Remarks 

Submitted on behalf of the 

Pennsylvania Chamber of Business and Industry 

 

DEP Listening Session on EPA’s Proposed CO2 Emissions Rule for 

Modified, Reconstructed, and Existing Power Plants 

Presented by: 

Shawn Good 

Director, Government Affairs 

Harrisburg, PA 

December 16, 2013 

417 Walnut Street 

Harrisburg, PA 17101-1902 

717.720.5443 phone 

http://www.pachamber.org 

 
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 Good afternoon. My name is Shawn Good, Director of Government Affairs for the 

Pennsylvania Chamber of Business and Industry, the largest broad-based business 

advocacy association in Pennsylvania. The Pennsylvania Chamber represents 

thousands of businesses from all industry sectors and of all sizes, from sole 

proprietorships to Fortune 100 corporations. The Pennsylvania Chamber would like to 

thank the DEP for inviting us to provide remarks to this listening session on the EPA’s 

proposed standards, regulations, or guidelines that address carbon emissions from 

modified, reconstructed, and existing power plants under Section 111(d) of the federal 

Clean Air Act. 

 Even though the Pennsylvania Chamber believes that the issue of carbon emissions 

needs to be addressed more globally--especially given that more and more of the 

world’s emissions of carbon dioxide are coming from developing countries and fewer 

are coming from developed countries, including the United States--we understand that 

reality dictates that the current EPA has every intention of proceeding with this 

proposed rule on power plants next year and into the foreseeable future, and we truly 

thank the DEP for being proactive in its outreach to the regulated community regarding 

this matter. With that in mind, I would like to convey the following points and ask that 

they be incorporated into the DEP’s vetting and analysis of the proposed CO2 

emissions regulation on modified, reconstructed, and existing power plants. 

 First, we ask that the DEP seriously and thoroughly consider the economic impact of 

this proposed regulation on electric generation units. We would ask that you evaluate 

this impact in the context of current marketplace conditions of Pennsylvania’s electric 

generation industry and the existing regulations and mandates to which this industry is 
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subjected. In addition, the DEP should take into account the emissions reductions 

already achieved by the electric generation industry in sulfur dioxide, nitrous oxide, 

particulate matter, and, of course, carbon dioxide. Projected CO2 emissions reductions 

by the industry in the near future under current federal and state environmental rules 

should be also considered. 

 Second, we ask that you consider the financial impact on manufacturing, industrial, 

and commercial users of electricity. There is a very strong likelihood that this proposed 

regulation will translate into higher electricity rates for our members who use 

electricity—from large industrial users to small businesses. So, we ask that the likely 

costs of this proposed regulation to the end users be considered seriously by the DEP 

during the development of its Section 111(d) State Plan. 

 Third, as alluded to earlier, the Pennsylvania Chamber has not come here today to 

debate whether there should be a CO2 emissions regulation for existing power plants. 

However, we are concerned that requiring our state’s power plants to comply with an 

additional regulation, especially in light of the recently announced closings of coal-fired 

power plants in the state, may make it more difficult for them to generate the amount of 

electricity that is necessary to ensure grid reliability, which, of course, is very important 

to our members both big and small. So, we ask that you consider this proposed 

regulation’s impact on the reliability and sustainability of our electricity grid. 

 Fourth, we ask that the DEP work with the EPA to ensure that this proposed 

regulation provides for enough flexibility in terms of compliance and that the 

technologies, practices, and methods required are truly achievable, practical, and 

commercially viable. In addition, we would ask that the science used in the proposed 
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rule be sound, verifiable, and inclusive of a variety of sources, including those that may 

counter the scientific findings of the EPA as they relate to this proposed regulation. 

 In closing, I would like to stress that abundant, reliable, and competitively priced 

energy production and delivery are critically important components of a healthy and 

robust economy. A lack of these components would significantly hamper the 

Commonwealth of Pennsylvania’s ability to attract and retain businesses. We ask that 

you keep this fact in mind as well as the need to balance environmental protection with 

economic development as you are developing your State Plan. Again, I want to thank 

the DEP for soliciting input from the regulated community on this proposed regulation 

well in advance of it being issued by the EPA in June 2014, and I welcome any 

questions that you may have.