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Ross Eisenberg Testimony for EPA Hearing 5/24

Ross Eisenberg Testimony for EPA Hearing 5/24

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NAM VP of Energy and Resources Policy Ross Eisenberg's testimony before the EPA on the NSPS for new power plants.
NAM VP of Energy and Resources Policy Ross Eisenberg's testimony before the EPA on the NSPS for new power plants.

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Published by: National Association of Manufacturers (NAM) on May 25, 2012
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05/25/2012

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Oral Comments: Public Hearing on EPA’s Proposed GHG NSPS for
Power Plants
 – 
May 24, 2012:
Good afternoon, my name is Ross Eisenberg, and I am Vice President of Energy and Resources Policy at the National Association of Manufacturers.The NAM is the largest industrial trade association in the U.S. representingover 13,000 small, medium and large manufacturers in all 50 states. TheNAM is the leading voice for the manufacturing economy in Washington,DC, which provides millions of high wage jobs in the U.S. and generatesmore than $1.7 trillion in GDP. In addition, two-thirds of NAM members aresmall businesses, which serve as the engine for job growth. Our mission is toenhance the competitiveness of manufacturers and improve American livingstandards by shaping a legislative and regulatory environment conducive toU.S. economic growth. We appreciate the opportunity to provide commentsat this public hearing.Through these proposed New Source Performance Standards for ElectricGenerating Units, the EPA is proposing a dramatic and fundamental changeto the scope and application of the Section 111 NSPS program under the
 
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Clean Air Act that will have long-term implications for energy andenvironmental policy in the United States.
Key Comments:
 
The NAM and our member companies are committed to protecting theenvironment through greater environmental sustainability, increasedenergy efficiency and conservation, and reducing greenhouse gasemissions. However, we know the U.S. cannot solve the climatechange issue alone. The establishment of federal policies to reducegreenhouse gas emissions must therefore be done in a thoughtful,deliberative and transparent process that ensures a competitive levelplaying field for U.S. companies in the global marketplace.
 
The
EPA’s proposed NSPS is a domestic
-only policy that sets adangerous precedent: that regulations, as opposed to the market,decide which fuels should be utilized in facilities, a precedent whichcould cascade to other manufacturing sectors. And despite the
EPA’s
assurances that the rule will not affect existing plants, the EPA in avoluntary settlement agreement has committed to regulate GHGemissions from existing facilities under the same provision, andgroups testifying today have urged the EPA to do so immediately.
 
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To issue this rule, the EPA must first make a finding that the source
category “contributes significantly to air pollution which may
reasonably be anticipated to endanger
 public health and welfare.” ThisClean Air Act requirement of “significant contribution” is a
fundamentally different finding than the EPA made in its priorendangerment finding for motor vehicles under Section 202, whichcannot be relied upon as a backdrop for this regulation of utilities. Yetthe
EPA’s proposal failed to make the necessary finding of significant
contribution of GHG emissions for the particular source category,which it is required to do here and for possible future regulations.
 
The
EPA’s
proposed standard of 1,000 pounds of CO2 per megawatt-hour does not reflect the best demonstrated technology for greenhousegas reductions from new conventional coal-fired power plants,although it can be accomplished by different types of power plants,namely natural gas plants and IGCC with carbon capture and storage.When applied to conventional coal-fired power plants, the
EPA’s
standard is inconsistent with the
EPA’s own Best Available Control
Technology (BACT) guidance for GHGs as well as plant-specificBACT determinations the EPA and states have made over the past 18months. Of particular concern to manufacturers is that some groups

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