Clean Power Plan
Section 111(d) - Greenhouse Gas Regulation




This rule is as much a state energy policy as it is an environmental regulation and a clear overreach by the Environmental Protection Agency to achieve the Administration's goal of cutting coal from America's electric portfolio. 


EPA’s “Clean Power Plan” represents the biggest obstacle to continued coal use that has confronted the industry in decades.  Although it is billed by proponents as a flexible and achievable way for states to curb GHG emissions, it is a de facto attempt to transform America’s energy usage away from coal.


To achieve the final goal, Pennsylvania would have to reduce carbon emissions by 34 percent over 2012 levels. 




Last year global coal use grew by 3 percent, faster than other fossil fuel, an obvious indication that other countries are embracing, not turning away from coal. In the U.S., the destruction of the coal industry has been targeted as the silver bullet to climate change, but combined, carbon emissions from U.S. coal-fired power plants account for less than 3 percent globally, according to an analysis by the American Coalition for Clean Coal Electricity using EPA data. According to testimony from the Institute for 21st Century Energy, the Energy Information Administration reports non-U.S. carbon emissions — which already represent 82 percent of global emissions —are projected to grow by 41 percent between 2010 and 2030.  Essentially, the EPA’s proposed rule will offset the equivalent of 13.5 days of Chinese emissions in 2030, based on U.S. Department of Energy projections.


The United States is the only country among the top energy producers to have reduced carbon emissions in the last decade. As we reduce our consumption of coal, paying the annual compliance cost of $5.4-$7.4B in 2020, rising up to $8.8B in 2030, according to the U.S. Chamber, developing countries will be strengthening their economies on the back of coal. Even more disconcerting is that as we are forced to divest from coal and electric rates increase, jobs in energy intensive trade-exposed industries such as steel, manufacturing and chemicals that Pennsylvania relies on will go overseas where electricity from coal-fired power plants is cheaper, but the process is far less environmentally friendly than the U.S. We will essentially be moving the emissions globally, losing the economic benefit and adding more carbon emissions to the same air. The U.S. Chamber of Commerce estimates the cost of compliance will be $51 billion in lost gross domestic product annually. 





EPA held an open comment period which ended December 1, 2014 (extended from the original comment period close of October 16, 2014). You can view some of the official comments submitted from Pennsylvania in the bar to the left or at our blog post here. 


In Pennsylvania, H.B.2354 (Act 175), sponsored by Rep. Pam Snyder (D-Fayette/Greene/Washington) allows for the inclusion of the state legislature, educated parties and hearings to ensure all aspects and outcomes are considered before DEP drafts the SIP and Pennsylvania adopts the Clean Power Plan. Click here to view the PCA bill passage press release. 


On August 3, 2015, EPA posted the final rule regulating carbon emissions from existing plants, commonly referred to as the "Clean Power Plan". 

Despite the fact that EPA has not yet published the rule in the Federal Register, PA DEP is pushing ahead with the development of a State Implementation Plan. A comment period will be open through November 12, 2015.  You can submit your comment here

Additionally, DEP has scheduled 14 listening sessions statewide. So that we can best coordinate our efforts and remind DEP of the negative impacts of this rule on jobs, the economy, the cost and reliability of electricity and Pennsylvania's position as an energy leader, please let us know if you plan on attending one or more of these sessions here. 



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“Because of the potential effects on fuel diversity, energy prices and other consumer effects, DEP believes that such policy decisions are better left to the United States Congress or other elected officials. ...As proposed, the Clean Power Plan could leave residential, commercial, and industrial U.S. Consumers exposed to less reliable, more expensive, and more volatile electric markets in the future. ”

                                                  -Pennsylvania Department of Environmental Protection


“...the EPA has not given sufficient consideration to the impacts its proposal will have on organized electricity markets and the challenges that the proposal presents to system reliability and the economy.”


                                                        - Pennsylvania Public Utility Commission 

"We should try to achieve an EPA policy as it relates to Pennsylvania as well as other states that doesn't put that kind of burden on ratepayers.”

                                                                                                             - Senator Bob Casey

“We are concerned that proposed federal emission standards will create power shortages and increase the cost of the power that is available. “We saw that exact scenario last winter, which threatened reliability and caused huge price increases.  If we fail to learn from our experience, shame on us.”

                              - David Taylor, Pennsylvania Manufacturers' Association

“Coal is a domestically sourced, low-cost form of energy which helps sustain jobs for Pennsylvania and beyond. Over the decades, coal-fired plants also have gone to impressive lengths to reduce emissions. Nevertheless, the Obama administration continues to implement policies that will make energy more expensive for hard-working Pennsylvanians while destroying good, family-sustaining jobs.”

                                                                                           - Senator Pat Toomey


“Unfortunately, the EPA's proposal threatens Pennsylvania's biggest competitive advantage, which is low energy prices. The proposal threatens to drastically change the way Pennsylvania produces and uses energy. This change is likely to come with a significant economic impact to the business community, as well as threaten reliability across the grid.”

                                                                             - Kevin Sunday, Pennsylvania Chamber