November 8, 2013

VIA ELECTRONIC MAIL AND U.S. MAIL

A. Stanley Meiburg, PhD

US EPA, Region 4

Sam Nunn Atlanta Federal Center

61 Forsyth Street, SW

Atlanta, GA 30303

meiburg.stan@epa.gov

carbonpollutioninput@epa.gov

Re: Carbon Pollution Standards for Existing Power Plants

Dr. Meiburg:

Conservation Voters of South Carolina (“CVSC”) is providing input to the U.S. Environmental 

Protection Agency (“EPA”) on the best Clean Air Act approaches to reducing carbon pollution from 

existing power plants. CVSC is an organization dedicated to making conservation and 

environmental issues a top priority among South Carolina’s elected leaders, political candidates, 

and voters. CVSC takes a great interest in addressing actions that can encourage efficient and clean 

energy generation in South Carolina. We recognize the importance of the President’s Climate Plan 

and its potential impact on our State. CVSC supports EPA’s plans to limit carbon dioxide emissions 

from power plants. We offer the following suggestions. 

1) EPA Should Encourage Energy Efficiency and Renewable Energy

Energy efficiency is South Carolina’s first fuel. CVSC and other groups in South Carolina are 

working at the state level to encourage energy efficiency and renewable energy, but we recognize 

that EPA regulations affect the energy mix nationally. EPA should allow for a flexible system in 

which power plants could use energy efficiency credits to offset carbon dioxide emissions. In its 

proposed emissions guidelines, which President Obama ordered EPA to issue no later than June 1, 

2014,1 EPA should follow the Clean Air Act and federal regulations and issue guidelines that would 

 

1 President Obama to EPA, June 25, 2013, Presidential Memorandum -- Power Sector Carbon Pollution Standards. 

Available at http://www.whitehouse.gov/the-press-office/2013/06/25/presidential-memorandum-power-sectorcarbon-pollution-standards.
Dr. Meiberg

November 8, 2013

Page 2

require sources to use the best system of emissions reductions.2 Considering power plant 

emissions, averaged at the company-wide or state-wide level, in crafting the best system of 

emissions reductions, allows for flexible, cost-effective options.

Allowing for the ability to credit energy efficiency and renewable energy would provide for a cost 

effective way to encourage reduction in carbon dioxide. In order to maximize the impact of the 

renewable energy credits, EPA should limit those credits to supply-side and demand-side energy 

efficiency programs and renewable energy sources such as wind and solar. EPA should ensure a 

diversity of resources are deployed to meet emissions reduction targets and avoid creating

incentives that could result in the existing and planned nuclear development in South Carolina to 

swamp potentially available credits for energy efficiency and renewable energy.

The Natural Resources Defense Council (“NRDC”) roadmap for complying with the existing source 

requirements of the Clean Air Act included extensive cost analysis that demonstrated that 

providing credits for energy efficiency and renewable energy, as a part of a larger trading 

program, would have societal benefits as much as fifteen times greater than compliance costs.3

Encouraging energy efficiency and renewable energy would also reduce the amount of natural gas 

replacing reduced coal generation. Increasing reliance on natural gas plants, even efficient 

combined cycle turbines, still presents a number of environmental and rate payer related 

challenges. These plants emit carbon dioxide and ozone-forming oxides of nitrogen; the 

historically volatile price of natural gas suggests that ratepayers could face cost increases; and

EPA must consider the environmental impacts from accessing shale gas when creating programs 

that could encourage natural gas use. 

2) EPA Should Work Closely With Stakeholders to Implement the Standards

CVSC appreciates the EPA’s extensive and unprecedented early outreach before it even proposes 

the standards for existing power plants. The eleven public listening sessions allowed EPA to hear a 

wide variety of perspectives before the formal rulemaking process begins. CVSC recommends that 

EPA continue this work, including outreach to environmental organizations, and the states that 

will implement the standards for existing power plants. With the state plans due in June 2016, one 

year after EPA issues final standards,4 EPA could help with these urgent state plans by providing 

technical assistance to stakeholders. Open data on emissions inventories, webinars, and modeling 

support would assist stakeholders with these vital plans. 

 

2 42 U.S.C. § 7411(a)(1) (2006) and 40 C.F.R. § 60.22(b) (2011).

3 NRDC, March 2013, Closing the Power Plant Carbon Pollution Loophole: Smart Ways the Clean Air Act Can Clean Up 

America’s Biggest Climate Polluters, Available at http://www.nrdc.org/air/pollution-standards/files/pollutionstandards-report.pdf.

4 President Obama to EPA, June 25, 2013, Presidential Memorandum -- Power Sector Carbon Pollution Standards. 

Available at http://www.whitehouse.gov/the-press-office/2013/06/25/presidential-memorandum-power-sectorcarbon-pollution-standards. 
Dr. Meiberg

November 8, 2013

Page 3

3) EPA Should Provide Bounded Flexibility for State Plans

The structure of Clean Air Act 111(d) provides for states to take the lead on implementation. Like 

with State Implementation Plans under Section 110 of the Clean Air Act, the state plans for carbon 

dioxide from existing power plants allow for differences in energy mixes and state energy usage. 

EPA however has the responsibility to ensure that state plans comport with its emissions 

guideline.

5 A patchwork of highly variable plans would be inefficient and cumbersome. CVSC 

recommends flexibility, within the bounds set by the EPA guidance document. 

Recognizing the unique attributes of states, within EPA guidance, will allow for the most effective 

environmental protections. In the case of South Carolina, unscrubbed coal plants have closed or 

will close in the next few years. Scrubbed coal plants, natural-gas-fired combined cycle turbines, 

and nuclear plants will compose much of the baseline generation for South Carolina. However 

offshore wind and solar are on the horizon, and EPA guidance should encourage the development 

of these renewable resources. 

CVSC appreciates EPA’s consideration of these comments, and we look forward to working with 

EPA on implementing climate plans in South Carolina. If you have any questions, please feel free to 

contact me by email at ann@cvsc.org or by telephone at (803) 799-0716.

Sincerely yours,

Ann Timberlake

Executive Director

Conservation Voters of South Carolina

Hamilton Davis

Coastal Conservation League

Ben Gregg

South Carolina Wildlife Federation

 

5 40 C.F.R. § 60.22(b)(5) (2011).