Summary	of	Region	2	Public	Listening	Session	

on	111(d)	for	Power	Plants

October 23, 2013 – New York, NY

On October 23, 2013, EPA Region 2 held a public listening session to obtain public input on how EPA can 

craft carbon pollution standards from existing power plants. Approximately 178 people1attended the 

meeting, and of those attendees, 91 people spoke. A vast majority of speakers supported EPA efforts. 

They voiced support on current EPA efforts to reduce criteria pollutants, the proposed carbon standards 

for new power plants, and the upcoming guidelines for existing plants. Many of the speakers thanked 

EPA for allowing them to speak during the listening sessions.

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

Overview:

EPA Region 2 Regional Administrator Judith Enck provided opening remarks for both listening sessions. 

John Filippelli, Director of the Clean Air and Sustainability Division in Region 2, also provided remarks 

and moderated. 

The audience was made up of representatives from industry, unions, citizens, academics, scientists, 

environmental support groups, attorneys, students, and press. Some of the organizations that were 

present included: Natural Resources Defense Council, American Petroleum Institute, Sierra Club, New 

York Public Interest Research Group, Environment NY, the Adirondack Council, West Harlem 

Environmental Action, Utility Workers Union, and National Rural Electric Cooperative Association. Jared 

Snyder, Assistant Commissioner of the New York State Department of Environmental Conservation

(NYSDEC), attended and spoke at the morning session. While a majority of speakers pre-registered to 

speak during the listening sessions, there were a handful of speakers who only planned to listen in but 

were inspired by others to also speak. Written statements were received along with books, pamphlets, 

drawings, and CD’s. A majority of the written statements received were copies of the speakers’ notes.

Support for Carbon Pollution Control for Power Plants

Speakers overwhelmingly supported carbon pollution controls for power plants. There was support 

voiced for a national control strategy for power plants, while a smaller number believed that control 

strategies should be implemented regionally, by state, or internationally. Several speakers also wanted 

strong verification and compliance guidelines to be included with control strategies. Carbon capture 

and storage was mentioned by a few of the speakers as a means for controlling emissions. 

A number of speakers asked EPA to considerer the cumulative impact of power plant emissions and not 

just focus on GHGs when setting guidelines. The other impacts that speakers discussed included 

emissions of other pollutants and energy and water use.

 

1

Note: The number of speakers who supported each of the issues outlined here was not quantified because some speakers 

spoke on multiple topics and comment cards and notes were received without authors. Due to these reasons it was not 

possible to distinguish new individual comments without double counting. Anonymous comment cards were also considered 

“speakers” in this summary. 
There were only a few speakers who discussed emissions limits or goals. One speaker supported output 

based standards and one speaker supported a mass based standard. A few speakers wanted carbon 

emissions goals to be at levels that would meet the IPCC’s most stringent stabilization scenarios which

required CO2 emissions to decline to less than 50% of today’s emissions by 2050.

Criticism of EPA Efforts

There were a few speakers that did not support carbon pollution control for existing power plants. 

Those individuals believed that EPA did not have the authority to regulate carbon pollution from power 

plants and that reductions from power plants would not help to mitigate climate change issues. At least 

one speaker specifically stated that section 111(d) of the Clean Air Act was not an authorized approach 

for regulating greenhouse gases from power plants. Several speakers thought EPA’s efforts were not 

stringent enough or taking place quick enough.

Carbon pollution controls for other sources

Some speakers who supported carbon pollution control for power plants also emphasized that there are 

other emission sources they would like to see controlled. Other sources that were discussed include 

emissions from biomass energy and the transportation sector.

Support for the Regional Greenhouse Gas Initiative (RGGI) as a compliance mechanism for 111(d) 

plans

RGGI is a market-based regulatory program which northeastern states participate in to reduce 

greenhouse gas emissions. RGGI was the most often discussed mechanism for complying with carbon 

pollution 111(d) plans. NYSDEC spoke about its participation and other speakers expressed its support 

for EPA guidelines that were based on RGGI. NYSDEC had a few points to share about its experience and 

observations in being involved with RGGI.

 Emissions reductions in the power sector are best accomplished through energy 

efficiency/renewable energy and more efficient power plants

 RGGI states demonstrated the feasibility of reducing emissions 50% in the power sector while 

continuing to have economic growth;

 A cap and trade system is a robust system to monitor compliance. Emissions rate requirements

should be translated to a mass based standard;

 Compliance should not be based on state boundaries, but rather based on geographies followed 

by the grid to recognize generation by more efficient plants;

 States who have accomplished reductions under RGGI should be treated in an equitable way in 

any new program.

RGGI was touted as a successful carbon pollution mechanism that should be used as an example for the 

rest of the country.

Do not penalize early emissions reductions

Several speakers noted that the northeastern US (RGGI participating states) has already been regulating 

carbon emissions and that their efforts should be accounted for. Guidelines for 111(d) plans should take 

this into account so that a disproportionate burden (economic) would not be placed on these early 

adopters when there are areas of the country that have not previously adopted carbon pollution 

emissions reduction measures.
Consideration of regional compliance instead of by state

One notable suggestion by speakers was to consider how the electric grid is constructed geographically 

instead of determining compliance using state boundaries. This could provide a more meaningful and 

effective way to reduce carbon pollution since it would more accurately reflect how the electrical grid 

operates and recognize already efficient power plants.

Timing

A number of speakers who supported EPA efforts also voiced that they wanted EPA to act as quickly as 

possible. 

Superstorm Sandy

The majority of those in attendance were from the NYC metro area which continues to recover from the 

impacts of Superstorm Sandy. A large number of speakers discussed their experiences during the 

Superstorm and the long recovery period in which many were without electricity and fuel. There were 

discussions of lack of heat and loss of ability to perform essential tasks such as living in tall buildings in 

which elevators had no power. The lack of elevators posed issues with those whose mobility is impaired

and had difficulty performing tasks such as bringing food up several flights of stairs. Speakers who 

discussed Superstorm Sandy stressed that regulation of GHG’s was needed so that they would not be 

impacted by climate change related storms in the future.

Health Concerns

There were a number of speakers who discussed their concerns with health effects related to air 

pollution. Though not necessarily focusing on GHGs, the speakers talked about the respiratory health of 

family, friends, and themselves. Speakers noted that they felt that they knew too many people with 

asthma and that those with asthma cited increased medicine use. Speakers called for reductions in 

emissions from the power sector.

Natural Gas

There were two sides to the discussions involving natural gas. There were many proponents of moving 

away from coal for power and toward cleaner fuels (such as natural gas). Some speakers recognized 

natural gas as a bridge fuel to a lower/zero emissions future.

There was also a set of speakers who spoke out against natural gas and hydrofracking. There were 

concerns regarding the safety and environmental effects of extracting natural gas. Other speakers did 

not believe that switching to natural gas as a energy source would help reduce GHG emission to levels 

prescribed by studies (such as the IPCC and WHO) because GHGs would still be emitted when 

combusted.

Energy Efficiency and Renewable Energy 

Most of the speakers at the listening sessions supported increasing the generation and use of renewable 

energy. Several speakers believed that moving to renewable energy would be economically beneficial 

by creating new jobs. Renewable energy was also the preferred source of power for many speakers who 

stated that they wanted the country to move completely away from using fossil fuels.
Generally if a speaker discussed renewable energy, they also wanted increases in energy efficiency for 

multiple sectors. The three most mentioned sectors were power plants, existing buildings, and new 

buildings. Some speakers wanted more energy efficient building codes for new buildings.

Economic impacts

A few speakers discussed the economic ramifications of carbon pollution guidelines. Some spoke of 

positive impacts gained from new technology and industry. Others spoke of the costs avoided (such as 

repair costs associated with Superstorm Sandy) as positive economic impacts from regulating carbon 

pollution from power plants. There was also a representative from a coalition of small businesses who 

spoke of the positive economic impacts. 

The representative from the American Petroleum Institute believed that there would be negative 

economic consequences from regulations and that EPA lacked the authority to regulate power plants. A 

representative from Utility Workers Union of America spoke about how regulating existing power plants 

were going to harm workers at coal fired plants by causing job losses. The representative asked for 

support in retraining of workers who would be negatively impacted. It was suggested that funding for 

retraining workers be factored into regulations (such as an additional fee or tax).

Some speakers acknowledged the possibility that there may be increased costs associated with limiting 

carbon pollution from existing sources but dismissed costs as a valid reason for not regulating power 

plants. They reasoned that the cost of compliance is insignificant when compared to the far more 

significant costs associated with climate related weather events, and that there could not be a price put 

on clean air. A small number of speakers cited that the industry still profited and existed after other 

control measures were put into place for other pollutants so that there is no reason that the industry 

could not adapt to regulating carbon pollution.

Underrepresented Populations

A small set of speakers emphasized that carbon pollution guidelines and initiatives should take into 

account environmental justice communities. These communities may bear a disproportionate amount 

of burden. In the case of carbon pollution and climate change, without limits to power plant emissions 

these communities may be the worst impacted by events such as Superstorm Sandy.

Consider electrical cooperatives

A representative from the National Rural Electric Cooperative Association emphasized that EPA needed 

to account for electrical cooperatives as guidelines are crafted. They may be involved in future 

emissions reduction programs but are smaller and have different issues than larger corporate run 

entities such as only owning a limited percentage of generating capacity at a power plant.