                 Summary of Region 6 Public Listening Session 
                          on 111(d) for Power Plants
                                       
                        November 7, 2013  -  Dallas, TX

On November 7, 2013, EPA Region 6 held a public listening session to obtain public input on how EPA can craft carbon pollution standards from existing power plants.  Approximately 400 people attended the meeting, and of those attendees, 222 people spoke.  

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

Overview

Regional Administrator Ron Curry and Deputy Regional Administrator Sam Coleman welcomed participants and offered opening remarks.  There were two, concurrent sessions.  Wren Stenger, Director of the Multimedia Planning and Permitting Division, and Tom Diggs, Chief of the Air Programs Branch, offered an overview of Clean Air Act section 111(d).  Trained facilitators moderated the sessions.

Of the total participants at the listening session, approximately 42% represented themselves or non-governmental organizations (NGOs) other than specifically environmental, 38% represented business and industry, 12% represented environmental NGOs, 6% represented government, and 2% represented unions.

Participants included Texas House representatives, companies, industries, local officials, municipalities, small businesses, churches, environmental groups, NGOs, citizens, and college students. 
We heard from local governments and citizens that they support power plants in their communities for the economy, jobs, emergency services, fire departments, and schools.  Solar and wind companies and specialists advised that energy portfolios should continue to expand to include renewables at paces from immediately and exclusively to a moderate incorporation time frame.  The Dallas County Medical Society supported EPA creating stringent carbon emission standards due to asthma, cancer, and sensitive populations.  (In October, the DCMS petitioned the TCEQ for more stringent air emission controls for three coal-fired power plants.)  

Many electric cooperatives stated that doing anything that impacts electric costs, reliability, and capacity would devastate towns and communities across Texas.  Some college students and youth organizations stated that EPA needs to shut down coal power plants now or implement very strict limits. Some churches, ministries, and preachers said that EPA must take care of the earth and the health of people.  People with sick spouses, children, and friends implored EPA to control air emissions.  Suggested approaches for future guidelines included market-based, carbon tax or fee with the tax/fee returned to consumers, state-by-state plans not one-size-fits-all, and enforcement that would actually reduce emissions.

Naturally, there were positions on the both ends of the discussion.  First, the environmental groups asked that EPA proceed without delay to implement strict emission standards or to shut down all coal power plants.  A few speakers suggested that paying more for electricity would be acceptable to them.  Second, some electric cooperatives and industry representatives discussed the importance of keeping electric costs low, considering the extreme differences in Texas weather and rural areas than in other parts of the country, and keeping the economy healthy and growing. Most of the speakers that were citizens or had small businesses near coal power plants encouraged EPA to proceed carefully so as not to impact jobs, towns, and people's livelihoods. Third, speakers expressed the importance of balance between the environment and the economy as EPA develops its position. The importance of affordable electricity, capacity, and reliability for now and into the future must be maintained for states to grow and prosper.  Most speakers wanted good air quality, but cautioned that a rash approach would be more harmful to people than a more flexible, long term plan.  Some speakers wanted to shut down all use of coal and fossil fuels.  Some recognized that facilities were old and should be shuttered, while others offered that older facilities should be allowed to continue for their design life.  Speakers questioned both the "junk" and "good" science as the foundation for climate change.  

Speakers generally thanked EPA for the opportunity to provide input at this early stage and asked that EPA keep the public involved. It was suggested that public stakeholders be included in a workgroup or team that will draft the guidelines.  

The following summary is divided into two parts:  a summary of comments generally supportive of the proposed carbon standard and a summary of comments generally in opposition to the proposed carbon standard.  In each part, the comments are included under general category topics.  Language of the commenters is frequently included In order to capture the essence of their concerns.    
  
Comments generally in support of EPA's proposed carbon standard for existing power plants

					
Health concerns

   * Human health is more important than jobs or economics, and global warming is a human health threat.  Climate change is happening and will get worse.  Asthma and lung cancer are related concerns.  Coal is not a fuel the U.S. should be investing in for the future; coal plants will adapt, but children and grandchildren will not. 

   * Diseases are likely to increase due to increased heat from climate change.  

   * Emissions from power plants particularly impact poor, minority neighborhoods.  Consider environmental justice in decision-making for the carbon standard.

		
   Other implications of climate change; climate change science 

   * Climate change is causing drought and raising costs in health care and food.  

   * Extreme weather is being caused by climate change, including tornadoes and flooding; climate change is causing at least a 33% increase in weather damage.  Summer 2011 drought and wildfires in Texas and 2013 floods are examples.

   * EPA should follow the science and make strong rules for existing power plants.  Science findings are definite.  If we can keep CO2-e concentrations under 450 parts per million, then we may have a 50-50 chance of avoiding the worst climate change impacts.  Invest in clean air.  Gas-fired power plants are better. Support the President's Climate Plan.

   * We are facing a human civilization crisis due to climate change.  Small towns will be without water in 3-5 years, 50% of reservoirs are less than 50% full, NOAA in 2009 said current climate changes are reversible only in 1000 years, and 2060 temperatures will be 4 degrees C above pre-industrial baseline.  Climate change has created refugees, with 600 million expected by 2050.  Do something now.  EPA must be true to its mission.  This is a national problem, not just a local problem.

		
Proposed carbon standard and other regulatory actions

   * EPA regulations should aggressively reduce greenhouse gas emissions. Export of coal to other nations is not desirable as it only transfers the problem of coal elsewhere.  However, carbon standard application should not be done arbitrarily and should minimize financial harm and electricity rate increases.  Incentivizing power plants to reduce emissions is good.  Also, EPA should allow for regional flexibility.

   * Regarding the proposed carbon standard, speakers mentioned that EPA should give States emissions credit for work their Public Utility Commissions and Departments of Environmental Quality have already done to encourage lower-emitting and renewable energy sources.  They also suggested EPA use a 2005 baseline for carbon reduction calculations. 

   * We need to be entirely rid of fossil fuels.  Set a shutdown date for coal plants.  Coal plants have an efficiency of 32% and similar to that of the 1970s.  Recent air pollution episodes in China demonstrate the importance of dealing with emissions from coal plants.

   * A carbon tax is a good idea; stop subsidies to coal, oil and gas industries.  Clean air is actually good for business.

   * Texas leads the nation in carbon emissions; action needs to be taken in Texas in particular.
			
Alternative energy
	
   * Alternative energy, such as solar and wind, and hydrogen and energy efficiency should be encouraged and are allies to EPA in this carbon standard process; no nuclear plants.  Decentralized energy production would be more beneficial.  Transitioning to clean energy will create jobs.
					
Jobs 

   * Loss of jobs is not as big an issue as some industries are touting; also, such losses are not necessarily related to a carbon standard.  Texas' biggest power company already is getting ready to file for bankruptcy and is worried it won't be able to take care of its workers.
				
Other pollution and sources

   * Other sources, such as fracking, also contribute to greenhouse gas emissions.

   * Other pollutants besides carbon dioxide are important and should also be addressed  -  such as methane, mercury, ozone, particulate matter.  Dallas-Fort Worth area ozone is worsened by coal plants.  Many people are affected by those health effects.  Also EPA needs to be concerned about clean water.
				
Overall concern

   *  Our moral responsibility is not to exploit the Earth but to care for it.


Comments generally in opposition to EPA's proposed carbon standard for existing power plants
				
Impacts on the economy and jobs

   * Carbon standards for existing coal-fired plants will bring severe economic hardship to towns that depend on them for property tax (37% of one county's taxes is paid by the local coal-fired power plant), direct employment in power plants and coal mines (these are high-paying jobs in rural areas), sales taxes, and ancillary employment in smaller companies.  Housing prices are directly associated with availability of these jobs.  Local public schools and hospitals are supported by these taxes as well. Many of these areas are just now emerging from the 2008-2010 economic recession.

   * The rule should find ways to save jobs that are imperiled by the new standard, and Texas will need more time to comply.

   * Municipal power agency in Texas is voluntarily reducing carbon emissions without regulation; coal-fired electricity is cheap power, and this agency has been operating for 30 years but is still paying off debt and the other air pollution control equipment.  Rush to a carbon standard may well imperil financial status of this municipal power agency.

Technology required under the proposed standard and practicality

   * Carbon capture and storage (CCS) will be necessary for coal plants, and this is not commercially practical.  No coal-fired plants will ever meet a CCS requirement.

   * New carbon standard will not be achievable or sensible.  EPA should carefully consider the liabilities of this rulemaking.  There could be considerable, unintended consequences.

   * EPA's role is to control pollutants, not to force specific technologies.  Any proposal should be subject to strict cost/benefit analyses.

   * The U.S. needs China and India to join in on a carbon pollution solution.  While energy efficiency is a good idea, imprudent solutions that result in tens of thousands of megawatts in coal-fired electricity generation being lost in the U.S. are not the answer.  Rule should encompass all environmental impacts, and EPA should not rush the rule-making.
					
Electricity prices

   * Cost of electricity for all consumers will increase (including economically impoverished families), as well as on other industries that produce goods for people, thereby raising prices on those goods.  The standards will also negatively impact reliability and safe, cheap generation in the entire grid.

   * Rural consumers of electricity, who are typically less prosperous than urban dwellers, will bear much of the economic burden for this standard.  70% of electricity from rural electric cooperatives comes from coal. Fuel-switching is not a practical alternative for many of these rural cooperatives.  EPA should particularly focus on impacts on rural electric cooperative operators.  There may be a 40% increase in annual consumer electricity prices for rural electric cooperative customers with this standard.
		
Need for electricity reliability and balanced energy portfolio

   * EPA should promote diversity in electricity production and not create one law for all the States that does not distinguish among differences in the states.  Coal and nuclear should be parts of that portfolio. Coal should remain the major way to generate electricity.

   * Texas needs a balanced energy portfolio, as it is growing very rapidly.  For example, shale gas production, which is a State-wide economic driver, relies on availability of cheap electricity.  Reliability is a big concern, and blackouts may result with closing coal-fired plants.  By 2018, Texas will fall below its reserve margin target under a moderate growth scenario, so a balanced energy portfolio is essential.
		
Need for flexibility and market-based alternatives

   * States need to be given the maximum amount of flexibility in complying with any such carbon standard.  For example, states should be allowed to take credit for renewable energy resources.  Perhaps EPA should allow states to develop their own guidelines and be allowed deviations from these.

   * Employing market-based alternatives in any rule is very important.  Carbon should be controlled more thoroughly where the costs are less expensive rather than at facilities where it would be more expensive.  

   * If this rulemaking goes forward, EPA should use accurate baselines and ensure states receive credit for early actions.

   *  The Clean Air Act is not the appropriate means with which to reduce greenhouse gas emissions.  EPA should set emission targets on what is reasonably defensible.  Consider grandfathering too.

	
Climate science and the role of greenhouse gases

   * State of the science:  Recent paper in Climate Dynamics by Wyatt (University of Colorado) and Curry (Georgia Tech) shows that the dynamics of global climate is such that there are 300-year natural cycles and much of climate variability is due to this, not greenhouse gas emissions.  The Wyatt-Curry paper accounts for the current 17-year "lack of global warming."  Don't rush into rule changes, but focus on knowing science better.  The current models EPA relies on don't seem to reflect reality.

   *  Greenhouse gases are beneficial to the Earth and are not problem-causers.
