Emmett Institute on Climate Change & the Environment

Grid Expert Comment Letter Opposing Repeal of Clean Power Plan

Cara Horowitz, Ann Carlson, William Boyd, (University of Colorado Law School), Nathaniel Logar

CEN_EMM_PUB_Grid Expert Comment Letter
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On April 25, 2018, Cara Horowitz, Nat Logar, & Ann Carlson of UCLA Law School’s Emmett Institute on Climate Change and the Environment, together with William Boyd of University of Colorado Law School, submitted a comment letter to the U.S. Environmental Protection Agency with and on behalf of five electric grid experts: Benjamin F. Hobbs, Brendan Kirby, Kenneth J. Lutz, James D. McCalley, and Brian Parsons. The comment letter opposes EPA’s proposal to repeal the Clean Power Plan to regulate carbon dioxide emissions from existing fossil-fuel-fired electric generating units.

The grid experts' comment letter argues that the Clean Power Plan respects and effectively harnesses the unique features of the electric grid and is consistent with the twin aims of the grid: power reliability and affordability for all consumers. In response to EPA’s proposal to repeal the plan, the letter argues that the Clean Power Plan is the most reasonable way to pursue carbon dioxide regulation from existing power plants. The design of the Clean Power Plan is eminently sensible: it reflects the regional nature of the power system, facilitates familiar compliance approaches such as emissions trading, and gradually accelerates industry trends already underway, as aging coal-fired units are replaced with cheaper, cleaner natural gas and renewable energy generation. Repeal of the Clean Power Plan would impede, not advance, power reliability and affordability.