Millions of Americans submitted comments last year applauding the Environmental Protection Agency's (EPA) Clean Power Plan to set the first-ever limits on carbon pollution from power plants. It's been nearly two months since the public comment period closed on EPA's proposal, and we've been taking a look at the comments submitted by states and power companies. Since states are responsible for implementation of these standards, and the resulting changes to the electric sector will have big implications for power companies, these stakeholders are integral to the success of the Clean Power Plan.
States support the Clean Power Plan
We haven't yet reviewed all 50 states, but so far we're seeing a lot of positive reactions. A group of 14 states applauded the Clean Power Plan in a joint comment letter to EPA, facilitated by the Georgetown Climate Center at Georgetown Law School. The states on this joint letter include California, Illinois, Minnesota, Oregon, Washington, Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont.
These states emphasize the need for action on carbon pollution and climate change. In the past few years, many of these states have recently experienced devastating wildfires, severe droughts and heat waves, and extreme weather events like hurricanes, and realize these kinds of climate impacts are bound to get worse if we don't reduce our carbon emissions.
These fourteen states agree that EPA should use its authority under the Clean Air Act to put carbon pollution limits on power plants, and mention their appreciation of "EPA's unprecedented outreach effort" to states and stakeholders in development of the Clean Power Plan. Some key excerpts from the comments of these 14 states:
- "We applaud the flexibility that EPA has provided to states, reflecting the federalist framework of the Clean Air Act and Section 111(d) in particular."
- "We support EPA's general approach to identifying a Best System of Emission Reduction (BSER) that recognizes the system-wide strategies that are already being used to achieve carbon pollution reductions from fossil fuel-fired power plants and drive technology improvements in the electricity system."
- "Even greater levels of cost-effective carbon pollution reductions from the power sector are achievable in this timeframe using the system described by EPA."
In addition, nine states participating in the Regional Greenhouse Gas Initiative (RGG) also welcomed EPA's proposal to limit carbon pollution. Through a cooperative agreement to limit carbon pollution from power plants, RGGI states have cut the sector's carbon pollution by 40% since 2005. Nine RGGI states (Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont) submitted joint comments about the EPA proposal. As they explained:
- "The RGGI states commend EPA for utilizing its authority under section 111(d) of the Clean Air Act to set the nation on a clear path toward achieving significant carbon reductions from our power sector, while catalyzing innovation and growth of the clean energy sector."
Utilities cooperating with EPA
Maybe its not all that surprising that states are supportive of pollution limits that will protect public health and infrastructure - after all, states spend a lot of money on both. But utilities aren't usually in the position of welcoming new pollution standards. So power company responses to the standards may come as a surprise: according to SNL Financial (subscription required), "62% of utility executives surveyed by Utility Dive, a trade publication, support the EPA's emissions plan or want it to be more stringent."
In addition to finding a generally positive outlook about carbon limits, Utility Dive found that carbon limits are not even at the top of the list of concerns among the utility executives surveyed. Their top three worries: old infrastructure, aging workforce, and the current regulatory model utilities live by.
Comments filed by power companies about the carbon standards also reveal positive reactions to the proposed pollution limits. NRDC is in the process of reviewing comments from electric utilities, and so far we have found that more than 50 utilities are engaging constructively with EPA. See my colleague Derek Murrow's blog for more detail. This list of utilities serves more than 45 million customers in the U.S. Many of these companies are directly supporting the Clean Power Plan, and all are offering constructive recommendations on how to improve the proposal.
For example, National Grid, a Northeast region utility serving 3.4 million customers, commented in support of the Clean Power Plan:
- "We see the EPA's proposed CPP as a practical move toward a meaningful reduction in GHG emissions, and National Grid supports its overall structure to advance America's clean energy economy."
Exelon, an Illinois-based utility that delivers electricity and natural gas to 7.8 million customers, urged EPA to stand strong on the interim pollution targets:
- "EPA can have confidence in the resiliency of the wholesale electricity markets in the face of changes in supply resulting from the Clean Power Plan, and the Agency should resist calls to weaken or delay interim goals." (Exelon)
And unlike some doomsday coal lobbyists, many utility companies stated that we can cut carbon pollution and keep the lights on, including Calpine Corporation, Exelon Corporation, Los Angeles Department of Water and Power, National Grid, NextEra Energy, and Seattle City Light. Specifically, these companies wrote:
- "We agree with EPA that meaningful emission reductions can be achieved from the electric sector while maintaining electric system reliability."
More reviews of the comments to come, but so far it is clear that both states and utilities are on the record supporting EPA's Clean Power Plan. While all parties have ideas on how to strengthen or improve the proposal, it is encouraging to see that states and utilities believe it's a good idea to cut carbon pollution.