Washington, DC – In June, the Environmental Protection Agency (EPA) proposed the first-ever national limits on carbon pollution from existing power plants, which are scheduled to be finalized after public comment and subsequent review. With the public comment period closing today, U.S. Senator Sheldon Whitehouse (D-RI) is submitting formal comments urging EPA to strengthen its proposal and to ensure that fear mongering from opponents doesn’t derail its efforts.
“You have the moral, economic, scientific, and popular high ground,” Whitehouse wrote. “EPA’s carbon pollution standards for existing power plants are one of the most important standards to ever have been developed by your agency. As you move forward, please remember that the public is relying on you to address the climate threat and to remain strong.”
Whitehouse’s letter also asks EPA to expand the final standards to incentivize even more renewable energy and energy efficiency and to explicitly recognize the potential of emerging technologies to reduce carbon pollution. For example, Whitehouse notes that EPA recognizes carbon capture and storage (CCS) as a potential compliance option in its proposed rule, but makes no mention of carbon capture and utilization (CCU) technologies, such as algae.
Whitehouse included this request after visiting BioProcess Algae in Portsmouth, RI with Senator Joe Manchin in October. The company has developed a process for converting carbon pollution into eco-friendly products such as animal feed and biodiesel.
“EPA should send a signal that CCU and not simply CCS would be a welcome means of compliance for states,” Whitehouse wrote.
Whitehouse concluded his comments by urging EPA to thoroughly consider comments submitted by the Regional Greenhouse Gas Initiative (RGGI) – a regional cap-and-trade system that Rhode Island participates in – to ensure that market-based programs like RGGI can be used to achieve compliance with the final power plants standards. He also urged EPA to consider steps to enable states to comply with the standards using carbon taxes or fees. Last month, Whitehouse introduced legislation that would establish a nationwide carbon fee.
The full text of Whitehouse’s letter is below.
December 1, 2014
The Honorable Gina McCarthy
Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington, DC 20460
Dear Administrator McCarthy:
Congratulations on the release of the first-ever carbon pollution limits for the biggest emitters – power plants. The Environmental Protection Agency is involved in a significant and consequential regulatory enterprise, as the fifty worst American power plants together emit more carbon pollution than all of South Korea or all of Canada.
It is also an enterprise that puts EPA into battle with a desperately motivated adversary. The carbon polluters are fighting to protect a loophole that even economists at groups as conservative as the American Enterprise Institute count as a “market failure.” This market failure allows these polluters to impose billions of dollars in costs and harm on their fellow Americans, without economic consequence to themselves. They will fight desperately to continue this harmful behavior; we know this because they already are fighting desperately in the legislative, judicial, and public relations arenas. The polluters have had a long, happy holiday from responsibility for the harms they are causing, and they don’t want that holiday to end.
For the rest of us – coastal states facing rising and acidifying seas; agricultural states facing drought and flood; timber states facing massive forest die-offs; northern states facing snowpack collapse; states across the country facing more heat waves and diminished air quality – the end of their holiday from responsibility cannot come soon enough. Unless we act now to cut carbon pollution, these effects will only grow worse, and our children and grandchildren will suffer the consequences.
EPA is addressing these threats, and the public is with you. Americans feel far better about the EPA than they do about Congress. Americans understand the need to curb carbon pollution. Indeed, most are surprised there aren’t already limits in place for carbon pollution. You have the moral, economic, scientific, and popular high ground.
EPA’s proposed carbon pollution standards offer polluters an opportunity to work with their states, and even across multiple states, to design plans to reduce carbon emissions, including cap-and-trade programs and similar regimes. The proposal provides flexibility to states to adopt reasonable strategies according to their circumstances, needs, and priorities. Rhode Island and other states in the Regional Greenhouse Gas Initiative (RGGI) have already shown that cap-and-trade can achieve both carbon reductions and economic growth. According to the Acadia Center, since RGGI began, “emissions in the region [have] dropped 2.7 times faster than the rest of the country . . . even as RGGI states’ economies have grown 2.5 times faster than other states.” In Rhode Island, RGGI has generated millions of dollars in new revenues since 2008, enabling more investments in energy efficiency, renewable energy, and other programs that benefit the state’s citizens. These investments and similar ones made by other RGGI states to date are projected to return more than $2 billion in lifetime energy bill savings to more than 3 million households and 12,000 businesses in the region.
Even greater benefits can be achieved through national carbon pollution standards, yet EPA’s efforts are under attack by the polluters and their Republican allies in Congress. Industry has a long history of muddling the science, manufacturing false doubt, and exaggerating the regulatory costs, all to undermine the development of public health standards. They have engaged in a massive and complex propaganda effort to mislead the public about the realities of climate change. They look with equanimity on the serious harms and perils that they impose on their fellow citizens, whether it’s a Rhode Island child on a nebulizer in the emergency room for an asthma attack triggered by smog, or a farmer looking out at his parched or flooded fields exacerbated by carbon-driven climate change.
You must not allow these forces to derail your efforts. In fact, I urge EPA to do more. In its final standards, EPA must ensure that necessary and cost-effective carbon pollution reductions are not left on the table. While EPA’s proposal will incentivize new investments in clean energy, still greater investments can be made to cut carbon pollution at a tremendous benefit to the American people. EPA should ensure that its final proposal captures the full technical and economic potential of renewable energy and energy efficiency to reduce emissions, and that all proven and effective measures are incorporated into its power plant standards. EPA should also explicitly recognize the potential of emerging technologies that are not included in its determination of the best system of emission reduction (BSER) to reduce emissions, if states choose to invest in them. In its proposal, EPA recognizes carbon capture and storage (CCS) as a potential compliance option, yet makes no mention of carbon capture and utilization (CCU) technologies, such as algae, which could transform CO2 from a costly waste disposal issue into an economic resource that will benefit industry, the environment, and ratepayers. EPA should send a signal that CCU and not simply CCS would be a welcome means of compliance for states.
Finally, I urge EPA to thoroughly consider RGGI’s comments on the proposed standards to ensure that market-based programs like RGGI can be used to achieve compliance with EPA’s final standards. EPA should also carefully consider comments from the Brookings Institution, R Street Institute, and others on steps EPA could take to enable states to comply using carbon taxes or fees.
EPA’s carbon pollution standards for existing power plants are one of the most important standards to ever have been developed by your agency. As you move forward, please remember that the public is relying on you to address the climate threat and to remain strong.
United States Senator