Summary	of	Region	1 Public	Listening	Session	

on	111(d)	for	Power	Plants

November 4, 2013 – Boston, MA

On November 4, 2013, EPA Region 1 held a public listening session to obtain public input on how EPA 

can craft carbon pollution standards from existing power plants. Approximately 140 people attended 

the meeting, and of those attendees, 74 people spoke. Of the speakers, approximately 95% 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 of Speakers:

Speakers included and represented public officials, small businesses, business communities, recreation 

communities, faith-based organizations, unions, consumer advocates, environmental groups, 

community groups, asset management firms, students, public health groups, energy groups, academics, 

entrepreneurs, concerned citizens, and parents. 

Impacts of climate change: 

Many speakers were concerned about climate changes and its impacts on health, outdoor recreation, 

businesses (including small businesses), jobs, livelihoods, vulnerable populations, natural resources, 

assets, and communities, and more broadly, the environment and the economy. 

Overview of Comments on 111(d):

The majority of speakers supported action by EPA on existing power plants, and many urged EPA to not 

only act, but to act quickly and boldly. Amongst these speakers, many also encouraged strong 

standards, with some calling for standards equivalent to EPA’s proposal for new sources. Several also 

urged EPA to meet the existing timeline (including timely review of state plans), with one speaker 

encouraging EPA to move even faster. Several speakers explicitly supported the phase-out of coal or 

more stringent regulations for coal. 

Some speakers advised the standards would send market signals to drive long-term investments, spur 

technological innovation and create jobs, while providing businesses with needed environmental and 

economic stability. Other speakers supported these standards as a part of a transition to a cleaner 

electricity generation fleet. 

Another speaker cited research that demonstrated measures to reduce carbon have large co-benefits, 

co-benefits large enough to offset the costs of carbon policies. Those benefits include reductions in 

ozone, particulate matter and mercury pollution. 

Generally, speakers presented both supply- and demand-side solutions for addressing carbon pollution 

from power plants. These speakers discussed energy efficiency, demand response, solar power, wind 

power, hydropower, tidal power, electric vehicles, biofuels, net metering, renewable portfolio standards 

and smart grid, and they urged EPA to consider options beyond onsite controls at power plants. 
Other speakers cautioned EPA not to penalize states who were early implementers of carbon pollution 

programs for existing power plants. This is discussed further in the section on “State Regulations”.

Economic Impacts:

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

EPA on several fronts. Those speakers urged EPA to ensure that regulations are fair and not rushed 

through, and account for the human element of those who may be negatively affected by EPA 

regulations (e.g., coal miners). Several other speakers advised that EPA regulations should prevent 

premature closures of environmentally compliant coal facilities. 

The speakers also encouraged EPA to take action to address job losses associated with EPA’s regulations, 

supporting a just transition (e.g. retraining, funding, other support) to new jobs (potentially clean energy 

jobs) for displaced workers, especially in coal-heavy states. 

Some speakers stated that EPA regulations should not harm the affordability and reliability of energy, 

also articulating concerns about over-reliance on a single fuel such as natural gas. However, other 

speakers presented evidence that reliability and the economy are enhanced by carbon emissions 

reductions. 

Considering the Regional Greenhouse Gas Initiative (RGGI):

Support for RGGI as a compliance pathway fell mostly in two categories: those that believed that RGGI 

and pacts like RGGI have been successful and should qualify as a compliance path for participating 

states; and those that believed all or part of RGGI is a successful model that EPA should build upon for a 

national program. In particular, speakers urged EPA to consider market-based tools that have worked in 

RGGI including its auction system and reinvestment program that uses RGGI funds for energy efficiency 

and clean energy projects. Speakers demonstrated that RGGI has provided economic benefit while 

reducing emissions. 

Several speakers added that allowances should not be free and that EPA should ensure that the floor of 

the standards is not set too low. Several speakers indicated that RGGI provides a simple and 

quantifiable accounting system for emissions reductions. One speaker recommended that EPA consider 

the New Hampshire RGGI program when it was first introduced (as opposed to the current program). 

Several speakers encouraged EPA to support states interested in joining RGGI for 111(d) compliance. 

However, while supporting RGGI, one speaker suggested that RGGI may not suit all states.

Energy Efficiency (EE) and Renewable Energy (RE):

A number of speakers urged EPA to consider EE and RE as a part of the solution for reducing carbon 

pollution from power plants. These speakers encouraged EPA to design the regulations to be flexible 

enough to include EE and RE as part of the solution. One speaker suggested that EE and RE may help 

limit over-reliance on natural gas. Another speaker suggested that EPA’s EE/RE Roadmap could be 

extended to carbon pollution. 
Several speakers emphasized that EE is a least-cost resource and that EPA should adopt a policy to 

pursue all cost-effective EE that is at lower cost than new generation. Speakers pointed out that EE can 

increase reliability. However, EPA should work with stakeholders to establish credible and harmonized 

methodologies for quantifying and crediting reductions from EE. More specifically, one speaker advised 

EPA to remove barriers to energy efficiency improvements at power plants. 

Regarding RE, speakers asked EPA to provide renewable energy an even playing field, to invest in 

renewable and clean alternatives, to transition to these safer, cleaner sources of energy. One speaker 

recommended that the USA consider a renewable energy super grid. 

Setting the Standard:

State representatives encouraged EPA to consider the “Best System of Emissions Reductions” very 

broadly to encompass the electric system as a whole, allowing flexibility for compliance not only at a 

state level, but at a regional level. One speaker articulated that EPA should set a technology-based 

standard based on the best boiler and turbine technology; and that any non-technology-based 

compliance option would need to be quantified to demonstrate that it would exceed the technologybased standard. Two speakers supported a mass-based emissions approach as opposed to a rate-based 

approach, while one speaker supported the rate-based approach. While one speaker wanted a firm 

limit on emissions from power plants, another speaker asked for a state-wide target based on the 

generation mix. Several speakers urged EPA to regulate more than just coal and gas and to categorize 

fuels not by their source or make-up, but by the emissions they contribute, so as not to give a free pass 

to other carbon emitters. One speaker recommended that power plants achieve a 35-40% reduction 

from 2005 levels in order to meet the President’s goal of 17% by 2020. 

Several speakers encouraged EPA to consider technology potential and innovation as EPA sets the new 

standards. These speakers also advocated maximum flexibility for states to adopt new and advanced 

energy technologies, allowing room for creativity and potentially spurring innovation through EPA’s 

regulations. 

Several speakers expressed concern over an over-reliance on or over-incentivizing a single source of fuel 

and articulated the need for EPA to encourage a diversity of fuels as it sets its standards. One speaker 

suggested subsidies for compliant facilities that would not otherwise be economically viable as a 

measure to ensure fuel diversity. Another speaker recommended a wire charge on rate payers to 

support these compliant facilities. 

One speaker discussed the need for transparency and consistency in measurement and verification of 

emissions reductions. 

State Regulations:

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

Furthermore, they recommended that EPA regulations provide sufficient flexibility to accommodate 

existing policy solutions that are already in place, recognizing that each state will have different 

methods that are optimal for that state. In particular, states advised EPA to account for existing state 

work, taking care to ensure that early implementers are credited for their proactive steps. States 

recommended that EPA require different percentages of emissions reductions from each state, in 

recognition of early action. Lastly, one speaker suggested that EPA establish clear criteria for state 
111(d) submissions, such as a model template, that would encompass the flexibility sought by states 

while still being enforceable by EPA. 

Carbon Tax/Price:

Several speakers supported the use of a carbon tax or price. These speakers suggested that such a tax 

or price would level the playing field for renewable energy, and urged EPA to create incentives for states 

to use the revenue to invest in energy efficiency and other emissions reduction programs. 

Ensuring Program Effectiveness:

While speakers encouraged EPA to incorporate flexibility, several speakers cautioned that standards 

cannot be so broad that it allows for actions that do not achieve real emissions reductions; and that 

effectiveness should not be compromised. For those states that choose not to implement their own

plans, one speaker urged EPA to establish a strong federal implementation standard. Several speakers 

encouraged EPA to think long-term in its public policy, acknowledge that there will be stranded assets 

and to work with EPA’s attorneys on the guidelines’ preamble. 

Federal Leadership:

Several speakers called on EPA and the federal government to provide bold, wise leadership, particularly 

where collective actions are needed such as climate change and carbon pollution. They recommended 

federal coordination across agencies and encouraged EPA to work with businesses.