Testimony 

EPA's Proposed Rule 

"Standards of Performance for 

Greenhouse Gas Emissions for New 

Stationary Sources: Electric Utility 

Generating Units" 

Docket Number EPA-HQ-OAR-2011-0660 

Presented by Mandy Warner 

Climate & Air Policy Specialist 

Environmental Defense Fund 

May 24, 2012 Public Hearing 

Washington, D.C. 

My name is Mandy Warner and I am with Environmental Defense Fund (EDF). a non-partisan 

environmental organization with more than 750,000 members nationwide. EDF is dedicated to 

working towards innovative. cost-effective solutions to environmental problems. building on a 

foundation of rigorous science, economics, and law. 

Thank you for the opportunity to testify today. The proposed standards are an important step 

towards addressing the massive quantities of climate destabilizing pollution emitted from U.S. 

power plants. one of the largest sources of greenhouse gases (GHG) in the world. By halving the 

lifetime carbon emissions from new coal-fired power plants relative to traditional coal plants, 

these historic clean air standards will provide long overdue and urgently needed protections for 

our health and climate while strengthening our made-in-the-U.S.A. clean energy economy. 

Buckxround 

Climate change presents a clear and present danger now to the U.S. and to the world. The 

National Oceanic and Atmospheric Administration recently announced that the lJ.S. completed 

the single warmest 12-month period on record.' Over the May 2011 to April2012 period all of 

the Mid-Atlantic states experienced record warn1 or much above normal temperatures." 

Leti unchecked. climate change will have severe impacts on Americans' health. our 

environment. and our economy. The U.S. Global Change Research Program has detern1ined that 

if carbon pollution is not reduced, it is likely that American communities will experience 

increasingly severe climate impacts. including: rising levels of dangerous smog in cities-which 

will lead to an increased risk of respiratory infections. more asthma attacks. and more premature 

deaths: increased risk of illness and death due to extreme heat: more intense huiTicanes and storm 

surges: increased frequency and severity of flooding; increases in insect pests and in the 

prevalence of diseases transmitted by food, water. and insects; reduced precipitation and runoff 
in the arid West: reduced crop yields and livestock productivity; and more wildfires and 

increasingly frequent and severe droughts in some regions. ill 

Greenhouse Gas Burden ji-om the U.S. Power Sector 

U.S. power plants fueled by coal and gas arc the single largest source of carbon pollution in our 

nation and one of the largest emitters ofclimate-destabili;.cing pollution in the world. The U.S. 

power sector is responsible for approximately 40'Yo of all carbon pollution in the U.S and emits 

more GIIGs than Russia. India, Japan. or Germany." Building just one inefficient. emissionintensive plant today locks us into millions of tons of future climate pollution-or the expensive 

alter-the-fact shuttering or built infrastructure that releases harmful pollution. We cannot 

effectively address climate-destabilizing emissions without addressing the pollution emitted by 

the power sector. 

U.S. Powet· Generation GHG Emissions Surpass Emissions 

from Most Countries 

(fv1i!lion Metric Tons CO? Equivalent; 

1111111111111 

~:cu1ce UNFCCC -Sixth .:::omcllatiOF and syntr,esrs of 1n1ltd· :lat;cnal co-:cmun,cattor,s t1or,' part1es not tnclv:!ed ,n Annex I to :he convent1cn. ;;JrlC: 

Nallona' Gr~r.house Gas :nv2r:tO~'' D~tA tor t',e o.eriod 19-:JC'- 201)9 :reiiKHng Ann-ex I counrr,es: 

Innovative Approaches 

Fortunately, our nation has the innovative solutions and the know-how to meet this pressing 

challenge while strengthening our economy. Numerous states across the U.S. are already 

limiting carbon pollution from new power plants, like Minnesota, Montana. and Washington. 

Ten leaders of state environmental agencies also recently wrote to EPA expressing their support 

for the standard, including Connecticut. Delaware, Maryland. Massachusetts, Rhode Island, 

Vermont. and the District of Columbia.' Furthermore, over two dozen states have policies in 

place to harness the economic and environmental benefits of cleaner energy. Twenty-four states 

have standards in place that will drive investment in energy efficiency, saving American homes 

and businesses money while reducing emissions. Many other states have developed policies to 

support innovation in clean, sustainable energy and to make their economies more efficient. 
These standards are aligned with market forces that are already driving utilities to develop 

cleaner technologies. An April 2012 World Resources Institute report explains that •·]ower 

natural gas prices. declining grovv1h in electricity demand, rising coal prices. and increased costcompetitiveness ofrenewables" arc shaping business decisions in the utility sector." 

Leaders within the utility industry recognize the importance and achievability ofEPA's proposed 

standards. Por instance. Ralph lzzo. CEO of Public Service Enterprise Group. issued the 

following statement after EPA released the proposal: 

"'The Agency "s action establishes a logical and modest standardfor new electric power plants 

and provides the industry with much needed regulatory certainty. The EPA provides a 

.frameworkjiH' the industry to confront this problem in a cost effective manner.· 

New clean air standards are a critical step in the right direction 

Under EPA ·s standards the nation's energy needs can be met through a diverse, efficient mix of 

power sources. including renewable energy. efficient natural gas power plants, combined heat 

and power. and improvements in the efficiency of our energy use. The standards also provide a 

pathway for the development of carbon capture and sequestration for coal plants. The New 

Source Performance Standards for carbon pollution will provide power companies with 

regulatory certainty for prudent, long-term investments in cleaner. homegrown energy that puts 

Americans to work. The technology we need is available today and the time has come when we 

can no longer afford to build new. uncontrolled coal plants that discharge vast volumes of GHG 

pollution for fifty years or more, recklessly imperiling our health, our environment and our 

prosperity. EPA's proposed limits on GHG pollution from fossil fuel power plants are essential to 

address climate change. to drive innovation in clean energy solutions, to ensure a steady t1ow of 

cost-effective and cleaner electricity to power our economy, and to protect the health and wellbeing of Americans, now and in the future. 

EDF will also be submitting further technical comments on the proposed rule. Thank you again 

for the opportunity to testify. I am happy to answer any questions you may have. 

'National Oceanic and Atmospheric Administration. http://vvww.ncdc.noaa.gov/sotc/national/20 12/4. (accessed May 

14. 2012). 11 National Oceanic and Atmospheric Administration. http://www.ncdc.noaa.gov/temp-andQIITi.Rlmaps.php?ts= 12&vear=20 12&month=4&imgs[J=Statewidetrank&subm itted:..:Subm it. (accessed May 14. 

2012). 

'"U.S. Global Change Research Program, http://www.globalchange.gov/. 

"Source: UNFCCC- Sixth compilation and synthesis of initial national communications from parties not included 

in Annex Ito the Convention. and National Greenhouse Gas Inventory· Data for the period \990- 2009 (reflecting 

Annex I countries). 

"' Letter to Administrator Lisa Jackson. Re: Standards (?f"Perj(Jrmanccfor Greenhouse Gas Emissions for /'v'ert· 

Stationmy Sources: Electric Utility Generating Units. May 9. 2012. 

'' World Resources Institute. Fact Sheet. "U.S. ELECTRICITY MARKETS INCREASINGLY r A VOR 

ALTERNATIVES TO COAL."