In short, the CPP is fundamentally incompatible with numerous practical and technical aspects of America’s electricity system, and would represent a vast expansion of the agency’s regulatory reach into the authority held by states and other federal regulatory agencies. The Partnership urges the Subcommittee to ensure EPA addresses the following concerns and develops a path forward that supports American jobs and the economy, maintains electric reliability, and allows all energy sources to play a role in our energy future.
States, which are ultimately tasked with implementing EPA’s proposal, have filed detailed comments that reveal widespread concerns about the design, content, and legality of the approach the Agency has proposed. A summary of official state comments developed by the U.S. Chamber of Commerce found a majority of states have raised numerous fundamental concerns with the rule. For example, 32 states questioned the legality of the rule, 32 states raised reliability concerns, 34 object to EPA’s rushed regulatory timelines, 33 object to the rule’s lack of credit for actions taken prior to 2012, and 40 states questioned the achievability of at least one of the “building blocks” upon which the rule is based. The extent and magnitude of these concerns illustrate that EPA must make major changes to its rule before finalization. If the fundamental flaws with the rule identified by states are left unaddressed, the end result will be a significantly more expensive, less reliable electricity system that will have negative repercussions across the entire U.S. economy.
If the Administration adopts policies that substantially increase the cost of energy – thereby decreasing the competitiveness of U.S. industries – investments and emissions will be sent to other, less efficient countries with higher CO2 emissions intensities.
The Partnership appreciates the opportunity to testify on this critically important matter. In light of the concerns summarized above, the Partnership strongly urges the Subcommittee to take any and all budget and policy actions necessary to reduce the threats EPA’s rule poses to the U.S. electricity system as well as the broader economy. Thank you.