AFS Provides Comments on EPA’s Clean Power Plan for Existing Power Plants
December 23, 2014
AFS submitted comments in December on the EPA’s controversial proposed Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (also known as the Clean Power Plan or 111(d)). Also, AFS signed onto the Partnership for a Better Energy Future’s comments led by the U.S. Chamber and National Association of Manufacturers, with dozens of other trade associations.
In the comments, AFS highlights key concerns on how the agency’s Clean Power Rule creates major questions about the reliability and affordability of electricity across the nation and does little to address the problem it seeks to solve because merely reducing fossil fuel carbon dioxide emissions without producing a measurable impact on world temperature or climate should not be regarded as a success. The comments show EPA’s plan as proposed will affect Americans negatively with major rate increases in electricity and especially impact U.S. manufacturers, including metalcasting facilities.
The Clean Power Plan would require state governments to implement plans to make steep cuts in carbon emissions (CO2) from existing power plants by 30 percent by 2030 using a 2005 emission level as a baseline and establishes state-specific targets to do so. The proposal will affect all 50 state governments, local governments, utilities, rate-payers, private and public investors (including pension funds), manufacturers, technology companies, public health advocates and various energy production stakeholders.
The final rule is scheduled to be finalized in June 2015, at which point AFS anticipates a serious legal battle to begin. A number of constitutional lawyers noted in their comments that EPA is reaching beyond its constitutional authority and is acting outside the bounds of the law and called for withdrawal of the EPA proposed rule to regulate carbon emissions for existing power plants.
We expect early votes in the House and possibly in the Senate for proposals intended to slow down or outright prevent the EPA from implementing that agenda. Nevertheless, because of the closely divided nature of the Senate, it will be extremely challenging for the 114th Congress to be able to stop administrative action from moving forward on the Clean Power Plan. AFS will continue to meet with lawmakers and congressional staff on the deep concerns regarding these climate rules.