Statement of Daniel A. Lashof, Ph.D. 

Director, Climate and Clean Air Program 

Natural Resources Defense Council 

Public Hearing on the Environmental Protection Agency's 

Proposed Carbon Pollution Standard for New Power Plants 

Washington, D.C., May 24, 2012 

I appreciate the opportunity to appear here today to provide further comments on behalf of the 

Natural Resources Defense Council in support of EPA's proposal to establish carbon pollution standard 

for new electric power plants. As my colleagues have noted, this will be the first national limit on carbon 

pollution from power plants and is a vital step toward protecting public health from the dangers of 

climate change. 

One of the clearest and most direct health threats from climate change is deadly heat waves. 

We all know that hot, muggy conditions are unpleasant. They are also dangerous-especially for old 

people, young children, and individuals with certain pre-existing conditions. Already an average of more 

than 1000 Americans die each year from the direct and indirect effects of excessive heat. Yesterday 

NRDC released a report showing that unabated climate change could increase that number dramatically, 

resulting in a cumulative total of more than 30,000 additional deaths by mid-century and more than 

150,000 additional deaths by century's end. 

Power plants are America's largest source of carbon pollution, so there is simply no question 

that carbon dioxide from power plants cause or contribute to endangering public health and welfare. 

Given that, EPA is simply doing is job by moving forward with common sense standards to limit carbon 

pollution standards from power plants. Indeed, these standards are long overdue. 

NRDC strongly supports EPA's decision to establish a fuel-neutral standard applicable to all new 

fossil fuel fired electricity generating units. Our electricity system is operated as an integrated whole and 

a megawatt-hour generated by a coal plant provides the same service as a megawatt-hour provided by a 

gas plant. As EPA notes in the proposal, a developer of a new power plant has a wide variety of design 
options that allow it to comply with the proposed standard. So there would be no justification for EPA to 

allow more pollution from certain types of plants based on a design choice within the developer's 

control, particularly when less polluting options are also less expensive. 

Indeed, NRDC urges EPA to go even further in establishing a fuel-neutral and technology-neutral 

carbon pollution standard for new power plants. We see no reason to make distinctions among fossil 

fuel generating units based solely on their technology configuration. We therefore urge EPA to include 

all fossil electricity generating units with a capacity greater than 25 MW in the category of potentially 

affected sources. (EPA has specifically asked for comment on how to address simple cycle turbines used 

to meet peak load and NRDC plans to elaborate on this in our written comments). 

Some opponents of EPA's proposal have characterized it as a war on coal. This is simply untrue. 

EPA is combating pollution, to protect the health of the American people. And the benefits have been 

enormous. In 2010 alone the health and environmental benefits of clean air standards have been valued 

at $1.3 trillion- more than 2S times their cost. Where else can you get that kind of return on 

investment? 

The proposed carbon standard for new power plants is fuel-neutral. In fact, EPA has gone out of 

its way by providing an option that would allow a new coal plant to have higher emissions than the 

standard for its first 10 years of operations, provided that its average emissions over 30 years comply 

with the standard. 

If coal is losing the battle for market share, it is because of market forces, not the EPA. Market 

analysts, utility executives, independent economists, and government forecasters all agree. 

For example, Alliance Bernstein's Senior Utilities Analyst Hugh Wynne cites the narrowing price 

differentials between natural gas and coal, the greater fuel efficiency of combined cycle gas turbines 

(CCGTs) over conventional coal steam plants and the lower construction cost of CCGTs in explaining that 

it's unlikely that the economics of coal would improve enough to revive interest in building new coal 
plants even in the absence of the proposed standard. " ... we expect the proposed rule to have little 

impact on capacity additions over the remainder of the decade," he concluded. 

Most utility executives have acknowledged this reality, and some have gone further-welcoming 

the regulatory certainty that the proposed standard would provide. In a statement that followed EPA's 

announcement of the proposed standards, Public Service Enterprise Group (PSEG) Chairman and CEO 

Ralph lzzo stated," ... EPA took an important step today in addressing the significant environmental 

threat posed by climate change. The Agency's action establishes a logical and modest standard for new 

electric power plants and provides the industry with much needed regulatory certainty. The EPA 

provides a framework for the industry to confront this problem in a cost effective manner." 

Finally, government forecasts by both the Department of Energy and EPA confirm that no new 

coal plants are likely to be built during this decade other than those already under construction. This 

remains true even in sensitivity analyses assuming much higher natural gas prices than are actually 

expected. 

EPA's proposal to set the first national limits on carbon pollution from power plants is in fact 

essential to establish an electric system that truly serves electricity customers. After all, electricity 

customers are also breathers. We need a reliable electric system, but a system that destabilizes our 

climate is anything but something we can rely on. Improving and finalizing this proposal is a small, but 

critical, step toward creating an electricity system we can all live with.