Mobilizing Public Comments for EPA Clean Power Plan

A big part of what motivates Community Power is the moral imperative for all of us collectively to lower carbon dioxide emissions on short order. What will actually push the dial for climate mitigation is phasing out existing coal fired power plants; shutting down the oldest and dirtiest coal plants first (ex. Xcel’s Sherco plant). Power plants account for 40% of all greenhouse gases in the U.S and 74% of those emissions are from coal-fired power plants. However, so many utilities have so much sunken investments into existing coal plants, they will face stranded assets if coal plants are shut down long before their natural depreciation is complete. Utility cooperation with this moral imperative has a lot to do with whether the companies see that coordinated action on new climate policy as something inevitable to prepare for or whether they assume political success with climate policy won’t happen. We are fortunate to have such an opportunity before us right now to build that public and political pressure right now.


We currently have a narrowing window of time to protect the outcome of the EPA's long-overdue and historic draft proposal to cut carbon dioxide emissions from all existing power plants by 30% from 2005 levels by 2030. Public comments on the draft rules for the nation's first ever carbon limits are being accepted until Dec 1st, 2014. The EPA is legally required to read and respond to all comments in deciding the final rules to be issued in June 2015. As a result we need as much supportive and forward looking commentary as possible in order to outweigh the onslaught of commentary from those who want to quash the EPA proposal and keep the status quo.

 The scope of the proposed rules only applies to CO2 emitted per megawatt hour from existing power sources. Because transportation, home heating, and agriculture will not be affected, this proposal alone by itself is not enough to meet the 80% by 2050 reductions the IPCC says are needed to stabilize the planet's climate.

However there is a reason why it is so crucial for the final EPA carbon limit rules issued in June 2015 to be robust. It will put the United States in adequate moral authority for working toward an ambitious new global climate deal in Paris next year which is a critical make or break conference because of how the politics of the US are structured. The international coordination we truly need to mitigate the climate crisis will only inspire additional nations to take concrete action if the US demonstrates it is serious about tackling its own emissions. During the time of the Kyoto Protocol last decade, the US refusal to take any international obligation has provided an excuse for other countries that have far less CO2 emissions per capita than the US to not make adequate commitments. The EPA proposal announcement on June 2nd sent a signal to China and the rest of the world that the U.S. is finally getting serious about reducing emissions. 

Let’s mobilize as many positive comments to the EPA before the October 16th deadline so that commentary from the backlash does not succeed in stripping the U.S. government from the one legal tool it has to reduce emissions and leave the US without any leverage for advancing a climate deal Paris next year.


 In an ideal world, those who state concern about whether the EPA rules will impede economic growth, cost jobs or cause our electricity rates to skyrocket would be expressing appreciation for how the EPA proposal takes a more flexible, dynamic approach than typical pollution regulation. Each of the 50 states will get its own customized cap of allowable emissions and is offered freedom to choose from different options by the EPA for how to meet the target. Options laid out in the rule draft include improving the efficiency of coal plants, converting coal to natural gas, increasing renewable generation, demand reduction through energy efficiency or joining a regional cap and trade program.

Of course, these efforts to be flexible and accommodating will not appease groups like The US Chamber who have demonstrated their closed-mindedness by fighting this EPA proposal even before the specifics were announced on June 2nd. And today these same groups are pressuring Congress to pass legislation that would block these new carbon limits and stop the EPA from taking any action on the climate crisis. The determined backlash has already filed three lawsuits against the EPA proposal even though the regulations are not final yet.

 They are taking part in a long tradition of overestimating the costs and job losses for new environmental regulations while discounting the economic, human health and jobs benefits. Pacific Institute President Peter Gleick has provided extensive documentation, going back to the 1970's of how such cost exaggerations are “always wrong.”

Instead standards such as the 1990 version Clean Air Act have driven and will drive technological innovation from the private sector and accelerate deployment of clean energy solutions and improved energy efficiency. In its draft proposal, the EPA estimates the net health and climate benefits for the rule will be $28 billion to $49 billion in 2020, rising to $48 to $82 billion in 2030. These far outweigh the estimated $5.5 billion in 2020, to $8.8 billion in 2030 compliance costs of the rule. Furthermore, the status quo route leading to climate disruption induced, massive droughts, wildfires, rising oceans and storms are what will be genuinely expensive and job-killing.

The bare minimum of what new EPA rules should accomplish would be to stop any new investments in building new baseload coal plants. We need to shift investment to creative energy storage capacity and innovation around the distribution edge because big baseload generation is technically incompatible with a grid based on more intermittent renewable power. Distributed low-carbon renewable energy generation has to fill the void if we are successful with getting the dirtiest of the aging coal plants retired.

We should not limit ourselves to playing defense on the Clean Power Plan when there are at least two important ways we can play offense to strengthen the Clean Power Plan.




 Just because the President and his administration have singled out coal burning power plants as the targets of the proposed EPA rules, it should not be a defacto license for natural gas fracking to run unquestioned and unchecked because of the methane leakage danger it poses. Through comments, lets ask the President and the EPA to emphasize biogas and anaerobic digestion alternatives to fracking for natural gas. Because methane is a far more potent greenhouse gas than CO2, the climate advantage that natural gas has over coal could be wiped out if even a small “frack”tion of the methane is released in the process of drilling and transporting the natural gas. Less coal burning has the environmental bonuses of less particulate pollution and toxins like mercury and sulfur dioxide. However natural gas extraction through fracking has its share of serious local environmental impacts that are not being given fair acknowledgment.



 As things stand right now, the 645-page draft rule is conspicuously devoid of any explicit mention of a carbon tax as an option for states in meeting the targets. The Congressional Budget Office has done an assessment which concludes a carbon tax is more economically efficient than cap and trade. EPA officials have made statements in public that a carbon tax is a viable mechanism for meeting climate goals. But if such statements are not in print in the final rules, then it makes it more of a risk for an individual state to use a carbon tax as a compliance mechanism. However, if a great number of states choose to meet their EPA targets through a carbon tax then businesses will lobby the Federal Government to issue a single federal carbon tax in order to minimize their costs of complying with varying of carbon pricing regimes. Skeptics who have yet to be convinced of a carbon tax understandably say they want more data. The more states that issue a carbon tax, the better we will be able to demonstrate that they can be effective at reducing emissions.

 If enough comments are submitted that say basically the same thing asking for a carbon tax, the EPA will group them together and address the comments as a group. The more comments there are in a group, the more attention the particular concern is likely to receive. 

Let's please amply our voices and don't let their corporate money of fossil fuel billionaires speak for the rest of us.


How to submit a comment

Your comment can be very simple, or very complex. 

Here are ways to leave a comment:

1. Comment online at:!documentDetail;D=EPA-HQ-OAR-2013-0602-0001

Paste the address into your browser, click on the blue “Comment Now!” button at the top right of your screen, and follow the instructions.

2. Submit your comment by mail. Send to this address:

Environmental Protection Agency, 
EPA Docket Center (EPA/DC), 
Mailcode 28221T, 
Attention Docket ID No. OAR–2013-0602, 
1200 Pennsylvania Avenue, NW., 
Washington, DC 20460




Take Action! Donate Attend an Upcoming Event