NWEC comments from recent Clean Air Act public session

NW Energy Coalition policy director Nancy Hirsh presented the following comments at a U.S. Environmental Protection Agency public listening session Nov. 7 in Seattle. The session concerned EPA’s plan to set CO2 standards for existing power plants under Section 111d of the Clean Air Act:

EPA CAAA Section 111d

Public Listening Session – November 7, 2013

Comments of Nancy Hirsh, Policy Director of NW Energy Coalition


Thank you for the opportunity to provide comments.  My name is Nancy Hirsh, policy director of the NW Energy Coalition.

Our policymakers, citizens and businesses face no greater challenge than facilitating the transition to a clean energy economy.  Climate change will affect all aspects of our economy and environment, including agriculture and hydropower. Low- and moderate-income communities will bear a disproportionate share of the burdens of climate change.  We applaud the leadership shown by the President and EPA to address greenhouse gas emissions from existing power plants.  This is exactly the right step to follow the commonsense approach to standards for new power plants. Carbon pollution standards that will protect public health from the impacts of climate change and spur growth by fostering innovation in cleaner energy technologies are desperately needed given the pace of climate changes.

EPA’s incremental approach to various clean air regulations has made power planning challenging and we are concerned that this approach is leading to investments in outdated fossil fuel plants that will not be in the interest of utility customers or the climate. While we understand this to be a function of the way the law is structured, we urge EPA, under the CO2 rules for existing plants, to establish strong, meaningful standards that take into account the electric system as a whole rather than focusing on individual point sources.  We need a system-wide approach involving both demand and supply side solutions. Energy efficiency is a clean energy solution that saves businesses and families money while creating jobs and reducing emissions.  The Northwest has an abundance of renewable energy resources, including hydropower, wind, solar, biomass and geothermal. All of these local resources should play a role in meeting our climate challenge and in reducing carbon and other air pollution. A regional comprehensive strategy will provide the greatest economic benefit to local communities as well as to states and regions.

Strong and meaningful standards that allow for regional collaboration and drive new investments in energy efficiency and renewable energy resources supplies will secure the most greenhouse gas emissions reductions and the associated economic and environmental benefits.  Idaho, Oregon and Washington are all served by fossil fuel plants that are not located within their boundaries. The cross boundary nature of CO2 emissions from existing coal plants should be carefully considered during the rule making so that the states that are served by these plants are able to participate directly in the regulatory structures and implementation systems for compliance.  Hence our call for a regional system-wide approach. It is time for the US to set clear standards that drive clean energy innovation and reduce the uncertainty around future clean technology investments, while avoiding investments that would extend the lives of highly polluting fossil-fueled power plants.

Thank you.