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Comment Letter on EPA's Carbon Pollution Standard

Regulatory Comments and Testimony

Title

Comment Letter on EPA's Carbon Pollution Standard

Full Document Available in PDF

Executive Summary

On behalf of the Competitive Enterprise Institute (CEI), a non-profit public policy group specializing in regulatory issues, I respectfully submit this comment letter on the Environmental Protection Agency’s proposed “Carbon Pollution Standard.”

CEI recommends that the EPA withdraw the proposed rule for the following reasons:

  1. The EPA’s proposal would effectively ban construction of new coal-fired power plants, a policy Congress has not approved and would reject if proposed in legislation and put to a vote.
  2. The proposal is an underhanded ‘bait-and-fuel-switch.’ The EPA assured stakeholders in March 2011 that it would not redefine source categories to require fuel-switching from coal to natural gas. Had the EPA come clean about its agenda in 2010 and 2011, Senators Murkowski and Inhofe would likely have garnered more support for their efforts to overturn the agency’s greenhouse gas regulations.
  3. The proposal relies on weird contortions – a consequence of the EPA’s attempt to use the Clean Air Act as a framework for regulating greenhouse gases, a purpose for which the Act was neither designed nor intended. For example, the EPA pretends that natural gas combined cycle – a type of power plant – is a “control option” and “system of emission reduction” that has been “adequately demonstrated” for coal-fired power plants.
  4. The proposal will provide another precedent for establishing National Ambient Air Quality Standards for greenhouse gases, taking America one step closer to policy disaster.