonably be anticipated to endanger public health or welfare.
EPA made that endangerment finding in 2009, because a mountain of scientific evidence demonstrates that carbon dioxide and other heat-trapping pollutants are already harming, and will continue to harm, the health and well-being of our families, our children, and our communities. Fossil fuel-fired power plants emit more than 2.3 billion metric tons per year of CO2, approximately 40 percent of total U.S. CO2 pollution, and more than a third of all U.S. greenhouse gases. By any standard, power plants contribute significantly to dangerous carbon pollution. (You can go to this nifty website check the carbon pollution from the power plants in your backyard.)
I’m going to tell the EPA hearing panel that NRDC supports EPA’s determination to set a single standard for both natural gas-fired generating units and coal-fired generating units. We agree, as EPA has found, that the same standard should apply neutrally to all power plants that perform the same function – here described as base-load and intermediate-load power generation – and that prospective power plant owners and operators have the flexibility to choose among all these technologies when building new plants.
I’ll express our support for setting a single emissions-rate standard applicable to all new plants in this category. EPA has proposed to set the standard at 1000 pounds per megawatt-hour (lbs/MWh) and asked for comment on a range of levels higher or lower. NRDC supports setting the new source standard below 1000 lbs/MWh because modern natural gas combined cycle plants can meet a tighter level at no additional cost. New coal-fired plants equipped with carbon capture and storage technology (CCS) can also meet a tighter level, especially if they use the 30-year averaging provisions that EPA has proposed for them.
Some politicians and industry spokesmen claim EPA’s proposed standard is a “de facto ban” on constructing new conventional coal-fired plants. They are running ads claiming the standard will kill jobs and raise utility bills.
But these are phony arguments. The proposed new source standard actually will impose no additional costs on the industry or on electricity rate-payers and will have no adverse impact on jobs. The reason is that market realities have already driven private sector decisions on new power plants away from coal.
As Brookings senior economist Peter Wilcoxen explained in April: “To put it simply: the life-cycle costs of coal-fired power are considerably higher than gas-fired power. This is not a theoretical matter: over the last decade, the electric power sector has responded by adding more than about 200 gigawatts of gas-fired capacity and about 2 gigawatts of coal. The US now has considerably more gas-fired capacity than coal-fired capacity and low gas prices will accelerate that trend even without the EPA decision.” He continued: “Finally, because it only rules out an expensive option that wouldn’t have been used anyway, the EPA rule will have no significant effect on electricity prices.”
Analysts from government departments, the power industry, and the financial world all agree in forecasting that the nation will meet its electricity needs over the next two decades without constructing new coal-fired plants. Power companies simply aren’t planning to build new coal plants due to the availability of low-cost natural gas, strong growth in wind and solar power, big opportunities to improve energy efficiency, and even the potential for nuclear power. For example, the country’s largest current CO2 emitter, American Electric Power, told the National Journal that the proposed rule “doesn’t cause immediate concern” for the company. “We don’t have any plans to build new coal plants,” said AEP spokesperson Melissa McHenry in March. She continued, “Any additional generational plants we’d build for the next generation will be natural gas.”
These market forecasts are robust. EPA’s sensitivity analyses in its Regulatory Impact Analysis show that power companies will not choose to construct any new conventional coal-fired plants before 2030 even if natural gas becomes 4-5 times more costly than it is today and power demand increases faster than expected.
The proposed new source standard reinforces what most power company executives and investors already understand – that carbon pollution and climate change are serious concerns, and that if and when underlying market economics support a comeback for new coal-fired power plants, they will need to be designed with CCS technology.
NRDC supports provisions EPA has proposed to facilitate construction of coal-fired plants equipped with CCS. NRDC agrees that CCS-equipped plants are technically feasible today and can be built even under current market conditions with subsidies provided under federal law. Further, NRDC agrees with EPA’s assessment that further experience with CCS can bring costs down.
The proposed carbon pollution standard for new power plants doesn’t stand alone. It is another important step that EPA has taken under President Obama to clean up and modernize the nation’s two most polluting sectors – the power plants that provide our electricity, and the motor vehicles that move us around. EPA’s standards to cut mercury, soot, and smog pollution from our power plants will save tens of thousands of lives and prevent hundreds of thousands of asthma attacks, heart attacks, and hospital visits. And when standards for new cars and light trucks are finalized later this summer, they will cut carbon pollution in half and double miles per gallon, saving car-owners thousands of dollars at the pump.
I’ll conclude by reminding EPA that the new source standard, important as it is, doesn’t complete the agency’s job of protecting the American people. Going forward, EPA also has the obligation under the Clean Air Act to start cutting the 2.3 billion tons of dangerous carbon pollution from the existing fleet of power plants.
The same industry spokesmen and politicians are peddling another false claim: that the Clean Air Act will wipe out the existing coal plants by requiring them to meet the same standard that EPA has proposed for new plants. But this is not what the Clean Air Act requires. The two applicable parts of that law – Section 111(b) for new sources and Section 111(d) for existing ones – are different. Nonetheless, significant and affordable reductions can and must be made in the heat-trapping CO2 from existing power plants, and EPA must get on with that job without delay.
Click on the button at the top to add your voice to the 1,000,000-plus citizens who’ve told EPA they support strong carbon pollution standards for both new and existing power plants.