Open Letter to the EPA
By Stephen Heins, 2015
Postponing the Release of their Clean Power Plan Rules rules for Cuttng Emissions for New Power Plants, Existing and Modified Power Plants.
First, the EPA should be applauded for postponing the release of their Clean Power Power rules for cutting emissions for new power plants, existing and modified power plants. They acknowledged that there are
"cross-cutting topics," stated Janet McCabe, the EPA's acting administrator for air quality. After all, The EPA has received over 4,000,000. Q responses since they announced their "Clean Power Plan."
Also, the EPA has received legal challenges from 13 states, plus the filings of Laurence Tribe. /Peabody
Coal, Murray Energy et all. Then, there is matter of reinventing the national electrical grid and new transmission to replace aging infrastructure, where most transmission operators think it will take 15 years to comply.
In that same news release, it said that the "EPA has consistently met or exceed the federal requirements for energy efficiency, fuel use, renewable energy, and other high-performance sustainable building metrics. In 2013, for example, EPA exceeded the 24 percent energy intensity reduction from its FY 2003 baseline, reducing its FY 2013 energy intensity by 25.6 percent from FY 2003. In FY 2013, EPA alsoreduced fleet petroleum use by 38.9 percent compared to the FY 2005 baseline, exceeding the goal of 16 percent."
Also, in the States, the 50 separate Public Utility Commissions (and their National Association of Regulatory Utility Commissioners) have been responsible for working with state governments, power plant operators, business community, state environmental groups, consumer groups and transmission companies to provide the electricity to power the largest economy in the world. For example, 47 states have demand-side energy efficiency projects, all with measurable results, 38 states have Renewable Portfolio Standards (RPS), 10 states have voluntary market-based Green House Gas (GHG) emission trading programs and numerous large individual companies Publicly Traded Utility Companies have been pursuing voluntary emission reduction strategies.
Experts like William Yeatman of the Competitive Enterprise Institute believes that the EPA should continue a policy of "Cooperative Federalism" by using the "normal tools of government" including the electoral process.
It seems to me that a more balanced approach would wait until the,Supreme Court decides on the constitutionality of your new rules.
Uncertainty has hung over the whole electricity sector, which has led to utility regulators and regulated utilities to develop two quite different plans in case the entire EPA is struck down by the Supreme,Court later in June 2015.
As I review the pertinent documents, I can't help noticing that several of the EPA's assertions could be debated. For example, in the EPA News Release of October 31, 2014, it talks about the impacts of climate change across the country, "ranging from more severe droughts and wildfires to record heat waves and damaging." One could easily argue that none of the events need necessarily be caused global warming. In fact, there is no detailed scientific evidence to ascribe “climate change" to these natural events.
While the global warming pause of the last 15 years has been addressed by more than a dozen theories including NASA, none of them have created a comprehensive enough theory to even roughly approximate the complex planet we inhabit. In a recent presentation at conference of the American Meteorological Society in Phoenix, EPA Administrator Gina McCarthy said that "Science is under attack like it has never been before." One doesn't have been "global warming denier" to take some exception to that broad statement. Science continues its dialectic with itself, as it has and should.
The only thing settled is that nobody has predicted the future with much accuracy. We are told that no one can use local, regional or national weather patterns to make prediction about the future, still Administrator
McCarthy went on to emphasis that the time for arguing about climate change has passed: "There is some advantage to being 60 and part of that is I can remember how the world was when I was a child, McCarthy
said, "if you don't think it is changed you're kind of nuts."
Who has the legal and controlling power to enforce new rules to any or all of these changes: State utility regulators, Federal Energy Regulatory Commission. What's the hurry?
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Steve Heins
The Word Merchant, LLC
530 Wilson Avenue
Sheboygan, WI 53081