Comments on Rollback of the Clean Power Plan Carbon Capture and Sequestration Rule

How to comment: 

The deadline for comments is 11:59pm Monday, March 18th

I am writing to oppose EPA’s proposal to withdraw regulations to limit carbon dioxide (CO2) emissions from coal-fired power plants (Docket: EPA-HQ-OAR-2013-0495). I am gravely concerned about the adverse effects caused by CO2 emissions and the lack of concrete action by EPA to address this problem.

CO2 is a major cause of climate change and global warming, which is responsible for widespread environmental destruction and both direct and indirect threats to human health (National Climate Assessment, 2018). The proposed rollback aims to eliminate the mandated use of Carbon Capture and Sequestration (CCS) technology in new, modified and reconstructed coal-fired power plants. This change would allow power plants to continue spewing dangerous levels of CO2 into the environment for years into the future and is a major step backward in EPA’s efforts to protect the environment.

EPA has failed to both justify the proposed changes and recognize the importance of maintaining the current requirements for the use of CCS technology. The EPA’s position is in contrast to The United Nations Intergovernmental Panel on Climate Change (2014 Synthesis Report), which has stated that emissions targets that would limit global warming to levels below those generally acknowledged to be potentially irreversible and catastrophic likely cannot be achieved without CCS. EPA argues that new or modified coal-fired plants are unlikely to be constructed in the US because market forces are not in coal’s favor, and therefore the existing regulation will never come into play. However, this is by no means a certainty. This approach could result in releasing significant CO2 emissions into the environment and would significantly delay replacing old fossil fuel technology with modern renewable energy technologies.

Another major problem of the proposed regulation change is that it would cede US leadership in the development of CCS technologies at a time when coal-generated power is stable, if not increasing, in the developing world. This fact reaffirms the need for CCS and other CO2-neutralizing methodologies for years to come. Withdrawing the requirement for the use of CCS technology in the US would further raise doubts about the US’s commitment to addressing global climate change. EPA acknowledges that operational projects show partial CCS is feasible for controlling CO2 emissions, both within and outside the power generation industry. Nevertheless, it is apparent that further development is necessary in order for CCS technology to be widely used. It can be argued that it is primarily the US that has the resources, knowledge and business capability to develop CCS in a way that can be implemented and made available worldwide.

One group in particular has committed to undertake actions that could lead to full commercialization of CCS. The US Climate Alliance, a bipartisan coalition of 21 states, is engaging its own efforts to address global warming, as outlined by the Paris Agreement, because of the federal government’s actions that will actually increase carbon pollution and promote global warming (Wash Post, p A16, Feb 14, 2019). The Alliance will pursue aggressive climate action by developing and promoting policies to reduce carbon pollution and promote clean energy and power sector modernization at the state, federal and international levels. By maintaining a focus on CCS, US leadership could address the most significant threat to our planet today and create a US-based industry supplying customers worldwide.

It is extremely disconcerting that EPA is promoting the use of coal for power generation. This is contradictory to the actions of other notable groups that are acting to limit coal’s use. One of the world’s largest coal mining companies, Glencore PLC, is limiting its coal output because of the fading market in the US and other developed countries (Wash Post, p A18, Feb 22, 2019). Glencore is also under pressure from its investors to address climate change and global warming. Additionally, major oil producing companies are taking action to decrease greenhouse emissions, invest in alternate sources of energy, and support a carbon tax (Wall St J, p B5, Feb 21, 2019). Finally, coal-fired plants, such as those of the Tennessee Valley Authority, are being retired earlier than planned because they are too costly to maintain and no longer needed to produce electricity because natural gas is a cheaper and less polluting alternate fuel (Wall St J, p A11, Feb 15, 2019). Taken together, these facts show a broad and diverse group of entities that recognize the harmful effects of operating coal-fired power plants and the limited future of such plants. It is time for EPA reclaim its role as the world leader in fighting this major cause of climate change and global warming by maintaining the requirement for CCS technology in the current regulation.