Comments From Supporters of EPA’s New Power Plant Rule


Francis Menton

My last post highlighted two lengthy comments submitted to EPA by groups of states critical of the agency’s recently-proposed “Power Plant Rule.” (EPA’s official title: “New Source Performance Standards for GHG Emissions from New and Reconstructed EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean Energy Rule.” ). The Rule seeks to eliminate, or nearly so, all greenhouse gas emissions from electric power plants, by some time in the 2030s. The comments that I highlighted delve into substantial technical detail, giving serious reasons why EPA’s proposed transformation of the country’s electricity generation system is unlikely to work and poses severe risks to the people’s electricity supply.

What about on the other side? Are there any comments on the proposed Rule that are supportive of the Rule, and that even contend that its restrictions on use of fossil fuels to generate electricity should be made more stringent, and/or advanced in time? The answer is that there are many such comments.

But how do these supportive comments deal with the problems identified in the critical comments? What do they say about risks to the reliability of electricity supply, or about the potential for greatly increased costs? The answer, as far as I can determine, is that they can’t be bothered addressing such issues.

I’ll freely admit that I haven’t attempted to read all the comments, of which there are now some 618. Rather, I have sought out a few from groups that appeared likely to be supportive of the Rule. So here are three such comments: one from something calling itself the U.S. Healthcare Climate Council; a second from the American College of Obstetricians and Gynecologists; and a third from a consortium of healthcare groups in Wisconsin described as “American Academy of Pediatrics – Wisconsin Chapter, Cream City Medical Society, Healthy Climate Wisconsin, et al.”

The “U.S. Healthcare Climate Council” may sound like some sort of official body, but as far as I can determine it is just a lobbying group based outside of D.C. that uses the cover of “healthcare” to push for elimination of fossil fuels. (Here is their website if you want to investigate further.). Here is their position on the proposed Rule:

We strongly support the EPA using their authority in sections 111(b) and (d) of the Clean Air Act to set these new pollution standards that would require fossil fuel power plants to reduce their GHG emissions for the first time and recommend that the standards be as strong as possible to protect human health and prevent the worst climate change impacts from occurring.

(Bold is in the original.). So what are the “climate change impacts on human health” they are talking about? There’s this:

A strong limit on power plant carbon pollution would also protect those patients who are most vulnerable, including children, older adults, those with health conditions, and people with lower incomes and communities of color who feel the health harms of climate change soonest and most intensely.

How exactly does that work? They don’t say. Hey, everybody know it. Read on and you come to this:

The proposed rules would result in up to $85 billion in net climate and health benefits, while preventing 1,300 premature deaths and over 300,000 cases of asthma attacks by 2030.

And what is the source? The link goes to EPA’s own “fact sheet” on the proposed Rule! As far as I can determine, the numbers are completely made up by government advocates, and certainly the “U.S. Healthcare Climate Council” has not checked them in any way. Since when does CO2 cause asthma? Hey, EPA says it, so it must be true.

And how about the issue of whether the emissions reduction goals are achievable on the stated timescale? These guys don’t deal with that, but that doesn’t stop them from advocating for shorter deadlines and more stringent requirements in every respect: “Increase the number of gas plants covered by the rule. . . . Move up compliance timelines so that power plants must reduce their emissions this decade. . . .”

As to the American College of Obstetricians and Gynecologists, you might wonder what expertise they have in anything related to climate change or how electricity is generated. The answer is that they have none, but that doesn’t keep them from showing their virtue here. Here’s their statement of why they are commenting:

As climate change continues to adversely affect the well-being of women, people seeking obstetric and gynecologic care, families, and communities, ACOG supports greater recognition of and investment into addressing the effects of the environment on public health. Specifically, ACOG in its position statement [c]alls on our national and international leaders to act to curb greenhouse gas emissions and limit further climate destabilization. . . . Greenhouse gas emissions accelerate climate change, which poses a serious threat to American’s health and well-being. . . .

Do they have any proof of this made-up nonsense?

In 2030 alone, nationwide the proposed standards would prevent: approximately 1,300 premature deaths; . . . more than 300,000 cases of asthma attacks. . . .

It’s the exact same bullshit projections cribbed from EPA’s own “fact sheet” and parroted back to them with no independent thought or research. And in conclusion:

Rapid emissions reductions are therefore required to limit damage to global ecosystems which provide essential services necessary for human wellbeing and societal stability.

I like the “therefore” in that sentence. No support for the proposition was provided in anything that preceded it.

And finally for today we have the comment from a large coalition of environmental and health groups from Wisconsin, which include Evergreen Action, Healthy Climate Wisconsin, Green Neighbor Challenge, the Wisconsin Chapter of the American Academy of Pediatrics, and many more. The gist:

[O]ur organizations urge the EPA to set the strongest possible safeguards on carbon pollution by early next year. While the agency’s current proposal is a good start, we ask the EPA to strengthen it in three ways: 1) require power plants to reduce their emissions more quickly, 2) apply the pollution safeguards to a wider number of gas plants, and 3) ensure communities have input on how the pollution safeguards are implemented at power plants.

And get ready for the health impacts of climate change:

Carbon pollution from the fossil-fuel industry drives climate change and leads to poor air quality and increasingly negative health outcomes, including respiratory disease, heart disease, and insect-borne infectious diseases.1 According to the National Institute of Environmental Health Sciences, poor air quality as a result of climate change can harm respiratory and cardiovascular systems. These health impacts include hypertension, coronary artery disease, heart attack, and stroke.2

And where does any of that come from? Footnote 1 goes to yet another EPA self-serving advocacy piece, “Climate and Human Health.” Footnote 2 goes to a similar piece from NIH.

Now, I don’t wish anybody a premature death, but this advocacy has completely lost its way. EPA has somehow ginned up a number of 1300 premature deaths per year that it thinks it can prevent by shutting down an electricity generation system that works and replacing it with something that has not been demonstrated to work or even been subject to a feasibility study. Last year there were 3,274,000 deaths in the U.S., so 1300 would be 0.04%, and they would appear to be counted by EPA even if the death is premature by only one day. How EPA knows that an imperceptible change in temperature could cause these deaths is an excellent question.

Meanwhile, what about the benefits of a reliable electricity supply? Is it really possible that we so completely take that for granted, like it’s just a fact of life? If we suddenly start having blackouts that last for weeks or months, how many people are then going to die prematurely? Hundreds of thousands per year, that’s how many.

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Chris Hanley
August 15, 2023 10:47 pm

… poor air quality as a result of climate change can harm respiratory and cardiovascular systems. These health impacts include hypertension, coronary artery disease, heart attack, and stroke …

Apart from the deliberate deceptive conflation of carbon dioxide carbon particulates and other contaminates this is the equivalent of overcharging in law or ‘charge stacking’ aka ‘piling on’ as is infamously going on in the US today: ‘”tacking on” additional charges that the prosecutor knows he [or she] cannot prove’ (Wiki).

Alexy Scherbakoff
August 15, 2023 10:47 pm

These groups are created/attract the worst kind of people. Having been on committees myself, I know the kind of dross that makes up said committees.

August 15, 2023 11:39 pm

Carbon pollution?

CD in Wisconsin
Reply to  strativarius
August 16, 2023 1:29 am

Exactly what I keep thinking. Are these bozos aware at all that they are demonizing the very basis for life when they refer to carbon as pollution? Are they that scientifically illiterate? Sadly, they probably are.

Whether they are referring to the carbon atom or the co2 molecule hardly matters. Let’s just shut down all of our fossil fuel power plants and then see how it affects our health.

Reply to  CD in Wisconsin
August 16, 2023 1:50 am

It’s the funniest joke of them all…. Carbon based life-form declares war on Carbon. The bond with two Oxygen atoms counts for nothing.

Peta of Newark
August 15, 2023 11:55 pm

quote:”It’s the exact same bullshit projections cribbed from EPA’s own “fact sheet” and parroted back to them with no independent thought or research.

No more than a variation on Tragedy Chanting

IOW Tribalistic, self reinforcing magical thinking as engaged in by a self-pleasuring and hyper-active mobs everywhere – usually at football stadia.
It is= The Madness of Crowds

But only A Certain (lower) Class do it:
BBC Quote:”This comes after English football’s governing body the FA announced new rules that include a section on tragedy chanting, saying anyone who commits this “vile form of abuse” could be banned from stadiums and arrested.

Reply to  Peta of Newark
August 16, 2023 1:51 am

The woke elites are cleaning up the people’s beautiful game.

Look out Millwall!

Reply to  Peta of Newark
August 16, 2023 2:06 am

So, we can arrest idiots mumbling the chants of climastrology?

August 16, 2023 12:34 am

If they think breathing in CO2 causes asthma, they will be shocked to discover what they breathe out.

Reply to  MCourtney
August 16, 2023 2:04 am

Isn’t it you breathe into a paper bag or something, to get CO2 levels back to where your body kickstarts the automatic bit again? IOW, lack of CO2 can trigger breathing difficulties?
As a kid I had the breath knocked out of me a couple of times, it’s real scary, you get afraid of death. I could never understand the kids whose parents gave them drugs for it, though…

Reply to  cilo
August 16, 2023 4:13 am

I also remember a high school biology class experiment demonstrating the importance of CO2 levels in regulating breathing.

The teacher had a fit student (from the football team) rebreathe a restricted volume of air in a closed system for as long as possible. They very quickly tore off the mouthpiece as they used up the oxygen and their brain panicked.

Then the teacher repeated the experiment with the same student but with the rebreathed air passing through a CO2 chemical scrubber. If the teacher hadn’t taken the mouthpiece off the student they would have passed out not realising they were starving of oxygen.

Lesson learnt – buildup of CO2 causes the body to respond when breathing, not the lack of oxygen (to which we would just pass out).

Unlikely such an experiment would be allowed in classrooms today – allowing a student to nearly pass out due to lack of oxygen!

Andy Pattullo
Reply to  ThinkingScientist
August 16, 2023 9:46 am

Exactly right. In the brain blood vessels have sensors for carbon dioxide which cause the vessels to dilate and deliver more blood (and oxygen) when carbon dioxide is high and then narrow the vessels and reduce blood and oxygen flow when carbon dioxide is low. This makes sense as a high carbon dioxide level means high tissue aerobic (using oxygen) metabolism and a need for more oxygen delivery to tissues. By artificially reducing carbon dioxide in the blood the sensors are “tricked” into reducing blood and oxygen flow below that necessary to keep the brain tissue functioning.

This is also the mechanism for dive syncope (fainting in deep water) when a diver hyperventilates to blow off carbon dioxide before diving so as to suppress the urge to breath when in deep water and extend the dive for a longer interval. When they rise towards the surface with an artificially reduced carbon dioxide level in their blood, the drop in pressure with ascent causes the oxygen pressures to fall in the brain because the CO2 is too low to trigger blood vessel dilation. The diver faints in the water and may drown as a result.

Don’t try this at home!!

August 16, 2023 1:59 am

The three comments listed seem to be written by a chatbot, with some leeway for the last one, that one seems quite committee-like.
The only thing here of some interest is this:
Covidiocy “narrative” was driven by oncologists and psychologists. Cancer and propaganda, go figure.
Now they want to drive Climastrology with paediatricians and ObGyns? Is this because:
a) With the severely reduced reproduction rate after covidiotvax, are they trying to find new business?
b) They are taking a leaf from the book of paedophilia, getting them “…by eight, before it’s too late”, only they go for the first eight months?
Is this pre- or post partum?

Tom Abbott
August 16, 2023 4:49 am

CO2 is a benign gas, essential for life on Earth.

Successfully demonizing CO2 will destroy the lives of countless people.

CAGW is a perfect storm of delusion. This delusion is extremely damaging to Western society. The scoundrels who created this CO2 delusion are enemies of humanity. They have, and will, cause great harm to the Western world, with their lies and distortions about CO2 and the Earth’s climate.

They can’t prove the claims they make, but that hasn’t stopped the delusion, because people incorrectly think they can prove their claims. With little pushback on the delusion, why wouldn’t people believe it?

Economic collapse, or colder temperatures will bring this delusion to a halt. In the Western world, that is.

In the rest of the world, they will be doing just fine burning coal, oil and gas.

The leaders of the West are such fools. They don’t have to be miltarily defeated. All the rest of the world has to do is just sit back and watch the West self-destruct over a CO2 delusion. It’s happening now.

Unless Trump gets elected.

August 16, 2023 7:06 am

Please act ASAP to reduce and eliminate GHG to prevent the total collapse of civilization from the growing climate crisis. There is 99% agreement that eliminating travel, air conditioning, nitrogen fertilizer, meat, and 24/7 reliable electricity in developed nations as well as keeping third world countries in energy poverty is the only way to save humanity from self destruction!

August 16, 2023 11:08 am

For every job lost by EPA rules, we should have an equal percentage of EPA employees lose their jobs so we can all share the pain.

Richard Page
August 16, 2023 5:04 pm

The EPA doesn’t care. The Biden regime doesn’t care. They are blinkered and focussed on one thing only – achieving the Paris Agreement targets at all costs. I saw a ‘TV talking head’ explaining the whole system to some empty-headed woke news anchor; the IRA is the ‘carrot’ but it isn’t intended to do the whole job, the EPA power plant regulations are the ‘stick’ and together they will achieve the Paris Agreement targets. And they genuinely believe this will happen, that the USA will acheive these suicidal targets and they neither know nor care what the repercussions to the US people will be. It’s a sickness, a mental illness or derangement that can be the only explanation for this.

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