Foundation Testifies at Federal EPA Carbon Standards Hearing

(Foundation Vice President Benita Dodd addressed an Environmental Protection Agency listening session on carbon pollution standards for existing power plants on October 23 in Atlanta.  This is the transcript of her remarks.)

BENITA DODD Vice President, Georgia Public Policy Foundation

Vice President, Georgia Public Policy Foundation

Thank you for the opportunity to speak at this listening session. My name is Benita Dodd and I am Vice President of the Georgia Public Policy Foundation.  The Foundation is an independent, state-focused think tank that proposes market-oriented approaches to public policy to improve the lives of Georgians.

The Foundation believes that tougher standards on carbon dioxide emissions being proposed by the Environmental Protection Agency and under discussion at the EPA’s 11 listening sessions around the country will have unfortunate consequences for the United States.

This nation holds the world’s largest estimated recoverable reserves of coal; in fact, the United States is a net exporter of coal.  In 2012, 81 percent of the billion short tons of coal produced in the nation (a short ton is 2,000 pounds) was used by U.S. power plants to generate electricity, providing 42 percent of the energy mix (1).  The nation’s estimated recoverable coal reserves represent enough coal to last 236 years.  (The Energy Information Administration’s (EIE) April 2013 Annual Energy Outlook considers the growth rate of U.S. coal production (0.2% per year for 2011-2040) and estimates about 194 years if no new reserves are added (2).

The importance of coal in Georgia’s energy mix is not to be underestimated, either.  According to the EIA, of the state’s electricity generation in 2011, coal accounted for 48 percent (3).  The mix has changed somewhat; natural gas prices dropped as innovative hydraulic fracturing technologies led to a cheaper and greater domestic supply of natural gas and coal prices rose (4).  Still, coal remains a crucial and reliable domestic source of energy.

Now comes the proposed regulation of C)2 emissions under the president’s Climate Action Plan. According to the EPA website, “In 2009, EPA determined that greenhouse gas (GHG) pollution threatens Americans’ health and welfare by leading to long lasting changes in our climate that can have a range of negative effects on human health and the environment” (5).

“Carbon dioxide (CO2) is the primary greenhouse gas pollutant, accounting for nearly three-quarters of global greenhouse gas emissions and 84 percent of U.S. greenhouse gas emissions.”

The EPA is working to redefine a gas that every living being exhales into a pollutant. Carbon dioxide emissions do not equate to carbon dioxide pollution. Further, water vapor is the primary greenhouse gas. And we exhale that, too. Should we regulate water vapor?

The average U.S. coal plant emits over 1,700 pounds of CO2 per megawatt hour (lbs CO2/MWh). The average natural-gas plant emits around 850 lbs CO2/MWh. The EPA proposal would limit CO2 emissions to between 1,000 and 1,100 lbs/MWh, depending on the size of the plant and method of emissions monitoring. This is a standard not yet met by any coal plant.

The EPA finds the standards “will result in negligible CO2 emission changes, energy impacts, quantified benefits, costs, and economic impacts by 2022.” (6) The EPA’s analysis also says the proposed standards “will result in negligible changes in GHG emissions over the analysis period (through 2022 and following years). Even in the absence of this rule, the EPA expects that owners of new units will choose generation technologies that meet these standards due to expected economic conditions in the marketplace.” (7)

If the EPA believes the marketplace is heading that way, and that the standard will have no impact on emissions, why promulgate this regulation? How responsible is it that producers will be shipping coal abroad instead, where environmental standards frequently are less stringent?

This proposed standard threatens future domestic use of an abundant and reliable energy resource, which utilities have used responsibly to provide affordable energy to consumers. Just this week, the EIA announced that 2012 U.S. carbon dioxide emissions from the consumption of fossil fuels declined almost 4 percent from the 2011 level. Energy-related carbon dioxide emissions have declined in five of the last seven years and are the lowest they have been since 1994. (8)American innovation, efficiency and a mix of energy sources are providing greater air quality improvements than government can.

This future of U.S. coal-fired plants and a dependable domestic source of fuel will be endangered by this proposal, and with it, our nation’s economic prosperity. As Americans continue to recover from the Great Recession, the federal government has a responsibility to ensure that citizens are not burdened by higher energy prices because of policies that it readily admits will have minimal effect.