December 1, 2014

The Honorable Gina McCarthy

Administrator

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Re: Docket ID No. EPA-HQ-OAR-2013-0602

Dear Administrator McCarthy:

The United States Conference of Mayors and the National League of Cities strongly support the 

U.S. Environmental Protection Agency’s (EPA) Clean Power Plan Proposed Rule on Carbon 

Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating 

Units. We appreciate the opportunity to submit comments as the agency develops a national 

policy to reduce greenhouse gas emissions. 

The Need

The National Climate Assessment released earlier this year showed that all parts of the country 

are currently experiencing impacts of climate change, such as extreme weather events, changes 

in precipitation, higher temperatures, sea level rise, wildfires, droughts and flooding. As the 

nation’s two preeminent organizations representing U.S. cities and towns, we are deeply 

concerned about these growing negative impacts of climate change upon our cities, which 

represent a clear, imminent and real danger to our communities. 

According to the International Panel on Climate Change Fifth Assessment Report, if we act now 

to limit greenhouse gas emissions, the world has a 66 percent chance of avoiding the critical 

threshold of a 2 degree Celsius warming of the planet. Delaying action will result in technical, 

economic, social and institutional challenges for the 21st Century that may be extremely difficult 

and expensive to overcome. Moreover, the costs of inaction will greatly outweigh the costs of 

taking action today. 

Given these findings, our country cannot afford to avoid action on limiting greenhouse gas 

emissions. This is no longer just a national and global issue; it is a local one that will determine 

the future of our communities and their economies. Beyond moving quickly to finalize a national 

plan for reducing greenhouse gas emissions, we encourage EPA, other federal agencies, and 
Congress to provide additional incentives to states, local governments, and utilities to help them 

move as quickly as possible in implementing their greenhouse gas reduction actions.

Overall Response to the Clean Power Plan

We applaud EPA’s recognition and acknowledgement in the Clean Power Plan that a “one size 

fits all” model will not promote the creative and innovative thinking necessary to dramatically 

reduce greenhouse gas emissions. We support the flexible approach that the Clean Power Plan 

outlines that would allow states to determine their own best method for meeting the emissions 

reduction targets. Utilities should be encouraged to work with their states, local governments, 

and businesses to implement strategies that work in their region. 

As the proposed rule allows, utilities should be encouraged to not only invest in more renewable 

energy sources, but also to recognize the value of “outside the fence” plans that promote a more 

comprehensive and sustainable approach to emissions reductions, such as energy conservation

strategies. As proven in California, utility efforts to fund increased energy efficiency in new and 

existing buildings and homes has yielded significant lower rates of energy usage. 

In addition, EPA should ensure that local governments are afforded sufficient opportunity for 

input into the development of state implementation plans in order to promote cooperative 

initiatives, but also to avoid the shifting of cost burdens to local governments through unfunded 

mandates. 

Specific Comments

We agree with EPA that emission limitations are to be measureable (quantifiable) and verifiable 

in terms of real reductions in GHG emissions from existing generating units. While we applaud 

and support flexibility in meeting such reductions through the four “building blocks” as proposed

(make fossil fuel plants more efficient, use low-emitting power sources, use zero- and lowemitting power sources, and use electricity more efficiently), the rule must ensure that such 

reductions are real and absolute in value. For example, because it is likely that much of the 

emission reductions will be the result of fuel switching from coal to natural gas, we believe 

utilities should be required to take into account additional emissions of greenhouse gases (i.e.

methane) from the extraction and transport of natural gas in their calculations of net emission 

reductions.

We also expect that the rule, when adopted, will bring institutional focus and cooperation to the 

task of GHG reductions. State Implementation Plans should include strong commitments and 

actions from utilities to the broad range of energy efficiency and renewable energy development, 

as long as such efforts meet stringent tests of measurement and verifiability. The utility sector, 

in the end, represents the strongest institutional entities to re-shape the nation’s energy system in 

ways that are innovative, cost-efficient, and in the long-run significantly less reliant on GHG 

emitting fuels.

We also agree with EPA that if reductions are to be counted in State Implementation Plans, 

utilities should provide evidence of long-term sustainable funding to ensure that such reductions 

are properly implemented over time. 
In addition to the options outlined in the proposed rule, we strongly encourage EPA to recognize

that the energy that is produced from reusing Municipal Solid Waste, which diverts waste from

landfills, should be considered a renewable energy source. According to EPA’s own studies, 

methane “is the second most prevalent greenhouse gas emitted in the United States from human 

activities” with landfills accounting for 18 percent. It is imperative that if we are to meet our 

greenhouse gas emission goals, we need to look comprehensively at the options that are before 

us, including waste-to-energy facilities.

In closing, we thank EPA for its leadership on this issue and for putting forth this proposal. It is 

vitally important that we waste no further time on debating the importance of this issue, but 

rather act swiftly and move forward in a comprehensive manner. Thank you for this opportunity 

to offer our support and comments. If you have any questions, please do not hesitate to contact 

our staff: Judy Sheahan, The U.S. Conference of Mayors (jsheahan@usmayors.org or 202-861-

6775) and Carolyn Berndt, National League of Cities (Berndt@nlc.org or 202-626-3101).

Sincerely, 

Tom Cochran Clarence Anthony

CEO and Executive Director CEO and Executive Director

The U.S. Conference of Mayors National League of Cities