Comment Letter from Technological Innovation Experts on EPA's ACE Rule Proposal


Sean Hecht submitted a comment letter on behalf of technological experts addressing EPA’s proposal to weaken pollution standards for power plants.

March 18, 2019
|
Sean Hecht

On October 23, 2015, EPA finalized emission standards for new coal-fired power plants under Section 111(b) of the Clean Air Act. The rule was intended to achieve reductions in pollution by setting emissions standards based on the level of emissions achievable by the best system of emission reduction. In late 2018, EPA proposed amendments that would significantly weaken the 2015 Rule.

On March 18, 2019, Sean Hecht submitted a comment letter on behalf of experts in technology innovation, diffusion, and pollution control, arguing that EPA’s proposal to weaken pollution standards for new and modified coal-fired power plants violates federal law, and the prior standard, adopted by the agency in 2015, is the proper one. The law is intended to ensure that new plants adopt effective pollution-control technology, promoting diffusion of that technology and associated improvements in public health and welfare. The commenters conclude that the new Proposed Rule, which incorporates only outdated efficiency improvements and not adoption of the adequately demonstrated technology of partial carbon capture and storage, is arbitrary and capricious.

Download

News
See All
May 06, 2025

NRDC and Waterkeepers File Petition to Enforce the Law on Threatened Colorado River

Read More
Apr 24, 2025

Wielding the Power of ISRs: Using Indirect Source Rules to Fight Pollution from Mega Facilities

Read More
Oct 17, 2024

Amicus Brief in West Virginia et al v. U.S. EPA et al for grid experts

Read More