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ACC Response to EPA’s Proposed Section 111(d) Rule
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ACC Response to EPA’s Proposed Section 111(d) Rule Announced June 2, 2014

The administration’s latest move to force carbon dioxide restrictions on existing electric generating plants is another unfortunate chapter in the push to restrict the use of coal in America. At the rollout of the proposed rule, EPA Administrator Gina McCarthy dismissed critics concerned about the rule’s high costs and threats to electric grid reliability with a simple “They’re wrong.”[i] However, numerous economic and energy experts have demonstrated the detrimental impacts of policies aimed at reducing coal use. For example, a recent IHS study for the U.S. Chamber of Commerce predicts that EPA CO2 rules will cause the loss of 224,000 jobs annually, increase electricity costs by $289 billion, and lower household incomes by over $500 billion.[ii]

Furthermore, EPA’s proposed rule will have no meaningful impact on global CO2 emissions or environmental conditions. The same U.S. Chamber study indicated that projected U.S. reductions represent “a mere 1.8 percent of global CO2 emissions, which IEA predicts to otherwise grow by 31 percent.”[iii] A unilateral U.S. regulatory mandate to reduce carbon will not dissuade other countries from using coal, and the U.S. will suffer severe economic impacts while CO2 emissions rise rapidly elsewhere.

Additionally, this rule will not provide the health benefits claimed by EPA. The alleged health benefits associated with this rule are in fact disingenuous “co-benefits” that EPA has already attributed to its other multi-billion dollar coal plant emissions reductions regulations.[iv]

This rule will have serious negative impacts on economic and social conditions, compounding the difficulties faced by an American economy struggling to come out of a prolonged downturn.[v] Ironically, fossil energy development has been a primary driver of our economic recovery to date.[vi] By diminishing coal use, this rule reduces energy diversity, security, and reliability – all of which negatively impact electricity affordability. Unfortunately, this rule will most heavily impact the poor, the elderly, small businesses, and domestic manufacturing.

A primary goal of federal energy policy should be the development and production of efficient, affordable, reliable domestic energy resources. Any federal climate goal to reduce carbon emissions from coal plants could best be met by a strong federal commitment to continued coal technology development. This would demonstrate global leadership far better than rushed regulations that will unnecessarily harm the economy, eliminate good jobs, and reduce America’s energy and electricity security.

[iii] Ibid.



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