Summary	of	Region	3	Public	Listening	Session	

on	111(d)	for	Power	Plants

November 8, 2013 – Philadelphia, PA

On November 8, 2013, EPA Region 3 held a public listening session to obtain public input on 

how EPA can craft carbon pollution standards from existing power plants. Approximately 125 

people attended the meeting, and of those attendees, 75 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:

Regional Administrator Shawn Garvin welcomed participants and gave remarks regarding the 

need for action. Diana Esher, the Air Protection Division (APD) Director, opened the session 

with the overview of Section 111(d), ground rules and logistics. 

The majority of the speakers supported EPA’s efforts to reduce carbon emissions from existing 

power plants. They spoke of the need to protect air quality, health concerns (mainly asthma), 

and preserving the planet for our children. Region 3 had a significant number of speakers from 

faith-based organizations, environmental groups, the medical community and the general 

public.

Representatives of coal and utility organizations stressed the need for (1) realistic timeframes 

to implement new rules; (2) reliable, balanced, diverse energy portfolio to assure the nation’s 

energy supply; and (3) consideration of the economy of Appalachia by protecting the jobs of 

those who work in coal mines or coal fired utilities.

A few people presented ideas on how EPA could reduce carbon emissions from existing plants.

Ideas included establishing a tax on emissions, allowing states to establish a cap and trade 

program, encouraging investments in new technologies through financial incentives, 

disconnecting utility profits from power consumption, increasing the use of combined heat and 

power, modernizing the region’s electrical grid, and increasing the use of existing highefficiency natural gas plants.

A few speakers also believed that the air pollution standards for natural gas plants should be 

tighter.

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. One speaker presented information on carbon pollution’s impact on sea level rise

and melting glaciers citing NOAA’s predicted sea level rise of 5-6 feet. Another speaker said the 

cost of climate change should be weighed against the cost of not acting and emphasized that 

this is not a war on coal; it’s a battle to save the planet. Speakers also said the failure of 

Congress to act on the issue of climate change means EPA needs to do so, that firming up the 

rule in a timely manner is essential, and that EPA needs to make the rules strong to give us clear 

air for the next generation.

Overview of Comments on 111(d):

Most speakers supported action on existing power plants, and asked EPA to act quickly and

meet the existing timeline under consideration. The groups applauded EPA’s intention to 

announce a standard to limit pollution from power plants. Many speakers supported strong 

regulation of coal and the phase-out of coal and noted the need to protect air quality, health 

and the planet. Many speakers believe the rule is important and should be cost-effective and 

drive innovation. 

Speakers suggested 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. 

Speakers presented ideas on supply- and demand-side solutions for addressing carbon pollution 

from power plants and discussed energy efficiency, combined heat and power, modernizing the 

grid, and incentivizing new technologies. They emphasized the use of combined heat and 

power at commercial facilities, more high-efficiency natural gas plants and improved efficiency 

at existing coal plants. Speakers maintained that electric prices need to stay stable and that 

efficiency increases will outweigh the cost of fuel switching at power plants. They also stated 

that increasing renewables by 20% would decrease costs by $9 B annually. 

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). 

The speakers also encouraged EPA to consider job losses in Appalachia associated with EPA’s 

regulations, and to protect the jobs of coal miners and those whose work is related to coal-fired 

utilities. 
Some speakers warned that EPA regulations should not harm the affordability and reliability of 

energy, also articulating the need for a diverse energy portfolio. 

Utility and coal groups want to work together for realistic standards. For utilities, it’s not just 

about selling more power, but also about opportunities for savings. Recommendations for EPA: 

require utilities to pursue all cost-effective energy efficiency resources (e.g., cost caps). 

Setting the Standard:

Speakers encouraged EPA to maintain realistic timeframes to implement the new standards. 

Speakers recommended that EPA maximize the ability that states have to implement 

regulations and permit states to include energy efficiency and conservation measures to 

implement regulations. They also encouraged conversion from dirty to clean energy, pointing 

out that oil is unaffordable for low income families, and recommended more stringent building 

codes.

One speaker highlighted Act 129 in Pennsylvania which sets savings and demand reduction 

goals for the state’s large electric utilities. For utilities, it’s not just about selling more power;

it’s also about opportunities for savings, etc. The speaker recommended that EPA require 

utilities to pursue all cost-effective energy efficiency resources (e.g., cost caps).

Another speaker stated that government has to lead the community to reduce carbon 

emissions by 80% by 2050. They added that we have enough reliable knowledge about climate 

change to regulate and limit it. 

 

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. 

Speakers also recommended a compliance mechanism framework and that multiple states 

should be able to use these guidelines. They said EPA should not penalize early movers to RGGI

and, additionally, RGGI should be evaluated for other states and assistance should be provided 

to states who choose RGGI as an option.