Summary	of	Headquarters Public	Listening	Session	

on	111(d)	for	Power	Plants

November 7, 2013 – Washington, D.C.

On November 7, 2013, EPA Headquarters held a public listening session to obtain public input on how 

EPA can craft carbon pollution standards from existing power plants. Approximately 500 people 

attended the meeting, and of those attendees, 243 people spoke. Of the speakers, a majority were in 

favor of EPA moving forward with greenhouse gas rules for existing power plants. 

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

Overview:

Acting Assistant Administrator for the Office of Air and Radiation Janet McCabe and Joe Goffman, Senior 

Counsel for the Office of Air and Radiation provided opening remarks. John Millet and Paul Gunning of 

the Office of Air and Radiation described how Clean Air Act section 111(d) has worked in the past and 

moderated the session.

Speakers included and represented members of Congress, public officials, industry representatives,

faith-based organizations, unions, environmental groups, community groups, students, public health 

groups, energy groups, academia and concerned citizens. 

Impacts of climate change: 

The majority of speakers expressed concern over climate change and the direct impacts that they see on

public health and the environment. A number of speakers voiced concerns over the impacts of climate 

change on future generations. There were a number of children who spoke that discussed their 

concerns with climate change and how inaction now, will create more problems for them and future 

generations.

Overview of Comments on 111(d):

The most common theme heard from speakers was that the EPA has to put standards in place that helps 

address the issue of climate change. Additionally, speakers asserted that it is vital for the agency to set 

standards in the short term, as opposed to waiting years down the road, to address climate change. 

Amongst these speakers, many also encouraged strong standards and a number of state and regional 

programs were given as examples that EPA should model its federal standards after. Furthermore, a 

number of speakers advocated for credits for states that already have programs in place. Several 

speakers spoke of the importance of coal in their communities and in the generation of reliable 

electricity from coal.

Economic Impacts:

While most speakers were supportive of EPA standards for carbon emissions, some speakers cautioned 

EPA on several fronts. There were some speakers that stated that the research supporting climate 

change is not conclusive to warrant action. Supporters and representatives of the coal industry
expressed concerns that EPA’s actions would adversely impact jobs, the power sector and the 

economies of coal-producing states. Some speakers expressed concern for small cooperatives and the 

impact that regulations would have on the cost of electricity for consumers. They asserted that their 

cooperatives have already spent millions of dollars to meet past standards and that additional standards 

would require more modifications that would be costly to the consumer. They expressed the need for a 

balanced solution. Additionally, others asserted that industry should get credit for programs already 

implemented to reduce carbon pollution.

State Regulations:

Speakers urged EPA to provide states ample time and flexibility for designing their state regulations. 

Many speakers asserted that state and regional conditions differ and technologies available and 

applicable to states differ and it is imperative that these differences are accounted for when standards 

are designed. It was stressed by many speakers that states need more than a year to comply with the 

standards. Additionally, attendees emphasized that existing programs should be encouraged to continue 

and that those programs should serve as a model for federal guidelines. Additionally, views varied as to 

whether to set guidelines based on a system-wide or source-based approach. Those that supported a 

source based approach asserted that this type of approach was essential in reducing environmental 

justice concerns that are often observed at the local level. Speakers encouraged EPA to give states the 

flexibility to choose between a mass versus rate based standard. 

Market Based Approaches:

Speakers urged EPA to allow market based approaches, like a cap and trade system. Some asserted that 

EPA should allow credits to be banked for future use and that the agency should let states set stronger 

limits to encourage over-compliance. A recommended approach would be to allow states to hold funds 

from auctions in strategic reserves to use them to prevent price swings which would help stimulate longterm investments.

Energy Efficiency (EE):

Speakers urged the agency to remove barriers to EE improvements at plants. Furthermore, speakers 

asserted that assistance is needed in translating EE into greenhouse gas reductions. Renewable energy

and EE were cited by many speakers as essential to achieve compliance.

Technologies to be Used:

A number of technologies were mentioned by speakers as possible methods to get carbon reductions. 

These included: turbine inlet cooling at natural gas facilities, encouraging the combined heat and power 

partnership and waste heat to energy projects (both at 111d sources and offsite) and biomass co-firing. 

Several speakers mentioned that fuel switching to natural gas should be an allowable compliance option 

while others favored renewable energy and EE over switching to other fossil fuels.

Additionally, a number of speakers stated that carbon capture and storage systems are not adequately 

demonstrated to be successful in getting reductions and are not commercially available. It was argued 

by some that EPA should not dictate what technologies are used. 
Impact of Regulations:

A number of speakers asserted that U.S. regulations to reduce carbon pollution would not have an 

impact on global carbon pollution. They asserted that other countries’ production of carbon will 

outweigh any benefits that U.S. regulations will have on carbon pollution. Others emphasized the 

adverse impact the guidelines would have on coal mining, coal jobs, and coal production in the United 

States.