EPA kicked off hearings this week in four cities on its proposed carbon pollution standards for the nation's 1500 power plants. Hundreds of concerned citizens are turning out at each hearing to raise their voices for action. A team of NRDC analysts and activists are testifying. Here are my remarks delivered on Tuesday, and links to my colleagues'.
Thank you for the opportunity to speak today on behalf of the Natural Resources Defense Council’s 1.4 million members and online activists in support of EPA’s Clean Power Plan, the proposed standards to limit carbon pollution from existing power plants. Several of my NRDC colleagues will testify during the course of these hearings, and we will address different aspects of the proposal.
EPA’s proposal is a giant leap forward in implementing President Obama’s Climate Action Plan, announced in June 2013. “The question,” the president said then, “is whether we will have the courage to act before it’s too late. And how we answer will have a profound impact on the world we leave behind not just to you, but to your children and to your grandchildren. As a President, as a father, and as an American, I am here to say we need to act.”
The President set out a specific timetable for EPA to propose and promulgate standards under the Clean Air Act to limit carbon pollution from the nation’s more than 1500 existing power plants. Power plants are the most important place to act, because they are responsible for nearly 40 percent of the nation’s carbon pollution. Power plants are responsible for more than two billion tons of carbon dioxide (CO2) pollution each year.
Limiting the carbon pollution from the nation’s existing power plants is the single most important thing our nation can do to fight climate change.
We limit all of the other air pollutants that come from power plants – the sulfur and nitrogen compounds that form dangerous soot and smog, as well as mercury and dozens of other hazardous air pollutants. But there are no federal limits on the carbon pollution that drives dangerous climate change, threatening our health and well-being, and the health and well-being of our children, grandchildren, and future generations.
So NRDC applauds EPA for proposing these standards. With hundreds of thousands of others, NRDC’s members are raising their voices in strong support for what you are doing. And we are already working with state and local officials, power companies, and other stakeholders across the country to begin developing smart and flexible state plans that advance energy efficiency and clean energy sources, to protect our health and our future while creating jobs and reducing electric bills.
The carbon pollution reductions these standards will achieve – 26% below 2005 levels by 2020, 30% below 2005 levels by 2030 – are substantial. In our view, even larger reductions are achievable cost-effectively in these time periods. We will have more to say later in these hearings, and in detailed written comments, on the opportunity to achieve greater carbon pollution reductions than EPA has proposed – bringing even greater public health and climate protection benefits to the American people.
EPA’s legal authority and responsibility to curb carbon pollution under the Clean Air Act is rock solid. The Supreme Court has upheld EPA’s authority to curb carbon pollution three times: in Massachusetts v. EPA in 2007, in American Electric Power v. Connecticut in 2011, and again last month in UARG v. EPA.
Under Section 111(d), EPA is on solid ground in proposing state-specific targets that recognize differences in how power is generated across the country. EPA is on solid ground in setting targets based on the reductions achievable using the range of methods available across the electricity system to reduce power plant carbon emissions. These methods include (1) cleaning up existing plants, (2) using cleaner resources more intensively, (3) expanding zero-emitting generation, and (4) reducing energy waste. Each of these four “building blocks” effectively reduces the emissions of affected facilities. And EPA is also on solid ground giving states and the affected facilities substantial flexibility to achieve the applicable performance target through different combinations of measures than those EPA used to set that target.
Contrary to some, there is nothing in the statutory language that limits the EPA to consider only measures implemented at each affected source itself when setting the level of emission reduction required by the Section 111(d) guidelines. To the contrary, the term “best system of emission reduction” and other features of the statutory language indicate EPA’s discretion to set targets based on the reductions achievable using the full range of measures available across the electricity system.
In sum, we strongly support the steps EPA is taking under the Climate Action Plan and the Clean Air Act to place meaningful, first-ever limits on the carbon pollution from existing power plants. And we look forward to continuing collaboration with states, industry, and other key stakeholders to craft and implement strong, effective carbon pollution standards to protect our health and our children’s future.
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Click here for comments by Noah Long, Jackson Morris, Starla Yeh, Christina Zhou, and Lance Robertson. (I'll add more links as the posts go up.)