August 8, 2023
“New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule”
Docket ID No. EPA–HQ–OAR–2023–0072
Introduction and Summary of Comments
Business Roundtable is pleased to present comments on the Environmental Protection Agency’s (EPA) most recent proposed rule to limit greenhouse gas (GHG) emissions from fossil fuel fired electric generating units (EGUs).
Business Roundtable is an association of more than 200 chief executive officers (CEOs) of America’s leading companies, representing every sector of the U.S. economy. Business Roundtable CEOs lead U.S.-based companies that support one in four American jobs and almost a quarter of U.S. GDP. Through CEO-led policy committees, Business Roundtable members develop and advocate directly for policies to promote a thriving U.S. economy and expanded opportunity for all Americans.
Business Roundtable recognizes that human activities are contributing to climate change and that climate change poses significant environmental, economic, public health and security threats around the world, including to the United States. We also believe companies should lead by example to reduce GHG emissions where possible and help mitigate the risks associated with a changing climate.
Most Business Roundtable members have announced goals to be carbon neutral by 2050 or even before, including all those in the power sector that would be directly affected by this regulation. These commitments rely on significant grid decarbonization efforts. Business Roundtable shares EPA’s goal to reduce GHG emissions from the power sector as rapidly as it is feasible to do so while continuing to ensure reliable, affordable, and resilient supplies of electricity to power our economy.
As EPA notes in the preamble, the power sector is the second largest emitter of GHGs in the United States. It is also the sector that has reduced GHG emissions the most since 2005. The power sector plans to rapidly reduce GHG emissions even further, accelerated by provisions in the Inflation Reduction Act of 2022, favorable economics, state policy choices and other factors. The pace of the transition to lower GHG emitting resources has been constrained by many factors, including grid reliability concerns, transmission expansion challenges, generator interconnection study delays, insufficient technology development, inflation, lack of skilled labor availability, and other factors outside the control of the power sector.
Having affordable, reliable, resilient, and secure electricity sources is the foundation of the modern economy, and the importance of the electric sector will only grow as demand for clean electricity increases across major U.S. economic sectors, including buildings, transportation, and industry. In its current form, the proposed rule fails to provide adequate flexibility to address reliability and other concerns that may arise if the pace of technology development and deployment at scale is slower than anticipated by EPA. This concern is particularly urgent given the additional impacts of multiple recently proposed or final EPA regulations affecting the power sector, which will cause many large-scale dispatchable generation resources to be retired. We urge EPA to build additional flexibility into its final rule, to mitigate the risk of the rule adding to these reliability issues (a concern other organizations also have expressed).