June 13, 2012

EPA Docket Center, Room 3334

1301 Constitution Ave., NW

Washington, DC  20460


Comments of the League of Women Voters of the United States on the Proposed Rule:

Standards of Performance for Greenhouse Gas Emission for New Stationary Sources:

Electric Utility Generating Units

Attn: Docket ID No. EPA-HQ-OAR-2011- 0660

Support.  The League of Women Voters of the United States (LWVUS) strongly supports the proposed Carbon Pollution Standard for New Power Plants and commends the EPA for taking this crucial first step to reduce carbon dioxide (CO2) emissions from large power plants that are built in the future.

Importance. The new standard is especially important as it applies to new coal-fired power plants.  Coal now accounts for about half of the electricity generated in the U.S. and is responsible for about 40 percent of all U.S. emissions of CO2, the most important long-lived greenhouse gas contributing to climate change.[1]  Since current coal-fired power plants emit about 2,000 pounds of CO2 per megawatt-hour (MWh) of electricity generated, the proposed standard, with a maximum of 1,000 pounds/MWh, is a major advance in the right direction.[2]  It will require that new coal-fired plants operate with much higher efficiencies, employ carbon capture and sequestration for at least half of the CO2 produced, or switch to natural gas.

Need for extending the standard to existing power plants. While this proposed new standard is an important first step, the LWVUS urges the EPA to extend the standard to existing power plants.  Reducing emissions from these power plants is critical to addressing the growing danger that climate change poses to the health and welfare of U.S. citizens and people around the world, as acknowledged by both leading climate scientists and the EPA. 

Increasingly dangerous CO2 levels. The level of CO2 in the atmosphere now far exceeds the natural range from the previous 800,000 years, according to ice core records.[3]  In the pre-industrial world, the atmospheric concentration of CO2 averaged about 285 parts per million (ppm).  At the time of the UN Earth Summit in 1992, atmospheric CO2 was about 355 ppm.  In April 2012, the level reached 396 ppm.  And April saw the 326th straight month with global temperatures above the 20th century average.[4]

Economic consequences.  Failing to take timely action to curb carbon pollution has serious economic consequences. 

  1. Extreme weather events, including drought, hurricanes, and floods, are costing billions of dollars in damages in this country alone.[5]
  2. Climate change-related events such as heat waves, high levels of ozone pollution, and outbreaks of vector-borne diseases have already had a significant impact on health care costs.[6]
  3. The longer we allow CO2 concentrations to rise, the more drastic the eventual cuts in emissions — and the higher the associated costs — will be.
  4. In the absence of a coherent clean energy policy, the U.S. is falling behind in developing and bringing to market the emerging technologies that sustain economic growth.[7]  

Urgency. The U.S. must take aggressive action to reduce greenhouse gas emissions from all sources, with emissions reduction targets of at least 20 percent below 1990 levels by 2020 and 80-100 percent below 1990 levels by 2050.  Reaching these targets will be difficult unless current power plants dramatically reduce their carbon emissions either by capturing and sequestering emissions, by changing fuels, or by shutting down completely.


[1] U.S. Department of Energy, at http://fossil.energy.gov/programs/powersystems/pollutioncontrols/Retrofitting_Existing_Plants.html

[2] Controlling Power Plant CO2 Emissions: A Long Range View, U.S. Department of Energy, at http://www.netl.doe.gov/publications/proceedings/01/carbon_seq/1b2.pdf

[3]  High-resolution carbon dioxide concentration record 650,000-800,000 years before present, Nature, May 2008, at http://www.nature.com/nature/journal/v453/n7193/abs/nature06949.html.

[4] http://co2now.org/

[5] National Oceanic and Atmospheric Administration, at http://www.noaanews.noaa.gov/stories2012/20120119_global_stats.html

[6] Six Climate Change-Related Events in the United States Accounted for About $14 Billion in Lost Lives and Health Costs, Kim Knowlton et al, Health Affairs, November 2011, at http://content.healthaffairs.org/content/30/11/2167.abstract

[7] How to Power the Innovation Lifecycle: Better Policies Can Carry New Energy Sources to Market, Center for American Progress, June 2010, at http://www.americanprogress.org/issues/2010/06/innovation_lifecycle.html


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