April 17, 2018
On April 17, 2018, state officials from fourteen environmental and energy agencies representing thirteen states submitted joint comments to the Environmental Protection Agency opposing its proposed repeal of the Clean Power Plan. The Clean Power Plan (CPP), issued by the Obama Administration under section 111(d) of the Clean Air Act, established a federal framework to reduce carbon emissions from existing fossil fuel-fired power plants, and was a key part of the previous administration’s strategy for meeting U.S. commitments under the Paris Climate Agreement. In October 2017, the Trump Administration’s EPA proposed to repeal the CPP. In this response, state officials note that EPA has an affirmative obligation under current law to regulate greenhouse gas emissions from existing power plants, argue that a federal framework is needed to achieve reductions, and urge EPA to maintain the CPP. The letter was signed by state officials from states representing a total combined population of 114 million people and 44 percent of the U.S. economy, with signatories from: California, Colorado, Connecticut, Delaware, Massachusetts, Minnesota, New York, North Carolina, Oregon, Rhode Island, Vermont, Virginia, and Washington.
The letter, which was facilitated by the Georgetown Climate Center, highlights that growing investments in low-carbon energy resources in conjunction with steady improvements in energy efficiency have contributed to substantial cuts in carbon emissions from the power sector. The letter emphasizes that the CPP was designed to allow states to meet compliance through the use of successful state policies and programs and it questions EPA’s assertion that the rule intrudes on state authority over electricity generation. Signatories also disagreed with EPA’s claim that the CPP would have significant negative economic impacts, noting that their economies have grown as they continue to decrease their emissions.
The letter is also strongly critical of the economic analysis that accompanied EPA’s proposed CPP repeal. In particular, the EPA chose to discount the estimated costs of climate change and to deviate from the agency’s long-standing approach to accounting for the public health impacts of particulate matter and other energy-related pollution.
The letter can be downloaded by clicking on the link below.
On February 26, 2018, officials from 12 states submitted comments regarding EPA’s Advance Notice of Proposed Rulemaking on a potential replacement for the Clean Power Plan. Those comments can be found here.