Comments From Supporters Of EPA's New Power Plant Rule

My last post highlighted two lengthy comments submitted to EPA by groups of states critical of the agency’s recently-proposed “Power Plant Rule.” (EPA’s official title: “New Source Performance Standards for GHG Emissions from New and Reconstructed EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean Energy Rule.” ). The Rule seeks to eliminate, or nearly so, all greenhouse gas emissions from electric power plants, by some time in the 2030s. The comments that I highlighted delve into substantial technical detail, giving serious reasons why EPA’s proposed transformation of the country’s electricity generation system is unlikely to work and poses severe risks to the people’s electricity supply.

What about on the other side? Are there any comments on the proposed Rule that are supportive of the Rule, and that even contend that its restrictions on use of fossil fuels to generate electricity should be made more stringent, and/or advanced in time? The answer is that there are many such comments.

But how do these supportive comments deal with the problems identified in the critical comments? What do they say about risks to the reliability of electricity supply, or about the potential for greatly increased costs? The answer, as far as I can determine, is that they can’t be bothered addressing such issues.

I’ll freely admit that I haven’t attempted to read all the comments, of which there are now some 618. Rather, I have sought out a few from groups that appeared likely to be supportive of the Rule. So here are three such comments: one from something calling itself the U.S. Healthcare Climate Council; a second from the American College of Obstetricians and Gynecologists; and a third from a consortium of healthcare groups in Wisconsin described as “American Academy of Pediatrics - Wisconsin Chapter, Cream City Medical Society, Healthy Climate Wisconsin, et al.”

The “U.S. Healthcare Climate Council” may sound like some sort of official body, but as far as I can determine it is just a lobbying group based outside of D.C. that uses the cover of “healthcare” to push for elimination of fossil fuels. (Here is their website if you want to investigate further.). Here is their position on the proposed Rule:

We strongly support the EPA using their authority in sections 111(b) and (d) of the Clean Air Act to set these new pollution standards that would require fossil fuel power plants to reduce their GHG emissions for the first time and recommend that the standards be as strong as possible to protect human health and prevent the worst climate change impacts from occurring.

(Bold is in the original.). So what are the “climate change impacts on human health” they are talking about? There’s this:

A strong limit on power plant carbon pollution would also protect those patients who are most vulnerable, including children, older adults, those with health conditions, and people with lower incomes and communities of color who feel the health harms of climate change soonest and most intensely.

How exactly does that work? They don’t say. Hey, everybody know it. Read on and you come to this:

The proposed rules would result in up to $85 billion in net climate and health benefits, while preventing 1,300 premature deaths and over 300,000 cases of asthma attacks by 2030.

And what is the source? The link goes to EPA’s own “fact sheet” on the proposed Rule! As far as I can determine, the numbers are completely made up by government advocates, and certainly the “U.S. Healthcare Climate Council” has not checked them in any way. Since when does CO2 cause asthma? Hey, EPA says it, so it must be true.

And how about the issue of whether the emissions reduction goals are achievable on the stated timescale? These guys don’t deal with that, but that doesn’t stop them from advocating for shorter deadlines and more stringent requirements in every respect: “Increase the number of gas plants covered by the rule. . . . Move up compliance timelines so that power plants must reduce their emissions this decade. . . .”

As to the American College of Obstetricians and Gynecologists, you might wonder what expertise they have in anything related to climate change or how electricity is generated. The answer is that they have none, but that doesn’t keep them from showing their virtue here. Here’s their statement of why they are commenting:

As climate change continues to adversely affect the well-being of women, people seeking obstetric and gynecologic care, families, and communities, ACOG supports greater recognition of and investment into addressing the effects of the environment on public health. Specifically, ACOG in its position statement [c]alls on our national and international leaders to act to curb greenhouse gas emissions and limit further climate destabilization. . . . Greenhouse gas emissions accelerate climate change, which poses a serious threat to American’s health and well-being. . . .

Do they have any proof of this made-up nonsense?

In 2030 alone, nationwide the proposed standards would prevent: approximately 1,300 premature deaths; . . . more than 300,000 cases of asthma attacks. . . .

It’s the exact same bullshit projections cribbed from EPA’s own “fact sheet” and parroted back to them with no independent thought or research. And in conclusion:

Rapid emissions reductions are therefore required to limit damage to global ecosystems which provide essential services necessary for human wellbeing and societal stability.

I like the “therefore” in that sentence. No support for the proposition was provided in anything that preceded it.

And finally for today we have the comment from a large coalition of environmental and health groups from Wisconsin, which include Evergreen Action, Healthy Climate Wisconsin, Green Neighbor Challenge, the Wisconsin Chapter of the American Academy of Pediatrics, and many more. The gist:

[O]ur organizations urge the EPA to set the strongest possible safeguards on carbon pollution by early next year. While the agency’s current proposal is a good start, we ask the EPA to strengthen it in three ways: 1) require power plants to reduce their emissions more quickly, 2) apply the pollution safeguards to a wider number of gas plants, and 3) ensure communities have input on how the pollution safeguards are implemented at power plants.

And get ready for the health impacts of climate change:

Carbon pollution from the fossil-fuel industry drives climate change and leads to poor air quality and increasingly negative health outcomes, including respiratory disease, heart disease, and insect-borne infectious diseases.1 According to the National Institute of Environmental Health Sciences, poor air quality as a result of climate change can harm respiratory and cardiovascular systems. These health impacts include hypertension, coronary artery disease, heart attack, and stroke.2

And where does any of that come from? Footnote 1 goes to yet another EPA self-serving advocacy piece, “Climate and Human Health.” Footnote 2 goes to a similar piece from NIH.

Now, I don’t wish anybody a premature death, but this advocacy has completely lost its way. EPA has somehow ginned up a number of 1300 premature deaths per year that it thinks it can prevent by shutting down an electricity generation system that works and replacing it with something that has not been demonstrated to work or even been subject to a feasibility study. Last year there were 3,274,000 deaths in the U.S., so 1300 would be 0.04%, and they would appear to be counted by EPA even if the death is premature by only one day. How EPA knows that an imperceptible change in temperature could cause these deaths is an excellent question.

Meanwhile, what about the benefits of a reliable electricity supply? Is it really possible that we so completely take that for granted, like it’s just a fact of life? If we suddenly start having blackouts that last for weeks or months, how many people are then going to die prematurely? Hundreds of thousands per year, that’s how many.