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Repeal of Carbon Dioxide Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Electric Utility Generating Units; Revisions to Emission Guideline Implementing Regulations; Revisions to New Source Review Program
Activity
League of Women Voters filed 10 comments on this docket between Jan 12, 2018 and Nov 20, 2018. 295 other organizations filed here. The comment window closed 2827d ago.
What League of Women Voters filed (10)
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The proposed rollback of EPA's first-ever regulation of emissions of greenhouse gases (GHGs) from the power sector, better known as the Clean Power Plan, will have devastating long-term effects on the health and welfare of the Southeast region of the United States. Over the past decade, Alabama coal-fired power plants produced an average of 76,3000,00 tons of carbon pollution each year. Power plants in Alabama contributed to 58% of statewide CO2 emissions . Southern Company, the parent company of Alabama Power, ranked third in a list of contributors to greenhouse gases . The Miller Plant, owned and operated by Alabama Power Company and operating in Jefferson County, Alabama, is listed as the number one facility within Southern Company contributing to this ranking . In fact, this same Miller Plant is the third largest carbon emitting coal-fired power plant in the country . According to NOAA, 2017 resulted in over $306 billion in damages across the country-- the most expensive year on record--due to weather and climate events around the country. Increased damage due to cold snaps, stronger more frequent tornadoes, and intense and longer hurricane storm events will be expected in the Southeast if carbon emissions are not reduced. Alabama, for example, has no plans to address future climate risks or implement adaptation strategies . In addition, Alabama has failed to dedicate any "state funding, policies, or guidelines to improve resilience against climate change-related extreme heat, drought, wildfire, or coastal flooding ." By proposing these changes, EPA is ignoring its responsibility to current and future generations. The Clean Power Plan will produce tremendous climate and public health benefits that far outweigh its costs. The LWV of Alabama opposes any weakening of the Clean Power Plan and recommends allowing the current rules to stand as originally proposed.
HEARING ON THE CLEAN POWER PLAN IN WILMINGTON, DE ON JANUARY 8, 2018 Re: Docket ID Number EPA-HQ-OAR-2017-0355 These comments are focused on the proposed repeal of the Clean Power Plan. Good morning. My name is Chad Tolman, and I'm speaking on behalf of the League of Women Voters of Delaware. The Delaware League strongly opposes the federal government's stated goal of repealing the Clean Power Plan (CPP), and recommends that Delaware continue to reduce carbon emissions from its power sector through RGGI (the Regional Greenhouse Gas Initiative), and from its transportation sector through the 8-state Transportation and Climate Initiative (TCI). We also support strengthening state goals for reducing greenhouse gas emissions from all sources, and strengthening the goals for its Renewable Portfolio Standard. The Clean Power Plan was the cornerstone of the previous administration's attempt to significantly reduce U.S. carbon dioxide emissions. Carbon dioxide (CO2) is the most important of the greenhouse gases, and electricity generation is the sector of the U.S. economy that produces the largest share. That is not true for all of the states; Delaware, along with eight other Northeast and Mid-Atlantic states have decreased their total power plant emissions under RGGI by over 40% since 2009. Their emissions from transportation now exceed those from power generation. President Obama tried to reduce transportation emissions by requiring greater fuel efficiency from the vehicle fleet. However, along with pulling out of the Paris Climate Agreement and threatening the CPP, President Trump has promised to eliminate higher fuel efficiencies. The Paris Agreement was the first one in history where all of the world's nations - except for the U.S. - agreed to try to reduce their emissions enough that the global average temperature would not rise more than 2C above what is was in 1750. The temperature has already risen by more than 1C, and will continue to increase by an unknown amount, even if we were to stop all human caused emissions now. Rather than stopping, global emissions are rising every year. Two degrees is the internationally agreed limit, beyond which we should not go, if we are to avoid serious damage to the climate system. With just a little over 1, we already have unprecedented droughts, wildfires, rainfall, flooding and hurricane damage. Some estimates of the damage in 2017 caused by Hurricanes Harvey, Irma and Maria are as high as $245 billion. That's over $700 for every man, woman and child in the United States. Revoking the CPP will be especially damaging for Delaware. We are the canary in the mine. We have a very long coastline relative to our area; the average elevation is the lowest of any state in the nation, and the coast is sinking even in the absence of global sea level rise, which has been projected to be as much as 6.6 feet by 2100. The amount will depend heavily on what happens to the Arctic and Antarctic ice sheets, which are losing ice at accelerating rates. More powerful storms resulting from warming seawater will add higher storm surges to rising seas, with potentially devastating effects on Delaware's coastal communities. Hurricane Sandy, which was expected to make landfall in Delaware, went farther north and did great damage to New Jersey and New York instead. The storm surge in New York raised the water level at the Battery tide gauge in Manhattan by nine feet above the normal high tide. But for the grace of god, we would have taken the brunt of the storm. Delaware spends millions of dollars every year to replenish beach sand in the absence of major storms. According to Senator Carper, our beaches attract tourists who add $6.9 billion each year to the state's economy - more than the total state budget - and employ 10% of our workforce. The Delaware Sea Level Advisory Committee found that a 4.9 feet rise in sea level would inundate 11% of Delaware's land area, 99% of its coastal wetlands, 73% of the Port o…
LEAGUE OF WOMEN VOTERS OF MARYLAND, INC. 111 Cathedral Street, Suite 201 Annapolis, MD 21401 410-269-0232; info@lwvmd.org; www.lwvmd.org TESTIMONY TO THE ENVIRONMENTAL PROTECTION AGENCY To: https://www.regulations.gov/comment?D=EPA-HQ-OAR-2017-0355-0002 .(for the docket 'Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units') POSITION: Oppose BY: Elaine A. Apter and Richard B. Willson DATE: January 10, 2018 The League of Women Voters of Maryland wishes to call to your attention the following facts and reasons for retaining (and enforcing) - not repealing - the Clean Power Plan: 1.Our planet is in serious trouble already due to the factors that are causing climate change. 2.We should not be putting corporate polluters ahead of the general population. 3.Implementing the 2015 version of the Clean Power Plan would have avoided 3,600 premature deaths and 90,000 pediatric asthma attacks each year according to 17 national health and medical organizations. Just doing nothing on CPP would have cost Americans this many health problems; the Pruitt policy now proposes a path that will further increase the public harm. 4.Analyses by Harvard and Syracuse Universities find that the now-proposed 'inside the fence line' approach will make air quality worse and endanger more lives than doing nothing at all. 5.The policy's intent of propping up the fossil fuel industries is at odds with job creation as well. Currently, the clean energy sector provides five times as many jobs as the fossil fuel industries. 6.The proposed policy change will also slow our nation's progress on solving the climate change problem. 7.EPA has a responsibility under the law to regulate carbon, having determined that carbon endangers the health of the American public. This legal obligation has been affirmed by the Supreme Court. 8.We support the implementation of the 2015 Clean Power Plan and its robust use of clean energy options -- not inadequate measures installed at existing power plants as now proposed. 9.Walking back our nation's carbon policies fails current and future citizens of the US, harming public health, communities, and the environment, and slowing economic growth - a lose-lose-lose outcome for America. 10.There is no indication that the proposed CPP withdrawal is based on current scientific evidence -- or indeed on any scientific evidence at all. 11.Failing to address climate change now sentences our grandchildren to suffer more violent storms, more wildfires, food shortages, water shortages, sea level rise, ecosystem destruction, and disease spread due to climate change. It cannot be right to disregard the effects of our actions today on the welfare of our grandchildren.
As a member of the League of Women Voters of Glen Ellyn, Illinois, here are my comments regarding the Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units. By repealing the Clean Power Plan, the White House is putting the interests of corporate polluters ahead of the health and safety of the American public. This decision will have a devastating impact on the planet at a time when we are seeing the powerful climate change effects with rising temperatures, deadly hurricanes and destructive wildfires. The League is appalled at this irresponsible decision that will have a long-term devastating impact on our planet and health of the American people. The EPA is legally required to regulate carbon, a finding upheld by the Supreme Court in 2011. Simply repealing the Clean Power Plan without replacing it with other carbon regulations would have been subject to legal challenge. Instead the Trump/Pruitt EPA has cynically devised a weak approach to carbon regulation in an attempt to satisfy its legal obligations without achieving meaningful greenhouse gas reductions. This proposed action would replace the flexible and effective approach proposed under the Obama administration with an inflexible 'inside the fenceline' approach which will cost more and have less impact. 'Inside the fenceline' measures - those which can be installed at existing power plant facilities - take renewable and energy efficiency options off the table. These are the least expensive options for reducing greenhouse gas emissions and should be maximized, not prohibited as options under federal policy. The 'inside the fenceline' approach will harm Americans more than simply not implementing the 2015 Clean Power Plan. Analysis by Harvard and Syracuse Universities finds that the proposed 'inside the fenceline' approach will make air quality worse and endanger more lives than doing nothing at all. The Pruitt proposal would actively sacrifice public health and wellbeing and create new air pollution hotspots around the nation. Implementing the 2015 version of the Clean Power Plan would have avoided 3600 premature deaths and 90,000 pediatric asthma attacks each year according to 17 national health and medical organizations. Just doing nothing on CPP would have cost Americans this many health problems; the Pruitt policy now proposes a path that will further increase the public harm. The policy's intent of propping up the fossil fuel industries is at odds with job creation as well. Currently, the clean energy sector provides five times as many jobs as the fossil fuel industries. Slowing this growing sector of the economy fails Americans economically as well as environmentally. And this policy change will also slow our nation's progress on solving the climate change problem, gutting a plan designed to reduce carbon emissions 32% by 2030 and replacing it with a proposal that could never accomplish similar results. EPA has a responsibility under the law to regulate carbon, having determined that carbon endangers the health of the American public. This legal obligation has been affirmed by the Supreme Court. The current proposal takes steps to weaken EPA's regulation of carbon, an abdication of this legal responsibility to the citizens of the US. The proposed 'inside the fenceline' approach is inadequate and costly. It will limit potential emissions reductions and increase the costs of every ton of avoided carbon. We desire a policy that does more, not less, to reduce carbon pollution and that makes it more feasible, not less, to do so at a reasonable cost. Weakening federal carbon regulation will cost thousands of Americans their health. This approach also raises the costs borne by American citizens by excluding lower cost energy efficiency and renewables options. The flexible approach proposed under the 2015 Clean Power Plan is superior for reducing carbon emissions and containing costs.…
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Abstract
The EPA is taking action to repeal the Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (EGUs), commonly referred to as the Clean Power Plan, as promulgated October 23, 2015. The EPA is also proposing the Affordable Clean Energy rule which would establish emission guidelines for states to develop plans to address greenhouse gas emissions from existing coal-fired power plants. The ACE rule would replace the 2015 Clean Power Plan, which EPA has proposed to repeal because it exceeded EPA's authority.
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- SL University of Detroit Mercy Studentunverified attribution1 filing · confidence 70%
- Social Justice & Engineering Initiative Corporationunverified attribution1 filing · confidence 70%
- Solar Energy Industries Associationtrade assoc.1 filing · confidence 85%
- Southern Companyunverified attribution1 filing · confidence 70%
- Southern Illinois Power Cooperativeunverified attribution1 filing · confidence 70%
- Steven J. Milloy Inc.unverified attribution1 filing · confidence 70%
- Sustainable Food Policy Alliancetrade assoc.1 filing · confidence 85%
- Tampa Electric Companyunverified attribution1 filing · confidence 70%
- Tennessee Mining Associationtrade assoc.1 filing · confidence 85%
- Texas Public Foundation (TPPF) on behalf of Morning Star Packing Companytrade assoc.1 filing · confidence 85%
- Texas Public Policy Foundationtrade assoc.1 filing · confidence 85%
- Texas Public Policy Foundation on behalf of Morning Star Packing Companytrade assoc.1 filing · confidence 85%
- The AES Corporationunverified attribution1 filing · confidence 70%
- The Energy & Environment Legal Institutetrade assoc.1 filing · confidence 85%
- The National Medical Associationtrade assoc.1 filing · confidence 85%
- Theresa Pugh Consulting LLCunverified attribution1 filing · confidence 70%
- Tri-State Generation and Transmission Associationtrade assoc.1 filing · confidence 85%
- Tribal Council Chairwomantrade assoc.1 filing · confidence 85%
- U.S. Chamber of Commerce1 filing · confidence 97%
- U.S. Green Building Counciltrade assoc.1 filing · confidence 85%
- U.S. Industrial Pellet Associationtrade assoc.1 filing · confidence 85%
- U.S. Tire Manufacturers Associationtrade assoc.1 filing · confidence 85%
- Union for Reform Judaismunverified attribution1 filing · confidence 70%
- University California Los Angeles School of Law UCLA School of Lawunverified attribution1 filing · confidence 70%
- University of Detroit Mercy BSN Nursing Studentunverified attribution1 filing · confidence 70%
- University of North Carolina School of Law Environmental Law Projectunverified attribution1 filing · confidence 70%
- University of Pennsylvaniaunverified attribution1 filing · confidence 70%
- University of Virginia School of Lawunverified attribution1 filing · confidence 70%
- University of Virginia School of Law for National Trust for Historic Preservation in the United Statesunverified attribution1 filing · confidence 70%
- University of Washingtonunverified attribution1 filing · confidence 70%
- Utah Mining Associationtrade assoc.1 filing · confidence 85%
- Vectren Corporationunverified attribution1 filing · confidence 70%
- VF Corporationunverified attribution1 filing · confidence 70%
- Vice President of Environmental Protection and Restoration Chesapeake Bay Foundationtrade assoc.1 filing · confidence 85%
- Ward 1 Council Member et al.trade assoc.1 filing · confidence 85%
- Waterkeeper Alliancetrade assoc.1 filing · confidence 85%
- Western Energy Alliancetrade assoc.1 filing · confidence 85%
- Western Governors Associationtrade assoc.1 filing · confidence 85%
- WindSoHy LLCunverified attribution1 filing · confidence 70%
- Wyoming Business Alliancetrade assoc.1 filing · confidence 85%
- Wyoming Mining Associationtrade assoc.1 filing · confidence 85%
- Xcel Energy Inc.unverified attribution1 filing · confidence 70%