Citizen Power’s testimony at the Public Hearings for the EPA Clean Power Plan Proposed Rule

posted in: Highlights | 0

Citizen Power’s Staff Attorney Theodore Robinson provided testimony on July 31, 2014 at the EPA public hearing held in Pittsburgh for the Clean Power Plan Proposed Rule . The hearings intent was to provide interested parties the opportunity to present data, views or arguments concerning the proposed action. Here is what Ted had to say…


Testimony – EPA’s Proposed Rule

“Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating Units”

Docket Number EPA-HQ-OAR-2013-0602

 Presented by Theodore Robinson – Citizen Power

July 31, 2014 Public Hearing, Pittsburgh, Pennsylvania

Good afternoon and thank you for the opportunity to testify today. My name is Theodore Robinson and I am a staff attorney with Citizen Power, a nonprofit public policy, research, education, and advocacy organization based in Pittsburgh, Pennsylvania. Since 1996, we have worked toward ensuring that low-income consumers and environmental interests are represented in the operation of the electric generation industry.

Citizen Power supports both the purpose and the general methodology of the EPA’s proposed rule. It is imperative that our nation effectively regulates greenhouse gases. The four building blocks approach under Section 111(d) is a reasonable and flexible step towards this goal. I would like to emphasize, however, that we view this proposed rule as only part of the solution. Additional legislation is necessary in order to further reduce emissions.

Although we generally support the proposed rule, our recommended changes to specific aspects of the rule will be addressed in our written comments. I would like to highlight three of these comments today.

First, we believe that greater reductions than those proposed by the EPA are possible through the application of the “best system of emission reduction.” For example, the use of a target of 8 to 10 percent heat rate improvements for the existing fleet is supported by the existing literature and the low cost per ton of carbon dioxide. In addition, we believe that the EIA data supports an energy efficiency “ramp-up” level of .3% instead of the proposed .2%.

Second, the proposed inclusion of new and preserved nuclear capacity as a substitute for carbon intensive generating capacity does not adequately reflect the future lifecycle greenhouse gas emissions of nuclear facilities. While wind generation has a consistently small greenhouse gas profile, the impact of nuclear facilities is dependent upon the uranium mining technologies used, the quality of the uranium ore, the enrichment method, and the carbon intensity of the electricity used for enrichment. The future quality of uranium ore, in particular, may degrade as higher quality mines are depleted, resulting in greater processing and higher emissions in the future. Additionally, the cost of disposing of nuclear waste as well as the cost associated with the potential of a nuclear accident needs to be taken into account when estimating the cost of reducing carbon emissions through increasing nuclear capacity.

Third, the use of re-dispatching to substitute combined cycle natural gas for fossil fuel-fired steam generation has impacts not addressed in the proposed rule. Specifically, the standard of performance must take into account the environmental impacts of nonair quality health and environmental impacts. The impacts from fracking, which will be increased as a result of re-dispatching, such as impacts to water quality, should be addressed and quantified in the proposed rule.

Thank you again for the opportunity to testify.