                 Summary of Region 4 Public Listening Session 
                          on 111(d) for Power Plants
                                       
                       October 23, 2013  -  Atlanta, GA

On October 23, 2013, EPA held listening sessions in Atlanta to solicit ideas and input from the public and stakeholders about the best Clean Air Act approaches to reducing carbon pollution from existing power plants. A total of 156 people attended the two sessions and 75 people spoke.

A high-level summary of the meeting is provided below.  

Overview:

EPA Region 4 Acting Regional Administrator Stan Meiburg and Acting Deputy Regional Administrator Beverly Banister  provided opening remarks for the afternoon and evening sessions.  Acting Director Jeaneanne Gettle and Deputy Director Carol Kemker of the Air, Pesticides and Toxics Management Division also provided remarks and moderated both listening sessions.  

Speakers included and represented utilities, concerned citizens, faith-based organizations, unions, consumer advocates, environmental groups, community groups, students, public health groups, and energy groups.  
                                       
Setting the Standards:

Fuel Mix  
   * Guidelines need to promote a balanced portfolio consisting of nuclear, hydro, coal and natural gas
   * Nuclear power should be treated the same as any other renewable energy source in the regulations
   * Coal plant could add solar and eliminate need to add carbon capture and storage
   * Power should be both reliable and affordable coal is an important component to US power portfolio
   * Take a go-slow approach and urges growth-based approach that considers all energy sources esp. coal 

Flexibility 
   * States need flexibility to design and implement the program 
   * Sec. 111(d) requires EPA to set guidelines-not standards; don't set arbitrary goals/targets
   * Consider what is best for country in long term and not set a "one size fits all" guideline 
   * States should have primacy to develop performance standards
   * States should be able to use flexible compliance mechanisms
   * Environmental groups cautioned against extending too much flexibility to state agencies for rule implementation
   * The standards should be able to be updated in the future
   
Technology and the Fence Line
   * Performance standards should be achievable by individual sources and based on affordable control measures that have been demonstrated
   * No trading programs, no offsets from other work; limit actions to what can be done inside the fence line
   * Allow for outside the fence line actions such as DSM, the use of cap and trade and permit auction mechanisms 
   * Guidelines and standards need to be based on adequately demonstrated technology/BSER (no CCS)
   * Include renewable and efficiency standards for power plants and remove regulatory barriers to efficiency improvements 
   * Should not allow averaging within a facility boundary
   
Reduction Baseline 
   * Several commenters said guidelines should allow states to take credit for CO2 reductions that are already in process from shutdowns and other actions. 
   
Timing 
   * EPA should give states ample time to fulfill rule-making roles and give sources time to comply. Three years was suggested as a reasonable timeframe for states to develop the 111(d) plans.
   * The guidelines should provide incentives for early adoption of standards
   
Cost/Benefits
   * EPA should not use the social costs of carbon to justify the cost and benefit of the guidelines.
   * EPA's social costs of carbon calculations have not been peer reviewed and violate OMB guidelines.

Comments related to why EPA SHOULD pursue regulation of GHGs from existing power plants, included:

1. Adverse Effects of Climate Change  
   * False choice that we must choose between public health and a strong economy; we must do both
   * Science shows clear impacts.  
   * Climate change damages economy  -  significant costs to: adapt to rising sea levels; rebuild after increasingly severe weather events; make up for reduced crop yields, etc.
   * Carbon standards will result in a reduction in O3, SO2 and PM2.5 and ultimately in asthma incidences.

2. Underrepresented Populations
   * Poor people are more likely to live in polluted areas, and will benefit more from these regulations
   * These rules will be good for low income communities and communities of color, who are disproportionately affected by climate change.
   * Coal is linked to poverty in KY
   
Comments related to why EPA SHOULD NOT pursue regulation of GHGs from existing power plants, included:

Economic Impacts:

1. Affordability 
         *       EPA should not take any action that will increase costs of rate payers 
*       Customers can't afford higher utility bills
*       Hardest hit would be those with a low household income
*       12 to 25 percent of their customers are below the poverty  
*       Rural areas may be most impacted. Electric companies have an obligation to serve sparsely populated areas which have high distribution costs. This should be considered in the guidelines
*       Coal fired generation provides supply certainty and minimizes increases on electricity prices
   
2. Impact on Business
   * Businesses need reliable/affordable energy; not having coal as option will undermine business confidence
   * EPA regulations would have chilling effect on ability to attract new industry and jobs
   * Costs of doing business in US will increase and send more jobs overseas
   * Rules should not will impact business profitability and competitiveness

3. Stranded plants  -  Several noted that EPA guidelines would cause premature closures of coal-fired units 
   
4. Job Losses
*       Supporters of the coal industry warned that EPA's actions will result in job losses from coal fired electric generating plant closures
*       One commented that many unions jobs would be lost if coal plants are shut down due to EPA rules -- EPA should avoid loss of jobs at plants which have invested billions in pollution controls.

Science:

 1.    Limited impact 
         *       Several noted that climate change is a global issue and because of the limited contribution of US emissions to global CO2, the rule won't have much of an impact. Also, no action is needed because power companies are already retiring coal capacity and increasing natural gas use.

 2.    Climate Change is Not Happening/Not Bad  
   * CO2 is not a pollutant, it is a necessary element
   * Global warming is not bad.  Cold is dangerous and causes death.
   * EPA erroneously assumes that CO2 is the primary cause of climate change.  Temperature has not changed in 16 years.  Antarctic ice is at record levels.  

 3.    Legal Authority 
   * EPA lacks authority under CAA to regulate GHGs

 4.    Fuel Mix 
   * Stop the war on coal; coal is cheap and abundant in the US
   

Elected Official Participation 
   * Two Georgia State Representatives attended with opposing views on EPA's action.  The proponent cited national security concerns and the opponent cited costs and jobs concerns. 

No Listening Sessions in Rural Areas
   * Several individuals noted that EPA is not holding meetings outside metro areas but these rules will impact rural citizens the most and they can't attend these meetings



