The Center for Biological Diversity submits the attached comments (and sources cited therein) to the EPA in response to EPA's non-rulemaking Docket EPA-HQ-OAR-2022-0723, which includes questions to the public regarding EPA's upcoming rulemaking to reduce carbon dioxide emissions from existing power plants using Clean Air Act section 111(d). These comments support the need for stringent standards that make verifiable, substantial reductions to greenhouse gas (GHG) emissions. In setting the best system of emission reductions (BSER), EPA should recognize the significant drawbacks of carbon capture and storage (CCS or CCUS) technologies and incorporate environmental justice considerations in its rulemaking. In addition, we urge EPA to consider setting a National Ambient Air Quality Standard (NAAQS) for GHGs under Clean Air Act section 108 to more effectively combat the climate crisis and address emissions from multiple sources. Given the Supreme Court's recent decision in West Virginia v. EPA, 142 S. Ct. 2587 (2022), limiting EPA's ability to regulate power plant emissions under section 111(d), a NAAQS standard would better utilize the EPA's central authorities to address a broader range of emissions.
EPANonrulemakingEPA-HQ-OAR-2022-0723
Reducing Greenhouse Gas Emissions from New and Existing Fossil Fuel-Fired Electric Generating Units
RIN
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Last modified
Apr 5, 2023
Comment window
closed 1219d ago
Center for Biological Diversity filings
2
Activity
Center for Biological Diversity filed 2 comments on this docket between Apr 5, 2023 and Apr 5, 2023. 16 other organizations filed here. The comment window closed 1219d ago.
What Center for Biological Diversity filed (2)
Apr 5, 2023· Comment submitted by Center for Biological Diversity (1 of 2)· EPA-HQ-OAR-2022-0723-0048
Apr 5, 2023· Comment submitted by Center for Biological Diversity (2 of 2)· EPA-HQ-OAR-2022-0723-0049
The following is submission 2/2 for the Center for Biological Diversity. This submission finishes attaching our sources cited in our March 27, 2023 comment.
Abstract
Solicit Public Input on the Agency’s Efforts to Reduce Emissions of Greenhouse Gases from New and Existing Fossil Fuel-Fired Electric Generating Units
View on regulations.gov →Co-filers (16)
See everyone who commented →- Center for Biological DiversityTHIS ORG2 filings · confidence 97%
- American Public Power Associationtrade assoc.2 filings · confidence 97%
- Edison Electric Institutetrade assoc.2 filings · confidence 97%
- (AMP) and Ohio Municipal Electric Associationtrade assoc.1 filing · confidence 85%
- American Academy of Pediatrics (AAP)1 filing · confidence 97%
- American Petroleum Institutetrade assoc.1 filing · confidence 97%
- Appalachian School of Law Energy and Mineral Law Associationtrade assoc.1 filing · confidence 85%
- Basin Electric Power Cooperativeunverified attribution1 filing · confidence 70%
- National Association of Clean Air Agenciestrade assoc.1 filing · confidence 85%
- National League of Cities (NLC) and The U.S. Conference of Mayorstrade assoc.1 filing · confidence 85%
- National Mining Associationtrade assoc.1 filing · confidence 97%
- National Parks Conservation Associationtrade assoc.1 filing · confidence 85%
- Partnership for Policy Integritytrade assoc.1 filing · confidence 85%
- Power Generators Air Coalitiontrade assoc.1 filing · confidence 85%
- Southern Companyunverified attribution1 filing · confidence 70%
- The Petroleum Alliance of Oklahomatrade assoc.1 filing · confidence 85%
- West Virginia Rivers Coalitiontrade assoc.1 filing · confidence 85%