EPA’s Power Grab Unscientific and Uncalled For

Benita Dodd testified on July 29 at the Atlanta Field Hearing of the Environmental Protection Agency regarding the Clean Power Plan. This is her official testimony, a written copy of which was submitted to the EPA.

By Benita M. Dodd



According to the Federal Register, on December 7, 2009, the EPA “found” that current and projected concentrations of greenhouse gases (GHG) in the atmosphere threaten the public health and welfare of current and future generations. Unfortunately, this finding and the EPA’s subsequent action threaten the public health and welfare of current and future generations of Georgians far more than greenhouse gases do. 

The EPA declares the goal of its Clean Power Plan is to cut “carbon pollution” from the power sector by 30 percent from 2005 levels. When the agency starts with referring to carbon EMISSIONS as carbon “pollution,” it demonstrates a slanted, not science-based agenda. Carbon is not pollution: We exhale it; it’s contained in all living organisms, forms the basis for organic molecules and is in fact the second most abundant element in the human body – accounting for 18 percent of our body weight. 

According to the Federal Register, President Obama’s executive order “specifically directs EPA to build on state leadership, provide flexibility and take advantage of a wide range of energy sources and technologies towards building a cleaner power sector.” Unfortunately, the flexibility the EPA is offering Georgia is akin to letting a condemned man choose his method of execution: One way or another, it’s the end. EPA has offered no alternatives to this expensive, climate change-agenda action.[1] 

It would require Georgia utilities to cut emissions by an additional 44 percent by 2030 at existing plants. The EPA expects this to be done by converting to alternative sources of energy and by energy conservation/ efficiency. But the EPA won’t credit Georgia’s utilities for their work done in embracing carbon-free energy by building the first nuclear units since Three Mile Island. EPA’s goal is also to, “Shrink electricity bills roughly 8 percent by increasing energy efficiency and reducing demand in the electricity system.” Reducing energy demand, like with water conservation measures, leaves the utilities further lacking the revenue they need for the efficiencies the government wants. 

In the Federal Register, the EPA notes, “At this time we do not have any estimates regarding the benefits and costs of this action, but we do expect it to be a significant regulatory action with annual effects on the economy exceeding $100 million.”

  • In the rule, the EPA projects that, in 2030, “the significant reductions in the harmful carbon pollution and in other air pollution, to which this rule would lead, would result in net climate and health benefits of $48 billion to $82 billion.”
  • In the overview, the benefits climb to $55 billion to $93 billion in 2030, including avoiding 2,700 to 6,600 premature deaths and 140,000 to 150,000 asthma attacks in children.

We never want our children to suffer, especially not if their asthma attacks are caused by polluting power plants. So these numbers are important for two reasons.

First, this nation deserves a credible approach that yields tangible results.

Second, as taxpayers, we deserve justification of the financial costs and the claimed benefits. “We can’t tell you the cost, but we do know how much it can save you,” sounds like a pitch from a sleazy car dealership.

And THOSE caveats are based on THESE statements: Then-EPA Administrator Lisa Jackson told Congress back in 2009 that U.S. action alone will not impact global carbon emissions levels; that this was “part of an overall strategy that is positioning the U.S. for leadership in an international discussion.”[2] And a former EPA computer modeler wrote July 8, 2014, in The Wall Street Journal, “I realized that my work for the EPA wasn’t that of a scientist, at least in the popular imagination of what a scientist does. It was more like that of a lawyer. My job, as a modeler, was to build the best case for my client’s position.”[3]

Meanwhile, the U.S. Chamber of Commerce’s Institute for 21st Century Energy predicts this will cost America’s economy over $50 billion a year between now and 2030, according to a new report.[4] 

As for using this action to reduce asthma attacks and fatalities: The EPA has highlighted the dramatic improvements in air quality over the past 30 years, despite the increase in population, the economy and vehicles miles traveled. So if outdoor pollution is the problem, why is it that rates of asthma have risen sharply over the past 30 years, particularly among minorities and children ages 5 to 14? Why are asthma prevalence and deaths climbing among lower-income and minority families?[5],[6] 

We should be more concerned with the EPA report that,“The average American spends approximately 90 percent of their time indoors.” Also, that “studies of human exposure to air pollutants by EPA indicate that indoor levels of pollutants may be 2 to 5 times – and occasionally more than 100 times – higher than outdoor pollutant levels.”[7] 

These are crucial concerns. If the EPA is needlessly placing burdensome regulations on America’s energy companies to curb carbon emissions, those costs will be passed through to consumers and hurt those very families with lower incomes – the families who struggle with children with asthma – taking away money that can be better used to improve their quality of life. 

Georgia’s utilities are diversifying their energy sources to accommodate those willing to pay for renewable alternatives and reduced emissions. Businesses are operating more efficiently and energy intensively. Targeting Georgia utilities for carbon emissions from coal-fired plants in which this abundant domestic product is used responsibly is not only wrong, it’s unethical. Coal and fossil fuels are used at home in an environmentally responsible way, unlike many places abroad. And even as this state’s energy output and demands have increased, the utilities have reduced emissions. 

The EPA’s Clean Power Plan is executive and federal overreach. It’s poor policy, poor science and poor practice, especially for Georgians. There is no indication that any country – especially any developing nation – has the ability or desire to use these resources with as much environmental stewardship and oversight as this nation does. Nor is there any indication that any other country will follow our lead – and shoot itself in the foot – by converting to costly, unreliable renewable energy alternatives or REDUCING energy use. What the EPA is doing is handing over an economic advantage to our competitors, burdening our taxpayers, businesses and consumers with additional costs and – worse – offering false hope to millions of Americans families that it can reduce asthma attacks that have no link to carbon emissions. 

Watch Foundation President Kelly McCutchen discuss the EPA proposal at Tuesday’s American for Prosperity Georgia rally in Atlanta:


[1] https://www.federalregister.gov/regulations/2060-AR33/carbon-pollution-guidelines-for-existing-power-plants-emission-guidelines-for-greenhouse-gas-emissio


[3] “Confessions of a Computer Modeler,” by Robert Caprara, The Wall Street Journal, July 8, 2014, http://online.wsj.com/articles/confessions-of-a-computer-modeler-1404861351 He wrote, “When I presented the results to the EPA official in charge, he said that I should go back and “sharpen my pencil.” I did. I reviewed assumptions, tweaked coefficients and recalibrated data. But when I reran everything the numbers didn’t change much. At our next meeting he told me to run the numbers again.

“After three iterations I finally blurted out, “What number are you looking for?” He didn’t miss a beat: He told me that he needed to show $2 billion of benefits to get the program renewed. I finally turned enough knobs to get the answer he wanted, and everyone was happy.”


[5] http://www.epa.gov/asthma/pdfs/press_kit.pdf

[6] “Children’s Environmental Health Disparities: Black and African American Children and Asthma,” Environmental Protection Agency http://www.epa.gov/epahome/sciencenb/asthma/HD_AA_Asthma.pdf


 Benita Dodd is the Vice President of the Georgia Public Policy Foundation.