However, Commenters show evidence that the proposed CPP falls short of establishing a standard that is rigorous or well‐informed enough to yield meaningful atmospheric carbon reductions in the coming decades.
The Comments conclude with these summaries of the inadequacy of the EPA's current proposal:
V. SIGNIFICANT CARBON EMISSION REDUCTIONS ARE DEMONSTRABLY FEASIBLE AND COST‐EFFECTIVE IN ALL U.S. STATES BY USING RENEWABLES AND ENERGY EFFICIENCY.
EPA fails to recognize that it is both feasible and cost‐effective to reduce carbon emissions from EGUs by about 55% below 2005 levels by 2030. This is demonstrated in 48 state‐specific models, which are described in the IEER Comments, Section V.C. In addition, IEER has provided spreadsheets detailing the basis for its models. As discussed above, IEER’s models demonstrate that states can achieve greater carbon reductions than the targets proposed by EPA, relying primarily on efficiency and renewable energy. This can be done at costs of carbon reduction per metric ton of CO2 equivalent that are generally lower than those in the Clean Power Plan. Despite 2030 emission reductions being over two‐and‐a‐half times greater (relative to 2012), IEER estimates that the IEER Climate Protection Plan would cost only about $3.3 billion more in 2030, or about $9 per person. Benefits, in terms of reduced health costs and lower damages in other areas would increase by tens of billions of dollars. IEER Comments, Section V.C.3.
VI. CONCLUSION AND RECOMMENDATIONS
For the foregoing reasons, EPA should return the CPP to the drawing board and correct the legal and technical deficiencies identified in these comments, the IEER Comments, and the Cooper Comments. The EPA should re‐issue a revised CPP that sets substantially more stringent targets for carbon emission reductions, that eliminates reliance on natural gas and nuclear energy, and that prepares the way for more significant carbon emission reductions in the future by relying much more heavily on renewable energy sources.
The full 26- page legal filing is available at https://www.nirs.org/climate/background/commentsonepacppby32orgs12114.pdf
Exhibit A, 71 pages in length, from IEER documents the criticisms of the EPA's proposed rule, and is available at https://www.nirs.org/climate/background/ieercommentsregardingepacpp12114exhibita.pdf