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Fight Climate Change: Comment Now on EPA Carbon Rule!

October 5, 2014

The public comment deadline for the historic Clean Power Plan is now October 16th.  The shale gas and oil industry, along with coal and traditional oil interests, are attacking this proposed plan, attempting to undermine and weaken it, with all they’ve got. You can help make history by supporting — and critiquing — the plan using the information below, and the short sample letter at the end, contributed by Ann Dixon. 

Carbon Rule:  We Can Do Better

By Ann Dixon

President Obama and the Environmental Protection Agency have a Clean Power Plan. When this plan is enacted, it will be the first time in U.S. history that carbon emissions have been regulated!  It calls for a  30% reduction in C02 emissions from power plants below the 2005 level. This is significant because one third of domestic greenhouse gas is from power plants.  View the entire proposal here.

The EPA’s Clean Power Plan fact sheet reads:

The power sector is a major contributor of CO2 in particular, but also contributes to emissions of sulfur hexafluoride (SF6), methane (CH4), and nitrous oxide (N2O) … The Clean Power Plan will reduce pollutants that contribute to the soot and smog that make people sick by over 25 percent in 2030…  Reducing exposure to particle pollution and ozone in 2030 will avoid a projected 140,000 to 150,000 asthma attacks in children, 340 to 3,300 heart attacks and 2,700 to 2,800 hospital admissions.

After being ordered by the Supreme Court, and after doing almost nothing during the Bush years, the EPA issued rules for future power plants in September 2013.  Then, on June 2nd, 2014, a new proposal for existing plants was released. This Plan states many options for complying. States will then submit their own plans to the EPA by the end of June 2016.  If state extensions are granted, plans won’t be due until one or two years later. Actual compliance would be needed by 2020, 2025 or 2030.

Public Citizen made a helpful video explaining the back ground of this Rule. They also have an Action Alert to let you comment at the same link.  View the video here.

Stronger Standards Needed

Why was 2005 chosen as a baseline for emissions?  A May 29th article in The Wall Street Journal, “Industry Worries about Carbon Cuts Proposal” explains that this framework lets the utility industry off the hook:

The utility industry would like to work from a baseline set between 2005 and 2007 because those years were the highest ever for U.S. carbon emissions. Emissions started falling in 2008, so using a more recent time frame would set more aggressive carbon-reduction targets.

Given the urgency of our planetary situation – predictions of mass extinctions due to climate change by 2050; arctic ice caps melting more rapidly than predicted, and millions of people being displaced due to storms aggravated by climate change – this isn’t enough.

According to blogger Ben Adler’s June 2nd Grist article,  “The Nine Things You Need to Know about Obama’s New Climate Rules,”

Environmental experts generally agree that more ambitious targets are possible, especially if the EPA is going to make the rules extend all the way to 2030. Since technologies to produce energy more cleanly keep getting better and cheaper, the targets should grow significantly more ambitious over the course of the next decade.

Disturbingly, the proposal calls for an increase in nuclear power, gas drilling (natural gas combined cycle units, or NGCCs) and pipeline installation!  In 2020, natural gas-fired generation from existing combined cycle units is projected to increase nine percent, from baseline.  In 2030, there will be a smaller increase and in 2050, a slight decrease.  Methane, as we know from NASA scientist Drew Shindell, is 105 times more potent a greenhouse gas than carbon, over a 20 year time frame. Fracking also causes suffering due to contaminated water, air, and soil.

According to page 2 -13 of the EPA document:

Operators have already shifted significant quantities of generation from coal units to NGCCs, absent any federal CO2 requirements. …[There is] the potential to increase the amount of lower carbon intensity generation by expanding low-carbon and renewable generating capacity… Adding new nuclear or renewable generating capacity to the electric system would tend to shift generation to the new units from existing EGUs with higher carbon intensity. Such expansion is consistent with current trends.

Recently, the EPA held public hearings about the Plan. While thousands traveled to testify in support of the plan, the United Mine Workers demonstrated outside a Carbon Rule hearing in Pittsburgh. They expressed concern about job loss.  I heard a lawyer representing the mine workers say, at a hearing in Washington, that he is also concerned about possible job loss. This is a legitimate concern.  Coal generation is projected to decrease between 16% and 17% in 2020.  Yet, according to EcoWatch’s June 2nd article, “Obama and EPA Release Historic Carbon Reduction Plan to Fight Climate Change,” coal and natural gas would still make up more than 60% of our energy grid.

An August 1st article, Dueling Rallies Pitts Jobs against Air in the Pittsburgh Post – Gazette, emphasized that millions of workers support the plan:

Kim Glas, executive director of the Blue Green Alliance, which counts 16 million environmental group and union members, said workers don’t have to choose between a clean environment or good jobs.  “Quality, family-sustaining jobs will be created throughout an economy that also addresses climate change,” Ms. Glas said. “We understand that workers need a fair shake. We will not leave workers behind as we transition to a more sustainable energy economy.

We need to be vigorous and vigilant to make sure that this commitment is honored; we must create a just transition to renewable energy.

Submit your comment about this plan to the EPA by Ocotober 16th of this year!  We only have ten days left!

Send e-mail to   with    “Docket ID: EPA-HQ-OAR-2013-0602” in subject heading. For full instructions, visit the EPA site.

 You may use the sample letter below. It’s best to personalize it.  For example, if you or a loved one suffers from asthma, include that as a reason to support the Plan. You may also use information in documents about the Carbon Rule found under Public Testimony on this blog.

Sample Letter

 Dear EPA,

I am so glad that there is, at last, a plan to regulate carbon emissions. I support the reduction of carbon, sulfur, methane and other toxins.

The plan should call for more rapid reductions than it does. Please use a more recent time frame (2009 or later), rather than 2005, as the baseline for emissions.

I am disturbed that the Plan calls for an increase in gas use. We should stop fracking (shale gas development) and, instead, make a swift and just transition to renewable energy (solar, wind, geothermal and biomass).


The deadline is October 16th. So please comment now — and make sure at least ten of your friends comment in the next ten days.

You know the Koch Brothers and their legendary “think tank” fake-grassroots organizations are getting in their comments. This is historic. Please make your voice heard!

One Comment
  1. stevebremner2014 permalink
    October 13, 2014 9:02 pm

    Thanks to Ann for doing so much sheer spadework and providing so many informational links. The old “I don’t know enough about it and/or don’t know how to research it” defense is no longer an option here. At time of posting this comment: 3 days left, last chance, comment to the EPA **NOW** people!

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