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CLEAN ENERGY GROUP
Clean Energy Group Comments on EPA's Proposed Rules on Greenhouse Gas Emissions Limits for Power Plants

August 10, 2023

The Environmental Protection Agency (EPA) is proposing changes to the Clean Air Act related to greenhouse gas emissions from fossil fuel-fired electric generating units. Clean Energy Group (CEG), along with nine partner organizations, has submitted comments expressing concerns about the potential impact of these proposed changes.  

The proposed rules would require new power plants as well as existing baseload plants to either install carbon capture and storage (CCS) technology with a 90% capture rate or begin combusting a blend of hydrogen and natural gas to meet EPA greenhouse gas regulations. Neither CCS nor hydrogen meet the requirements to be considered a viable pathway for emissions reduction. CCS is only in operation at one active power plant in the world, and the technology has never sustained a 90% emissions capture rate (source). What's more, the additional fuel required to power the technology leads to an increase in nitrogen oxide (NOx) emissions of anywhere from 5%-60% which the technology does not capture (source). Combusting hydrogen also leads to an increase in NOx emissions of six times that of natural gas (source). Hydrogen itself is also an indirect greenhouse gas that has a short-term global warming impact 35 times higher than carbon dioxide (CO2) (source). The proposed rules also exclude peaking power plants from consideration and fail to include battery storage, a proven emissions reduction technology, as a recommended tool for reducing emissions. 

"The EPA's proposed rules favor expensive and unproven technologies with questionable climate benefits," said Seth Mullendore, CEG President and Executive Director. "Instead of accelerating the country's shift away from fossil fuels, the EPA's embrace of hydrogen and carbon caption will further exacerbate the climate crisis and prolong existing environmental injustices." 

"Carbon capture and storage and hydrogen have not been tested in power plants at scale, but what we do know about these technologies is that they are dangerous, polluting, and antithetical to climate goals," said Abbe Ramanan, Director of CEG's Hydrogen Information and Public Education initiative. "At best, pushing these technologies will extend a reliance on fossil fuels and resign communities to decades more of air pollution. These rules do not go far enough in considering hydrogen's indirect global warming potential, negative environmental impacts, and limited efficacy at reducing CO2 emissions, nor do they adequately address the emissions and safety concerns associated with using CCS technology. Putting forth CCS and hydrogen as viable technologies for reducing emissions recklessly plays with the health and well-being of the communities around these plants." 

"The EPA's proposed rules do not sufficiently regulate emissions for peaker power plants, which are heavily polluting and are often located in low-wealth neighborhoods and communities of color," noted Shelley Robbins, Director of CEG's Phase Out Peakers initiative. "These plants are slowly poisoning their neighbors with emissions that evade control. The rules also do not include battery storage added to power plants as a way to reduce greenhouse gas emissions. Including peaker plants and allowing battery storage for reducing emissions at all power plants, but especially for peakers, would halt this kind of neighborhood pollution, saving lives and improving community health outcomes." 

CEG's comments are available to read at: www.cleanegroup.org/publication/comments-epa-ghg-emissions-limits-power-plants

CONTACT: Samantha Donalds, Clean Energy Group, sam@cleanegroup.org  

About Clean Energy Group:  

Clean Energy Group (CEG) is a leading national nonprofit advocacy organization focused on accelerating an equitable and inclusive transition to a resilient, sustainable, clean energy future. CEG works at the forefront of energy innovation to address the urgency of the climate crisis while strengthening historically marginalized communities through enabling greater access to and ownership of clean energy technologies. Founded in 1998, CEG has been a thought leader on effective climate and clean energy strategies for more than two decades, filling a critical resource gap by advancing disruptive energy initiatives and serving as a trusted source of technical expertise and independent analysis in support of communities, nonprofit advocates, and government leaders working on the frontlines of climate change. www.cleanegroup.org  

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Clean Energy Group

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