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NO BENEFITS


  • In 2013 the U.S. electric sector emitted 2.05 billion metric tons of CO2, representing approximately 4% of global anthropogenic greenhouse gas emissions.xix




  • Analysis based on another EPA rulemaking shows that the climate effects of the EPA proposal are meaningless. For example, the atmospheric CO2 concentration would be reduced by less than 0.5%; global average temperature increase would be reduced by less than 2/100ths of a degree Fahrenheit; and sea level rise would be reduced by 1/100th of an inch (the thickness of three sheets of paper).xx




  • To justify the EPA proposal, its supporters argue the U.S. must show global leadership in reducing CO2 emissions. However, other countries are abandoning pledges to reduce emissions or increasing emissions regardless of their pledges. According to the Washington Post, many industrialized countries are not expected to meet their commitments to reduce CO2 emissions.xxi


November 19, 2014



i U.S. Energy Information Administration, Electric Power Monthly, February 2014.

ii Ibid.

iii National Mining Association, http://www.countoncoal.org/states/.

iv Eugene M. Trisko, Energy Cost Impacts on Tennessee Families, January 2014.

v Ibid.

vi Ibid and The 60 Plus Association, Energy Bills Challenge America’s Fixed-Income Seniors, 2014.

vii ACCCE, Coal Unit Shutdowns as of October 23, 2014. Retirements and conversions are based on public announcements by the coal unit owners.

viii The percentage reduction is relative to emission rates in 2012. The Tennessee emissions rate goal is from Table 8, pages 346 – 348, of EPA’s proposal, and 2012 emission rates are found in EPA’s Goal Computation Technical Support Document, June 2014. http://www2.epa.gov/sites/production/files/2014-05/documents/20140602tsd-goal-computation.pdf.

ix EPA, GHG Abatement Measures technical support document, June 2014. EPA assumes the heat rate of every coal-fired electric generating unit can be improved by 6%.

x EPA, Technical Support Document (TSD) for the CAA Section 111(d) Emission Guidelines for Existing Power Plants: Goal Computation Technical Support Document, June 2014, Appendix 1.

xi Ibid.

xii EPA, Technical Support Document (TSD) for the CAA Section 111(d) Emission Guidelines for Existing Power Plants: GHG Abatement Measures, June 2014, Table 4.9.

xiii EPA, Regulatory Impact Analysis for the Proposed Carbon Pollution Guidelines for Existing Power Plants and Emission Standards for Modified and Reconstructed Power Plants, June 2014, Table 3.3.

xiv September, 9, 2014 letter signed by the governors of Alabama, Alaska, Arizona, Idaho, Indiana, Mississippi, New Mexico, North Carolina, North Dakota, Oklahoma, Pennsylvania, South Carolina, Utah, Wisconsin, and Wyoming to President Obama; Petition for Review, West Virginia v. EPA, Case No 14-1146 (D.C. Cir. filed Aug. 1, 2014); Brief of the States of West Virginia, Alabama, Alaska, Kentucky, Nebraska, Ohio, Oklahoma, South Carolina, and Wyoming as Amici Curiae in Support of the Petitioner, In Re: Murray Energy Corporation v. EPA, Case No. 14-1112, (D.C. Cir. filed June 25, 2014); and Perspective of 18 States on Greenhouse Gas Emission Performance Standards for Existing Sources under § 111(d) of the Clean Air Act, signed by 17 Attorneys General and the Commissioner of the Indiana Department of Environmental Management, September 11, 2013. Additionally, one or both legislative bodies in 19 states (including Tennessee) have passed bills or resolutions opposing the approach that EPA has taken, and state officials in other states have sent comments to EPA opposing its approach.

xv NERA Economic Consulting, Potential Impacts of the EPA Clean Power Plan, October 2014. An annual average increase of 14% means that electricity prices are projected to be 14% higher each year, on average, under EPA’s proposal than electricity prices would be in the absence of the proposal.

xvi EPA Clean Power Plan: Costs and Impacts on U.S. Energy Markets, Energy Ventures Analysis, August 2014 http://www.countoncoal.org/states/

xvii NERA Economic Consulting, Potential Impacts of the EPA Clean Power Plan, October 2014.

xviii North American Electric Reliability Corporation, Potential Reliability Impacts of EPA’s Proposed Clean Power Plan: Initial Reliability Review, November 2014; Midwest Independent System Operator, Clean Power Plan: MISO Analysis Update for ADEQ/APSC Stakeholder Meeting, October 1, 2014; Southwest Power Pool, Grid Reliability and Transmission Buildout Issues, presentation to Arkansas DEQ Stakeholder Meeting, October 1, 2014; Electric Reliability Council of Texas (ERCOT), ERCOT Analysis of the Impacts of the Clean Power Plan, November 17, 2014; and American Electric Power, Transmission Challenges with the Clean Power Plan, September 2014.

xix IPCC, Climate Change 2014: Mitigation of Climate Change: Contribution of Working Group III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change; EIA, Monthly Energy Review, February 2014.

xx ACCCE, Climate Effects of EPA’s Proposed Carbon Regulations, June 2014.

xxi Steven Mufson, All over the planet, countries are completely missing their emissions targets, (September 23, 2014) http://www.washingtonpost.com/blogs/wonkblog/wp/2014/09/23/all-over-the-planet-countries-are-completely-missing-their-emissions-targets/

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