As the public comment period closed late last year for the Environmental Protection Agency’s “Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units” rule, National Ready Mixed Concrete Association and the Associated Builders & Contractors joined a host of business interests raising concerns of the proposal’s increased costs and limited benefits, especially on greenhouse gas reduction claims.
EPA proposed “Carbon Pollution Emission Guidelines” or the Clean Power Plan (CPP) in June 2014, aiming for a final version in mid-2015. The agency estimates that the rule will reduce power sector carbon dioxide emissions by about 30 percent over the next 16 years, using 2005 emissions levels as a base. “This goal is achievable because innovations in the production, distribution and use of electricity are already making the power sector more efficient and sustainable while maintaining an affordable, reliable and diverse energy mix,” the agency contends.
In its comments, NRMCA projects “significant downstream costs … for electricity customers. When taking into consideration the energy cost increases stemming from the proposal, the cost of purchasing and mixing key ingredients for ready mixed concrete will be inevitably higher and result in unnecessary overall price increases. For the ready mixed concrete industry alone, this would be devastating and equally burdensome for residential, commercial or government [market] customers.”
NRMCA concludes its comments with rhetorical questions: “If EPA does not know how the rule will truly impact electric utility companies or their customers, or others downstream, how can [the agency] truly know what, if any, benefits the rule holds, and if that relates to a reasonable justification for the rule’s finalization? The clear language in EPA’s proposal stating doubts about the rule’s impact on electric utility companies and their customers, contrary third party analysis, EPA’s reliance on ‘illustrative estimates,’ and the lack of consideration for small entities begs the question of how and why EPA can in good faith and conscience proceed with finalizing such a proposal without all the requisite and proper information?”
As a part of the Partnership for a Better Energy Future, ABC and other business organizations whose members represent more than 80 percent of the U.S. economy argued in their comments that CPP is not compatible with numerous practical and technical aspects of America’s electricity system. In order to foster continued growth and take full advantage of the nation’s energy potential, the Partnership urges EPA to withdraw the rule and instead use a comprehensive energy approach to support the continued provision of reliable and affordable electricity.
Additional Partnership arguments opposing the rule or concerns surrounding the White House’s approach to greenhouse gas emissions reduction include: the country’s need of an “all-of-the-above” energy strategy; increased energy prices and lower power supply reliability; the potential to drive manufacturing to less efficient countries, resulting in a net global GHG emissions; troubling precedent for future regulation of other industry sectors; and, absence of poll data showing Americans’ support for EPA’s GHG reduction strategy.