## 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 people 1 attended 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 upcom ing 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 open ing 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, sci entists, 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), attend ed and spoke at the morning session

. While a majority of speakers pre

- registered to speak d uring the listening sessions, there were a handful of speakers who only planned to listen in but were inspired by others to also speak. W ritten 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 small er number believed that control strategies should be implemented regionally, by state, or internationally. Several speakers also wanted strong verificat ion 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 pla nt emissions and not just focus on GHGs when setting guidelines. The other impacts that speakers discussed include d 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 distinguis h 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 level s that would meet the IPCC’s most stringent stabilization scenarios which required CO 2 emissions to declin e 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. Emission s 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 reduction s 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 em issions reductions**  Several speakers noted that the northeastern US (RGGI participating states) ha s 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 previous ly 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 h ow the electrical grid operates and recognize already efficient power plants. **Timing** A number of speakers who supported EPA efforts a l so 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 s peakers discussed their experiences during the Superstorm and the long recovery period in which many were wit hout 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 an d 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

. **H ealth Concerns**  There were a number of speakers who discussed their concern s 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. Speake rs 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 b ridge 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 e nergy 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 inc reasing 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 fuel s
.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 sm all 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 negat ively 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 pol lution from existing sources but dismissed costs as a valid reason for not regulat ing 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 amo unt 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 issue s than larger corporate run entities such as only owning a limited percentage of generating capacity at a power plant

.