Once upon a time, there was an administration that protected its people from dangerous modern fire-breathing dragons. Then in August 2018, the big bad wolf-ogre-gremlin-current administration announced plans to undo Obama rules limiting harmful emissions from fossil fuel power plants. The plot: to repeal the Obama-era Clean Power Plan, and put in its place a wicked changeling, a watered down alternative dubbed the Affordable Clean Energy rule.
But as in all good stories, there’s time for a dramatic rescue! The law requires that the public can comment on this proposed change until Oct 31, 2018.
How to comment
The Environmental Protection Agency (EPA) will accept comment on the proposed Affordable Clean Energy rule through October 31, 2018. Comments should be identified by Docket ID No. EPA-HQ-OAR-2017-0355 and may be submitted by one of the following methods.
- Go to https://www.regulations.gov/comment?D=EPA-HQ-OAR-2017-0355-21117
- or, if that link doesn’t work, go to https://www.regulations.gov/document?D=EPA-HQ-OAR-2017-0355-21117 and click the blue COMMENT button on the right side near the top;
- or, if that doesn’t work go to https://www.regulations.gov and follow the instructions for submitting comments to EPA-HQ-OAR-2017-0355.
- Email: Comments may be sent to a-and-r-Docket@epa.gov. Include Docket ID No. EPA-HQ-OAR-2017-0355 in the subject line of the message.
- Postal mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mail Code 28221T, Attention Docket ID No. EPA-HQ-OAR-2017-0355, 1200 Pennsylvania Avenue, NW, Washington, DC 20460.
Some things you can say in your comments:
- The bottom line: oppose repealing the Clean Power Plan (CPP) and replacing it with the Affordable Clean Energy (ACE) rule, because it’s imperative to reduce fossil fuel emissions and the ACE is much weaker than the CPP.
- EPA evidence in the record shows the CPP would prevent 3,600 premature deaths, 90,000 asthma attacks in children, and 1,700 heart attacks each year
- The EPA’s own calculations show that the proposed ACE would result in an additional 1,400 deaths and 48,000 new asthma attacks yearly compared to the CPP
- Under the CPP the federal government sets emission targets for states, but the ACE allows states to set the targets themselves, which promotes a “race to the bottom”
- The goal of the CPP (backed by evidence in EPA’s regulatory record) was to cut greenhouse gas emissions by 32% by 2030, compared to 2005 levels. The EPA’s own calculations indicate the proposed ACE would only reduce emissions by somewhere between 0.7 and 1.5%
- EPA’s proposed ACE uses deceptive accounting gimmicks to artificially inflate the costs of reducing greenhouse gas emissions and to minimize the health benefits of the original CPP. This means its cost-benefit analysis is flawed and unreliable
- The Regulatory Impact Analysis shows that under every illustrative scenario EPA analyzed, the ACE would result in more CO2, SO2, and NOx than the CPP
- The EPA’s analysis radically under-counts the deaths, illnesses, and climate damages from power plants’ soot, smog, and carbon pollution. This is contrary to sound science and economics
- The ACE proposal drastically undercounts the real costs of climate pollution for all Americans by ignoring global impacts. Climate pollution has worldwide impacts, but the proposal counts only those impacts that are expected to occur within U.S. borders.
- The EPA’s own estimates show that, compared to the Clean Power Plan, the ACE plan would impose up to $10.8 billion in annual net costs on Americans in 2030, when accounting for compliance costs and the loss of the CPP’s benefits for climate and public health. By contrast, the CPP was designed to save consumers hard-earned money on electric bills
- We cannot afford further delay in confronting the threat of climate change by repealing the CPP and replacing it with the much weaker ACE. Even the current administration’s reports contain overwhelming evidence that we need to cut fossil fuel emissions, including:
- The 11/17 Climate Science Special Report – the combined work of 13 federal agencies including the EPA – which contains overwhelming evidence that human-generated carbon emissions are the dominant cause of global warming with all of its effects on the U.S. and the world, including floods, heat waves, rising sea levels, hurricanes and storms
- The 8/18 Environmental Impact Statement (EIS) by the National Highway Traffic Safety Administration (NHTSA) about federal fuel-efficiency standards for cars and light trucks showing that with our present rate of greenhouse gas emissions, the planet is expected to experience a disastrous warming of 7 degrees Fahrenheit by the end of this century
The Clean Power Plan (CPP) was adopted by the Obama Administration in 2015. Under the Clean Air Act, the Environmental Protection Agency (EPA) is legally obligated to regulate carbon dioxide from major sources in the United States. That’s why, in 2015, the EPA released its first standard aimed at cutting carbon emissions from power plants, known as the “Clean Power Plan.” The power sector is second only to the transportation sector as a source of emissions in the US.
The CPP aimed to cut emissions from the electricity sector by an estimated 32% below 2005 levels by 2030—a modest but important first step. Cost-benefit analysis consistently showed a net economic gain from the CPP. It was adopted after a robust, years-long regulatory process in which the EPA held numerous hearings and received millions of comments.
The Trump Administration was hostile to the CPP from the beginning and solicitous of the coal industry and fossil fuel sectors generally. Trump directed the EPA to begin the process of repealing the CPP and replacing it with what EPA dubbed the “Affordable Clean Energy” (ACE) rule. That regulatory process is now pending and, as required by federal law, EPA is now accepting public comments on this proposed repeal and replace. The deadline for commenting on the proposed ACE is October 31, 2018.