Comments on the Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units

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More than 97% of scientific papers in the field of climate change support a role for human activity in altering Earth’s climate. There is no longer any debate that human activity is changing the climate; the only question is how we will deal with this inescapable fact. Well-understood physics, dating back 150 years and never substantively challenged, show that carbon dioxide (CO2) emissions can affect the Earth’s climate by trapping heat. In line with predictions, recent studies show that CO2 is a major driver of human-caused climate change. We have a moral responsibility to lead on this issue.

In 2015, the Environmental Protection Agency (EPA) issued the Clean Power Plan (CPP). This plan was developed after years of extensive public engagement that explored how best to establish requirements under the Clean Air Act to limit climate pollution from the power sector. The CPP is flexible and sensitive to local needs because it sets emissions standards for fossil fuel-fired power plants and corresponding emissions goals for each state that reflect the unique power system in each state. Under the CPP, each state develops and implements its own plan to reach its goal. This flexibility allows each state to set their own energy priorities. Maryland has a diverse set of energy needs and opportunities, and the freedom allowed under the CPP is important for Maryland’s growth.

THE CPP SAVES LIVES: EPA’s 2015 analysis shows that full implementation of the CPP in 2030 would avoid 1,500 to 3,600 premature deaths; 90,000 asthma attacks in children; up to 1,700 heart attacks; 1,700 hospital admissions; and 300,000 missed work/school days nationwide. A recent analysis by the Trump administration found that the CPP could prevent up to 4,500 premature deaths each year by 2030–an estimate higher than previous EPA projections.

THE CPP SAVES MONEY: EPA’s 2015 analysis estimates that the CPP’s benefits ($31 to $54 billion) would far exceed the costs ($5.1 to $8.4 billion) upon full implementation in 2030. From the soot and smog reductions alone, for every dollar invested through the CPP, American families would see up to $4 in health benefits. Repeal means that these health benefits would be lost. EPA’s analysis showed that by 2030, more efficient use of electricity would result in the average family’s electric bill being $7 lower with the CPP than it would have been otherwise. Across the country, the CPP is expected to result in $20 billion of climate-related benefits in 2030 alone.

THE CPP IS GOOD FOR JOBS: Clean energy jobs have seen incredible growth in recent years, with solar and wind jobs growing at a rate 12 times faster than the rest of the U.S. economy. Wind turbine technician is the fastest-growing profession in the country. Today more than 3 million Americans hold jobs in clean energy, installing and operating wind and solar systems and making our homes and buildings more energy efficient, passing savings onto us. Today more than 67,000 Marylanders work in energy efficiency-related jobs, chiefly helping homes and businesses waste less energy by improving lighting efficiency, materials and insulation, and heating and cooling systems.

THE CPP IS AN EFFECTIVE WAY OF COMBATING CLIMATE CHANGE: Fossil fuel-fired power plants are the largest source of greenhouse gas pollution in the U.S., emitting 31% of U.S. emissions. Any credible effort to cut climate-changing emissions must substantially cut power plant emissions. With strong and achievable standards, the Clean Power Plan would cut U.S. carbon pollution 32% below 2005 levels by 2030 (870 million tons). The CPP is an appropriate way to cut climate pollution under the Clean Air Act because it recognizes the electricity system is interconnected and reflects the way the power industry really works.

The Trump administration has argued that the economic costs of the CPP outweigh the benefits. We believe that this position is unsupportable by any objective assessment of the facts, and this analysis uses inappropriate assumptions and simply omits some benefits. The analysis is, quite frankly, intended to support a predetermined ideological agenda and could not survive independent scrutiny. Furthermore, this repeal is predicated on a specific interpretation of the Clean Air Act that is in direct opposition to EPA’s prior interpretation. Since the CPP is currently subject to several lawsuits, repealing it before these lawsuits have a fair and impartial hearing speaks to the unsound interpretation of the Clean Air Act on which the administration is predicating this repeal, and is an attempt to thwart the courts as the legitimate arbiter of interpreting the law.

We oppose in the strongest possible terms the repeal of the CPP provisions, and urge the EPA administrator to fully implement the law.