Janet McCabe, acting assistant administrator for the Environmental Protection Agency’s Office of Air and Radiation, said last week that the agency had met with more than 300 groups and received more than 1.6 million comments since releasing its proposed carbon emission rule in June. Here are a few samples.
Aluminum-maker Alcoa said states should be allowed to take into account the “measurable and verifiable” carbon reductions made by utilities and industrial power generators since 2005.
Alcoa points to its massive plant in Newburgh, Ind., where it installed more efficient turbines and sulfur scrubbers in the early 2000s.
Making additional improvements to energy efficiency would be cost-prohibitive today, Alcoa said. Thus, the company said the EPA should identify which existing units in the state have no cost-effective options to achieve a 6% unit heat rate improvement under building block 1.
“This correction also should be applied to the proposed CO2 standards for other states where heat rate improvements have already been implemented on the existing utility boilers,” said Michael Padgett, vice president of energy and carbon strategy at Alcoa.
Federal Energy Regulatory Commissioner Philip Moeller said market forces have already reduced greenhouse gas emissions by 10% below 2005 levels. But he said the EPA’s proposed rule “will dramatically interfere with America’s competitive market forces, perhaps resulting in even more greenhouse gases in the future.”
The EPA plan “seems to assume that a significant amount of new natural gas pipelines needed to fuel power plants, along with a similarly significant expansion of the nation’s electric transmission system will suddenly appear so as to meet the new demands,” Moeller continued. “Such an assumption ignores the very real challenges we currently have in expanding these categories of energy infrastructure.”
The Kentucky Chamber of Commerce was among the critics asserting that the EPA lacks legal authority for the proposed rule, which the agency plans to administer under section 111(d) of the Clean Air Act.
“The statutory language of Section 111(d) is the result of differing House and Senate versions of the language that were never reconciled in conference, but instead, were both signed into law. The House version prohibits existing sources from being regulated under Section 111(d) if those sources are already regulated under Section 112. The Senate version provides that unless a particular air pollutant emitted by an existing source is regulated by one of the other listed Clean Air Act provisions (e.g., Section 112), existing sources emitting that pollutant could be regulated under Section 111(d). Because the Senate version was classified as a conforming amendment and conforming amendments are considered procedural in nature, the House amendment controls.”
The Ohio Environmental Protection Agency said the EPA’s cost analysis is “flawed and radically underestimates the projected cost of electricity from this proposal.”
The American Coalition for Clean Coal Electricity said the EPA’s proposal “is based on flawed data and sets a dangerous legal and regulatory precedent that puts America’s energy and economic future in jeopardy. The problems associated with this legally questionable proposal are manifold and will result in needless harm to Americans’ pocketbooks and our economy at large.”
The Nuclear Energy Institute, which noted that nuclear power produces about two-thirds of all carbon-free electricity in the U.S., called the plan “fundamentally flawed.”
“EPA’s proposed rule … recognizes the importance of nuclear energy in reducing electric sector carbon emissions and attempts to create an incentive for states to preserve existing nuclear generating capacity. As proposed, however, the rule does not achieve that objective. In addition, the proposed rule creates a significant, inappropriate and inequitable penalty for Georgia, South Carolina and Tennessee, where new reactors are being built.”
The Natural Resources Defense Council said the EPA can achieve substantially deeper cuts in carbon emissions by accelerating the use of energy efficiency and renewable power. “The administration can make this good plan even better,” said David Doniger, director of NRDC’s Climate and Clean Air Program.
