Summary	of	Region	6 Public	Listening	Session	

on	111(d)	for	Power	Plants

November 7, 2013 – Dallas, TX

On November 7, 2013, EPA Region 6 held a public listening session to obtain public input on how EPA can craft 

carbon pollution standards from existing power plants. Approximately 400 people attended the meeting, and of 

those attendees, 222 people spoke. 

A high-level summary of the meeting is provided below. 

Overview

Regional Administrator Ron Curry and Deputy Regional Administrator Sam Coleman welcomed participants and 

offered opening remarks. There were two, concurrent sessions. Wren Stenger, Director of the Multimedia 

Planning and Permitting Division, and Tom Diggs, Chief of the Air Programs Branch, offered an overview of Clean 

Air Act section 111(d). Trained facilitators moderated the sessions.

Of the total participants at the listening session, approximately 42% represented themselves or nongovernmental organizations (NGOs) other than specifically environmental, 38% represented business and 

industry, 12% represented environmental NGOs, 6% represented government, and 2% represented unions.

Participants included Texas House representatives, companies, industries, local officials, municipalities, small 

businesses, churches, environmental groups, NGOs, citizens, and college students.

We heard from local governments and citizens that they support power plants in their communities for the 

economy, jobs, emergency services, fire departments, and schools. Solar and wind companies and specialists 

advised that energy portfolios should continue to expand to include renewables at paces from immediately and 

exclusively to a moderate incorporation time frame. The Dallas County Medical Society supported EPA creating 

stringent carbon emission standards due to asthma, cancer, and sensitive populations. (In October, the DCMS 

petitioned the TCEQ for more stringent air emission controls for three coal-fired power plants.) 

Many electric cooperatives stated that doing anything that impacts electric costs, reliability, and capacity would 

devastate towns and communities across Texas. Some college students and youth organizations stated that EPA 

needs to shut down coal power plants now or implement very strict limits. Some churches, ministries, and 

preachers said that EPA must take care of the earth and the health of people. People with sick spouses, 

children, and friends implored EPA to control air emissions. Suggested approaches for future guidelines 

included market-based, carbon tax or fee with the tax/fee returned to consumers, state-by-state plans not onesize-fits-all, and enforcement that would actually reduce emissions.

Naturally, there were positions on the both ends of the discussion. First, the environmental groups asked that 

EPA proceed without delay to implement strict emission standards or to shut down all coal power plants. A few 

speakers suggested that paying more for electricity would be acceptable to them. Second, some electric 

cooperatives and industry representatives discussed the importance of keeping electric costs low, considering 

the extreme differences in Texas weather and rural areas than in other parts of the country, and keeping the 
economy healthy and growing. Most of the speakers that were citizens or had small businesses near coal power 

plants encouraged EPA to proceed carefully so as not to impact jobs, towns, and people’s livelihoods. Third, 

speakers expressed the importance of balance between the environment and the economy as EPA develops its 

position. The importance of affordable electricity, capacity, and reliability for now and into the future must be 

maintained for states to grow and prosper. Most speakers wanted good air quality, but cautioned that a rash 

approach would be more harmful to people than a more flexible, long term plan. Some speakers wanted to shut 

down all use of coal and fossil fuels. Some recognized that facilities were old and should be shuttered, while 

others offered that older facilities should be allowed to continue for their design life. Speakers questioned both 

the “junk” and “good” science as the foundation for climate change.

Speakers generally thanked EPA for the opportunity to provide input at this early stage and asked that EPA keep 

the public involved. It was suggested that public stakeholders be included in a workgroup or team that will draft 

the guidelines.

The following summary is divided into two parts: a summary of comments generally supportive of the proposed 

carbon standard and a summary of comments generally in opposition to the proposed carbon standard. In each 

part, the comments are included under general category topics. Language of the commenters is frequently 

included In order to capture the essence of their concerns. 

 

Comments generally in support of EPA’s proposed carbon standard for existing power plants

Health concerns

 Human health is more important than jobs or economics, and global warming is a human health threat. 

Climate change is happening and will get worse. Asthma and lung cancer are related concerns. Coal is 

not a fuel the U.S. should be investing in for the future; coal plants will adapt, but children and 

grandchildren will not. 

 Diseases are likely to increase due to increased heat from climate change. 

 Emissions from power plants particularly impact poor, minority neighborhoods. Consider environmental 

justice in decision-making for the carbon standard.

Other implications of climate change; climate change science 

 Climate change is causing drought and raising costs in health care and food. 

 Extreme weather is being caused by climate change, including tornadoes and flooding; climate change is 

causing at least a 33% increase in weather damage. Summer 2011 drought and wildfires in Texas and 

2013 floods are examples.
 EPA should follow the science and make strong rules for existing power plants. Science findings are 

definite. If we can keep CO2-e concentrations under 450 parts per million, then we may have a 50-50 

chance of avoiding the worst climate change impacts. Invest in clean air. Gas-fired power plants are 

better. Support the President’s Climate Plan.

 We are facing a human civilization crisis due to climate change. Small towns will be without water in 3-5 

years, 50% of reservoirs are less than 50% full, NOAA in 2009 said current climate changes are reversible 

only in 1000 years, and 2060 temperatures will be 4 degrees C above pre-industrial baseline. Climate 

change has created refugees, with 600 million expected by 2050. Do something now. EPA must be true 

to its mission. This is a national problem, not just a local problem.

Proposed carbon standard and other regulatory actions

 EPA regulations should aggressively reduce greenhouse gas emissions. Export of coal to other nations is 

not desirable as it only transfers the problem of coal elsewhere. However, carbon standard application 

should not be done arbitrarily and should minimize financial harm and electricity rate increases. 

Incentivizing power plants to reduce emissions is good. Also, EPA should allow for regional flexibility.

 Regarding the proposed carbon standard, speakers mentioned that EPA should give States emissions 

credit for work their Public Utility Commissions and Departments of Environmental Quality have already 

done to encourage lower-emitting and renewable energy sources. They also suggested EPA use a 2005 

baseline for carbon reduction calculations.

 We need to be entirely rid of fossil fuels. Set a shutdown date for coal plants. Coal plants have an 

efficiency of 32% and similar to that of the 1970s. Recent air pollution episodes in China demonstrate 

the importance of dealing with emissions from coal plants.

 A carbon tax is a good idea; stop subsidies to coal, oil and gas industries. Clean air is actually good for 

business.

 Texas leads the nation in carbon emissions; action needs to be taken in Texas in particular.

Alternative energy

 Alternative energy, such as solar and wind, and hydrogen and energy efficiency should be encouraged 

and are allies to EPA in this carbon standard process; no nuclear plants. Decentralized energy 

production would be more beneficial. Transitioning to clean energy will create jobs.

Jobs 

 Loss of jobs is not as big an issue as some industries are touting; also, such losses are not necessarily 

related to a carbon standard. Texas’ biggest power company already is getting ready to file for 

bankruptcy and is worried it won’t be able to take care of its workers.
Other pollution and sources

 Other sources, such as fracking, also contribute to greenhouse gas emissions.

 Other pollutants besides carbon dioxide are important and should also be addressed – such as methane, 

mercury, ozone, particulate matter. Dallas-Fort Worth area ozone is worsened by coal plants. Many 

people are affected by those health effects. Also EPA needs to be concerned about clean water.

Overall concern

 Our moral responsibility is not to exploit the Earth but to care for it.

Comments generally in opposition to EPA’s proposed carbon standard for existing power plants

Impacts on the economy and jobs

 Carbon standards for existing coal-fired plants will bring severe economic hardship to towns that 

depend on them for property tax (37% of one county’s taxes is paid by the local coal-fired power plant), 

direct employment in power plants and coal mines (these are high-paying jobs in rural areas), sales 

taxes, and ancillary employment in smaller companies. Housing prices are directly associated with 

availability of these jobs. Local public schools and hospitals are supported by these taxes as well. Many 

of these areas are just now emerging from the 2008-2010 economic recession.

 The rule should find ways to save jobs that are imperiled by the new standard, and Texas will need more 

time to comply.

 Municipal power agency in Texas is voluntarily reducing carbon emissions without regulation; coal-fired 

electricity is cheap power, and this agency has been operating for 30 years but is still paying off debt and 

the other air pollution control equipment. Rush to a carbon standard may well imperil financial status of 

this municipal power agency.

Technology required under the proposed standard and practicality

 Carbon capture and storage (CCS) will be necessary for coal plants, and this is not commercially 

practical. No coal-fired plants will ever meet a CCS requirement.

 New carbon standard will not be achievable or sensible. EPA should carefully consider the liabilities of 

this rulemaking. There could be considerable, unintended consequences.

 EPA’s role is to control pollutants, not to force specific technologies. Any proposal should be subject to 

strict cost/benefit analyses.
 The U.S. needs China and India to join in on a carbon pollution solution. While energy efficiency is a 

good idea, imprudent solutions that result in tens of thousands of megawatts in coal-fired electricity 

generation being lost in the U.S. are not the answer. Rule should encompass all environmental impacts, 

and EPA should not rush the rule-making.

Electricity prices

 Cost of electricity for all consumers will increase (including economically impoverished families), as well 

as on other industries that produce goods for people, thereby raising prices on those goods. The 

standards will also negatively impact reliability and safe, cheap generation in the entire grid.

 Rural consumers of electricity, who are typically less prosperous than urban dwellers, will bear much of 

the economic burden for this standard. 70% of electricity from rural electric cooperatives comes from 

coal. Fuel-switching is not a practical alternative for many of these rural cooperatives. EPA should 

particularly focus on impacts on rural electric cooperative operators. There may be a 40% increase in 

annual consumer electricity prices for rural electric cooperative customers with this standard.

Need for electricity reliability and balanced energy portfolio

 EPA should promote diversity in electricity production and not create one law for all the States that does 

not distinguish among differences in the states. Coal and nuclear should be parts of that portfolio. Coal 

should remain the major way to generate electricity.

 Texas needs a balanced energy portfolio, as it is growing very rapidly. For example, shale gas 

production, which is a State-wide economic driver, relies on availability of cheap electricity. Reliability is 

a big concern, and blackouts may result with closing coal-fired plants. By 2018, Texas will fall below its 

reserve margin target under a moderate growth scenario, so a balanced energy portfolio is essential.

Need for flexibility and market-based alternatives

 States need to be given the maximum amount of flexibility in complying with any such carbon standard. 

For example, states should be allowed to take credit for renewable energy resources. Perhaps EPA 

should allow states to develop their own guidelines and be allowed deviations from these.

 Employing market-based alternatives in any rule is very important. Carbon should be controlled more 

thoroughly where the costs are less expensive rather than at facilities where it would be more 

expensive. 

 If this rulemaking goes forward, EPA should use accurate baselines and ensure states receive credit for 

early actions.

 The Clean Air Act is not the appropriate means with which to reduce greenhouse gas emissions. EPA 

should set emission targets on what is reasonably defensible. Consider grandfathering too.
Climate science and the role of greenhouse gases

 State of the science: Recent paper in Climate Dynamics by Wyatt (University of Colorado) and Curry 

(Georgia Tech) shows that the dynamics of global climate is such that there are 300-year natural cycles 

and much of climate variability is due to this, not greenhouse gas emissions. The Wyatt-Curry paper 

accounts for the current 17-year “lack of global warming.” Don’t rush into rule changes, but focus on 

knowing science better. The current models EPA relies on don’t seem to reflect reality.

 Greenhouse gases are beneficial to the Earth and are not problem-causers.