Emmett Institute on Climate Change & the Environment

Comment Letter from Technological Innovation Experts Opposing EPA’s Proposal to Weaken Emissions Standards for New Coal-Fired Power Plants

Sean Hecht (on behalf of Nicholas Ashford, H. Christopher Frey, M. Granger Morgan, Edward S. Rubin, and Margaret Taylor)

CEN_EMM_PUB-Technology Innovation Expert Comment Letter
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On October 23, 2015, EPA finalized emission standards for new coal-fired power plants under Section 111(b) of the Clean Air Act. The rule was intended to achieve reductions in pollution by setting emissions standards based on the level of emissions achievable by the best system of emission reduction. In late 2018, EPA proposed amendments that would significantly weaken the 2015 Rule.

On March 18, 2019, Sean Hecht submitted a comment letter on behalf of experts in technology innovation, diffusion, and pollution control, arguing that EPA’s proposal to weaken pollution standards for new and modified coal-fired power plants violates federal law, and the prior standard, adopted by the agency in 2015, is the proper one. The law is intended to ensure that new plants adopt effective pollution-control technology, promoting diffusion of that technology and associated improvements in public health and welfare. The commenters conclude that the new Proposed Rule, which incorporates only outdated efficiency improvements and not adoption of the adequately demonstrated technology of partial carbon capture and storage, is arbitrary and capricious.