EPA's Pittsburgh Hearing on the Clean Power Plan: My Comments

Jackson Morris at EPA hearing.

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.  I’m one of a team of NRDC analysts and activists who are testifying.  Here are my remarks, delivered in Pittsburgh today, and links to my colleagues'.  

Good afternoon, my name is Jackson Morris. I am Director of Eastern Energy at the Natural Resources Defense Council and a native Pennsylvanian who travelled across the state from my family farm in the Susquehanna Valley to testify today.

NRDC is a nonprofit environmental organization with more than 1.4 million members and online activists, including nearly 54,000 in Pennsylvania. Since our founding in 1970, our lawyers, scientists, and other environmental specialists have worked to protect the world's natural resources, its public health, and the environment. NRDC’s top institutional priority is curbing global warming emissions and building the clean energy future. I’m also a father of three, and my top personal priority is taking care of my kids.

Pittsburgh's Mayor Bill Peduto, surrounded by local kids, kicking off a press conference today in support of the EPA's Clean Power Plan. 

For both those reasons I’m here to support the EPA’s proposed Clean Power Plan. It is the largest single step ever taken to reduce global warming emissions in this country. By reducing emissions we will reduce the risk of climate impacts for our children, including the droughts, severe storms and the climate-change-related health problems, including increased respiratory problems, that we are already experiencing in Pennsylvania and across the country.

The proposed Clean Power Plan will also yield other significant benefits for us here in the Keystone State: Modeling shows that pursuing carbon reductions through a state plan that ramps up our investments in energy efficiency and renewable energy can yield more than 5,000 jobs by 2020, and save families and businesses more than $450 million dollars in energy costs. These reductions will also prevent thousands of asthma attacks, heart attacks and other respiratory illnesses by cutting air pollution from power plants.  

In Pennsylvania, we already have some good, ongoing models that will help us meet the draft state target of a 32% reduction of carbon intensity by 2030. In fact, since EPA used fairly conservative assumptions to generate its estimates of our renewable energy and energy efficiency potential, Pennsylvania could harvest significantly greater cost-effective carbon reductions, with increasing benefits.

On energy efficiency, the state’s energy efficiency law, Pennsylvania Act 129, enacted in 2008, has already delivered huge cash and energy savings to customers and is set to deliver many more. Customers of the state’s largest distribution utility—PECO—have saved roughly $331 million since the law was first implemented; and customers of PPL—my own utility—have saved roughly $428 million.

There’s huge potential to do more on efficiency in Pennsylvania. The state’s own analysis shows we can cost-effectively cut more than 27% of our forecasted energy use over the next 10 years, using currently available technology. (By contrast, EPA assumes cumulative energy savings in 2029 of just over 11%).           

On the renewable energy front, while the state’s Alternative Energy Portfolio Standard definitely needs to be strengthened, Pennsylvania is well-positioned to ramp up. Even in its current relatively modest form, the standard has already driven the installation of more than 1,300 megawatts of wind power—Pennsylvania has 25 wind farms—providing 1.5% of the state’s energy in 2013 and powering the equivalent of 300,000 homes.

A solid solar power foundation has been established as well. There are more than 440 solar companies in our state, employing 2,900 workers, and our installed solar capacity is 11th in the nation.

We can give Pennsylvania more jobs, more energy savings, a more stable climate, and healthier families by meeting—and exceeding—the targets in the proposed plan.

NRDC also strongly supports EPA’s proposal to allow states to pursue regional, multi-state approaches to compliance. As the Regional Greenhouse Gas Initiative has demonstrated, a regional approach has a number of advantages. These include but are not limited to greater flexibility for compliance entities, better alignment with energy markets—electricity transmission generally doesn’t stop at state borders—and lower net costs for compliance, which benefits consumers. In fact, a recent report from the Analysis Group found that “RGGI produced in total $1.6 billion in net present economic value (NPV) for the ten-state [RGGI] region.” Such interstate value might be achieved by linking the three energy-intensive states of Ohio, West Virginia, and Pennsylvania, and their assets I’ll outline below, to achieve these benefits at the lowest cost.

In order to facilitate such discussions among states interested in pursuing regional approaches, we urge EPA to publish and release mass-based targets to accompany the rate-based targets included in the proposed rule. Doing so will reduce uncertainty for state regulators, giving both the RGGI states and others a clearer picture of their mass-based obligations as they weigh compliance options and engage in regional conversations. 

All this brings me to Ohio, the Buckeye State. In cutting carbon emissions from power plants, Ohio is already ahead of the game, with a robust energy-efficiency and renewable-energy sector. Ohio’s efficiency and renewables law, called the Renewable Energy Portfolio Standard, is on hold for two years. But the law, once fully implemented, can be an important part of the calculus as the state devises its compliance plan. 

Already, the standard has saved Ohioans billions of dollars on energy. Additional efficiency savings from beefed-up building codes, appliance standards, and deep, industrial efficiency programs can put Ohio even further ahead in meeting its Clean Power Plan targets. 

These energy-efficiency investments can reduce carbon emissions by a conservative 32 million tons annually—the amount emitted by 6.7 million cars. And a fortified clean energy economy, which the Clean Power Plan can help bring about, will mean more jobs for Ohioans. In fact, a recent NRDC analysis demonstrates that improving energy efficiency as part of the state’s implementation plan can put 8,600 Ohioans to work, and reduce the state’s total electric bill by about $400 million a year—$6.80 per month for every household.  

Thanks to the renewable energy standard, Ohio is also on track to derive 12.5 percent of its energy from renewable sources, like wind and solar power, by 2025—eight years ahead of EPA’s assumption for this compliance tool. Since the law was first implemented in 2009, these low-carbon energy sources have fostered 25,000 jobs at more than 400 Ohio companies in places like Dublin, Tipp City, and Toledo

You may hear from other folks that Ohio’s reduction target is daunting for a state that relies on coal for nearly 70 percent of its power. But the truth is that Ohio is already on track. 

Pennsylvania’s neighbor to the South, West Virginia, also has much to gain from its very achievable and realistic target under the Clean Power Plan: The state is the third windiest east of the Mississippi and already home to six large wind farms. In West Virginia, there’s enough wind power potential to supply almost 20 percent of the state’s electric needs. Electric rates that have skyrocketed recently due to an overreliance on one fuel source—coal—can be brought down as the state capitalizes on its largely untapped energy efficiency resources, saving consumers money on energy and creating jobs simultaneously.

EPA’s proposed plan is an important step forward for the nation. We must now work to build on this proposal and adopt an even stronger final rule next year to benefit not only Pennsylvanians, but Ohioans and West Virginians and the economies of these three states. In the meantime, regulators in these states can get busy crafting smart compliance plans that will make them national clean-energy leaders.

We look forward to continuing to work with EPA and state decision makers in Pennsylvania, Ohio and West Virginia—and across the nation as well—to strengthen the Clean Power Plan proposal and pursue smart state approaches to meeting and beating the required emissions reductions. Doing so will maximize job creation, bill savings and public health benefits. Thank you. 

Here are links to Noah Long's comments at the EPA hearings in Denver earlier this week, and David Doniger's comments in Washington DC.