Organisation Name
National Association of Manufacturers (NAM)
InfluenceMap Query
GHG Emission Standards
Data Source
Legislative Consultations
 
 

Score for this Data / Query Cell

-2.0

InfluenceMap has researched and collated the following pieces of evidence associated with the data source and query indicated above. Extraordinary information is indicated by a coloured flag in the upper right corner. Evidence items in order of data inputted with exceptional items first.

 

Opposing GHG emissions standards

InfluenceMap Comment:

Advocating for policy makers to oppose specific GHG emissions standards. (Evidence from joint statement submitted during the EPA's consultation on 'Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units, December 2014, p 4)

Extract from Source:

EPA is proposing this rulemaking as a key component of the President’s Climate Action Plan, which identifies a wide range of actions that the administration is implementing to address the challenges of climate change. In proposing to achieve greenhouse gas (“GHG”) emission reductions from existing electricity generating units (“EGUs”) in the proposed ESPS, however, EPA for the first time in the more than 40 year history of the Clean Air Act (“CAA”) is bootstrapping unprecedented, newfound legal powers onto its existing legal authority without the necessary legislative amendment. This self-enacted authorization would elevate the Agency to the most influential and pervasive federal regulator of not just the environment, but the generation, distribution, and utilization of electricity in the nation. Such a role reaches far beyond the bounds of the CAA, and the very mission of EPA as an agency established to reduce air pollution and not as a regulator of the nation’s electricity grid.

Created: 03/06/2015 Last edited: 28/11/2017

 

Opposing GHG emissions standards

InfluenceMap Comment:

Opposing the Clean Power Plan (Testimony of Ross Eisenberg before the Senate Committee on Environment and Public Works, November 2017)

Extract from Source:

We did oppose the Clean Power Plan and we are asking the EPA to replace it with a better regulation, we are comfortable with regulation.

Created: 28/11/2017 Last edited: 28/11/2017

 

Opposing GHG emissions standards

InfluenceMap Comment:

Directly advocating to policymakers to support a repeal of the Clean Power Plan (Comments on Evaluation of Regulations, May 2017)

Extract from Source:

Clean Power Plan. The final Clean Power Plan would fundamentally shift how electricity is generated and consumed in this country, effectively picking winners and losers in terms of both technologies and fuels. The rule also represents an attempt to vastly expand the EPA’s traditional authority to regulate specific source categories by setting reduction requirements that reach into the entire electricity supply-and-demand chain. The requirements will be substantial, potentially costing billions of dollars per year to comply. Some studies estimate that compliance with the rule would cost well over $300 billion and cause double-digit electricity price increases for ratepayers in most states. Manufacturers are concerned about these potential costs and reliability challenges as electric power fleets are overhauled in compliance with the regulations. Manufacturers are also keenly aware that the EPA is using this regulation as a model for future direct regulations on other manufacturing sectors—meaning manufacturers could potentially be hit twice by GHG regulations. EO 13777 Justification: This regulation could eliminate jobs or inhibit job creation; its costs could exceed its benefits; and it derives from a Presidential directive that has been rescinded and substantially modified. NAM Recommendation: The President and has already taken strong action to reexamine this regulation, which manufacturers welcomed. The NAM encourages the EPA to replace the Clean Power Plan with a Section 111(d) regulation that better reflects the statute’s requirements. In addition, the NAM requests that the EPA delineate what constitutes “significant” endangerment for GHGs, which is a higher threshold than the “cause and contribute” endangerment determination the Agency made for mobile sources under Title II of the Clean Air Act.

Created: 28/11/2017 Last edited: 28/11/2017

 

Opposing GHG emissions standards

InfluenceMap Comment:

Opposing New Source Performance standards (Comments on Evaluation of Regulations, May 2017)

Extract from Source:

NSPS for GHG Emissions from New, Modified, and Reconstructed Stationary Sources: Electric Utility Generating Units. This rule, a precursor to the Clean Power Plan, set performance standards for GHG emissions under Section 111(b). In its final rule, the EPA inappropriately concluded that carbon capture and sequestration (CCS) was “adequately demonstrated” for utility-scale applications and its utilization is the basis for the mandated standard for all new coal-fired power plants. As a matter of fact, CCS had not been adequately demonstrated at the utility scale—making a standard that requires it for all new coal plants an effective ban on those plants. Manufacturers need access to all energy sources to keep energy affordable and reliable. Even the manufacturers of CCS, who would presumably benefit from a rule like this, filed comments with EPA that CCS was not adequately demonstrated and that mandating it in the rule would chill demand for development of this technology. Finally, a regulation requiring technologies that are not commercially available would set a damaging precedent for future regulation of manufacturers’ operations. EO 13777 Justification: This regulation could eliminate jobs or inhibit job creation; its costs could exceed its benefits; and it derives from a Presidential directive that has been rescinded and substantially modified. NAM Recommendation: Like the Clean Power Plan, the President and has already taken strong action to reexamine this regulation, which manufacturers greatly appreciate. The NAM recommends that EPA issue a new 111(b) rule that bases its standard on a more realistic definition of the Best System of Emissions Reduction (BSER) for GHGs that has been adequately demonstrated. One potential option could be the definition proposed by the NAM-supported Whitfield-Manchin bill in the 113th Congress, which stated that a technology can be BSER once it has been achieved over a one-year period by at least six units located at different commercial power plants in the United States.

Created: 28/11/2017 Last edited: 28/11/2017