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GHG Regs Must Be Top Priority

January 9, 2012

Setting greenhouse gas performance standards for new and existing coal-fired power plants has to be THE environmental, energy, and climate policy priority for 2012. Given the carbon footprint of this industry, building a new coal fired power plant without some level of carbon dioxide control is simply not justifiable technically, politically, or even economically. Cleaning plants up later costs more than building them with clean technology now.

The first of these U.S. EPA rules is now under review at the Office of Management and Budget, and EPA must finalize the rule in the late spring, under a consent decree with environmental groups. This rule is critical because coal-fired power plants are the largest stationary sources of carbon dioxide air pollution – and there is now available control technology permitting deep reductions, as we are seeing with the first applications for plants that capture and sequester carbon dioxide.

EPA’s recent actions in finalizing the Mercury and Air Toxics Rule and the Cross-State Air Pollution Rule are excellent protections for public health – but they simply won’t get significant carbon dioxide reductions from new or existing coal plants. Cost-effective controls exist to meet these rules without retiring many existing units, but those controls do not have any impact on carbon dioxide emissions. So, the MATS and the CSAPR –when implemented, as we are confident they will be — are not a substitute for a performance standard for CO2 emitted by coal fired power plants. And, to the extent that the power industry seeks “regulatory certainty” these new source performance standards are very timely – as they complete EPA’s multi-pollutant strategy for the power sector, providing critical information for planning for power sector transition in the coming decades.

We expect President Obama to continue to stand strong on the need to bring the electric generating sector into the 21st century. Issuing CO2 performance standards for this industry is an absolutely necessary step if the Administration has a hope of meeting its commitment to a 17 percent reduction below 2005 levels by 2020. Moreover, the Supreme Court’s recent decision in AEP v. Connecticut, denying private plaintiffs the right to sue power plant owners over climate damage, is based on the assumption that these standards will come out in the near term, and be established at levels that actually address the significant climate impact from this industry.

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