'Affordable Clean Energy' rule could result in more than 1,600 more premature deaths
Iowa Attorney General Tom Miller, part of a coalition of 26 states, counties, and cities, called on the Environmental Protection Agency to abandon its proposed replacement to the Clean Power Plan, the first nationwide limits on climate change pollution from existing fossil-fueled power plants, one of its largest sources.
In extensive comments filed with EPA, the coalition charges that the proposed replacement rule is replete with factual inaccuracies, analytical errors, and legal flaws and, accordingly, concludes that the rule, if adopted, would be unlawful.
Miller noted that Iowa was well prepared to comply with the Clean Power Plan. Wind provided 37 percent of Iowa’s total electric generation in 2017, a larger share than in any other state. In addition, coal's share of net electricity generation in Iowa declined from 76 percent in 2008 to 45 percent in 2017.
“A combination of smart federal and state policies have contributed to the rapid growth of renewable energy in Iowa,” Miller said. “The Trump administration will endanger this progress by replacing the Clean Power Plan.”
In the comments, the coalition stresses the overwhelming scientific evidence of human-induced climate change and its increasing impacts, and the corresponding need for EPA to perform its duty under the Clean Air Act to set nationwide limits on power plant emissions of climate change pollution. The coalition argues that any contention by the Trump EPA that the federal Clean Air Act requires it to discard the Clean Power Plan in favor of this proposal reflects an unlawful interpretation of the act. Further, the coalition argues that if EPA’s position is that it simply prefers its replacement rule as a matter of policy, such a position would be indefensible in light of the serious harm EPA acknowledges the proposed rule would cause to public health and the environment.
According to EPA’s own analysis, the replacement proposal could actually increase emissions of climate change pollution and other harmful pollutants from power plants. EPA estimates that up to 61 million more tons of carbon dioxide would be emitted from the power sector under the proposed rule in 2030, as compared with the Clean Power Plan. EPA further acknowledges that the proposed replacement rule, as compared to the Clean Power Plan, would cause power plants to emit up to 39,000 more tons of nitrogen oxides and 53,000 more tons of sulfur dioxide in 2030.
The additional air pollution EPA predicts will occur under its proposed replacement rule will mean that hundreds or thousands more people will die prematurely, suffer asthma attacks, and miss school and work. According to an EPA analysis, the replacement rule would result in up to an additional 1,630 premature deaths, 120,000 asthma attacks, 140,000 missed school days, and 48,000 lost work days in 2030, compared with under the Clean Power Plan. The increases in deaths and illnesses that EPA itself predicts will occur as a result of its replacement rule will fall disproportionately on “environmental justice communities,” low-income communities and communities of color already overburdened by pollution.
As the comments also discuss, EPA has completely turned its back on the successful experience of many states, such as Iowa, to significantly reduce carbon pollution from power plants while growing their economies and maintaining reliability of the electrical grid.
According to comments Iowa submitted to the EPA, wind supports around 8,000-9,000 jobs in Iowa. More than $13 billion has been invested in wind power and there are 11 wind-related manufacturing facilities in Iowa. Annual land lease payments total more than $20 million.
The Clean Power Plan is the culmination of a decade-long effort by partnering states and cities to require mandatory cuts in the emissions of climate change pollution from fossil fuel-burning power plants under the Clean Air Act. The Clean Power Plan, along with the companion rule applicable to new, modified, and reconstructed power plants, would control these emissions by setting limits on the amount of climate change pollution that power plants can emit. The Clean Power Plan would eliminate as much climate change pollution as is emitted by more than 160 million cars a year -- or 70 percent of the nation’s passenger cars.
In addition to Iowa, these new comments were filed by the attorneys general of New York, California, Connecticut, Delaware, Illinois, Maine, Maryland, Massachusetts, Minnesota (by and through its Minnesota Pollution Control Agency), New Mexico, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, Virginia, Washington, and the District of Columbia, and the cities of Boulder, Colo.; Chicago; Los Angeles; New York; Philadelphia; and South Miami and Broward County, Fla.