BCSE Statement: Proposed Carbon Pollution Standard for New Power Plants 

May 24, 2012 

Thank you for the opportunity to participate in this public hearing. My name is Lisa 

Jacobson and I am the President of the Business Council for Sustainable Energy. 

The Council is a coalition of companies and trade associations from the energy 

efficiency, natural gas and renewable energy sectors. 

Our coalition also includes independent electric power producers, investor-owned 

utilities, public power, commercial end-users and project developers and service 

providers for environmental markets. 

The Council was founded in 1992 and advocates for policies that increase the use of 

commercially-available clean energy techno:ogies, products and services. 

Our diverse business membership is united around the revitalization of our economy 

and the creation of a secure and sustainable energy future for America. 

I want to communicate five things to you this afternoon: 

First, BCSE believes that energy efficiency, renewable energy, and natural gas will be 

able to help our nation reduce emissions, grow the economy, create jobs and 

strengthen our energy system -- in addition to being cost-effective compliance options. 

Second, we support the science underpinning the greenhouse gas endangerment 

finding and EPA's continued use of section 111 of the Clean Air Act to regulate 

greenhouse gas em1ssions. 

That said, we believe the optimal policy for regulating greenhouse gas emissions is for 

Congress to enact a comprehensive market-based program that allows for flexibility and 

cost-effective emissions reductions, including carbon offsets. 

Third, in evaluating EPA's proposal, we applaud the Agency for adopting an outputbased approach. As we communicated to EPA in past comments, the Council has long 

supported the development and use of output-based emissions regulations as effective 

ways to enhance air quality and encourage cost-effective and efficient emissions 

reductions. The best way to limit emissions and to drive technological innovation is to 

ask facilities to produce more useful output per unit of pollution. 

Fourth, building on this positive step for energy efficiency, EPA has an opportunity in the 

carbon pollution standa1·d to encourage clean and efficient combined heat and power 

1620 Eye Street NW Suite G0"1 VVashington, DC 20006 p: 202.785.0507 ~ f: 202.785.0514 ~ http://www.bcse.org 
and waste heat recovery. The proposal asks for comments specifically on CHP. We are 

working with our members to suggest ways EPA could better account for and 

encourage useful heat output from CHP units to help comply with the proposed 1000 

pounds of C02 per megawatt hour standard. 

There are also possibilities to credit onsite use of CHP-generated electricity with 

avoided line losses, which can be quite high at times of peak demand. Today, in EPA 

Public Hearing in Chicago on this proposed standard, BCSE Board member Recycled 

Energy Development is speaking on these exact issues and we urge you to take its 

recommendations into consideration. 

Finally, over the past two years, there have been discussions on how EPA might guide 

the states in regulating existing sources through this NSPS. BCSE urges you to keep 

this in mind in finalizing the Carbon Pollution Standard for new sources and devising the 

federal guidelines that states must follow in their plans to cover existing power plants, 

under section 111 (d). 

BCSE supports an approach that allows states and tribes to show achievement of 

equivalence with prospective federal Clean Air Act Section 111 (d) requirements through 

their own and cooperative regional climate, clean energy, and energy efficiency 

programs and policies. 

To that end, EPA should establish the minimum stringency states must meet but allow 

states the flexibility to achieve greater reductions. For example, flexible market-based 

programs that allow for carbon offsets and emissions trading can drive down emissions 

at lower cost and encourage over performance with reduction targets. This is a 

complicated issue, but it's essential that facilities not face double regulation and that 

existing programs that work are allowed to continue achieving emissions reductions at 

low cost while spurring clean energy development. 

Again, thank you for this opportunity to speak with you today. The Council will work with 

its members in the coming month to submit full written comments on the proposed 

standards and we look forward to submitting them to you for your full consideration.