21st Century Engery

 

Dear Chamber Executive: 

 

In case you missed it, the U.S. Chamber's Institute for 21st Century Energy released an analysis of state concerns with the Environmental Protection Agency's (EPA) proposed greenhouse gas regulations (GHG) for existing power plants last week. 

As you know, in December, EPA closed the regulatory docket on the rule after receiving a record two million public comments. Key among those are the comments submitted by all 50 states most notably from state environmental agencies and public service commissions that are responsible for overseeing electricity issues. 

The Energy Institute's analysis reviews these state responses in detail and summarizes 12 of the most significant and common themes raised during the comment period. It found that a majority of states raised concerns or objections in 8 of those 12 issue areas. For example, 

 

• 32 states raised fundamental concerns with the rule's legal foundations
• 28 states warned of negative economic impacts
• 32 cited threats to electricity reliability
• 30 states objected to EPA's aggressive interim compliance targets
• Also of note, 40 different states questioned the achievability of at least one of the agency's four proposed "building blocks" upon which the rule is based

 

We think the untold story of the rule is the extent and magnitude of state concerns. The analysis highlights and illustrates how these collective state concerns demonstrate the strong need for EPA  to go back to the drawing board. 

 

We hope this analysis will provide a useful resource for your Chamber, the broader business community, policymakers as well as advocates working to develop ongoing state positions on the rule as EPA proceeds toward finalization. 

The complete analysis, broken down by state, can be found on the Energy Institute's website.It includes: 

 

• Example concerns raised by states
• References and links to all state docket filings  
• A downloadable worksheet of more than 800 comments filed by states and notable stakeholders 

 

If you would like more information on our analysis or EPA's greenhouse gas regulatory agenda, please contact me or Dan Byers. 

Sincerely,

Sue Forrester
Director of Outreach and Advocacy
Institute for 21st Century Energy
U.S. Chamber of Commerce