Audubon New York Comments on EPA GHA Rule for New Power Plants

On May 8, 2014, Executive Director Erin Crotty, of Audubon New York submitted the following formal comments to The Honorable Gina McCarthy, Administrator for the Environmental Protection Agency:

Dear Administrator McCarthy:

On behalf of Audubon New York, the state program of the National Audubon Society representing 27 local chapters and nearly 50,000 members, we thank you for the opportunity to provide the following comments in support of the Environmental Protection Agency’s (EPA) new Standards of Performance for Greenhouse Gas Emissions From New Stationary Sources: Electric Utility Generating Units (Docket ID: EPA-HQ-OAR-2013-0495). We applaud your leadership on developing these strong and aggressive new standards in addressing and reducing greenhouse gas pollution from new energy production projects and helping to combat climate change. 

As you know, climate change is one of the leading threats to birds and other wildlife in New York and across the nation.  Climate change is likely to result in immediate impacts on birds and other wildlife that live in specialized ecosystems, such as high elevations and coastal species, and disrupting migration patterns and food availability. Specifically from data collected over the past 40 years in New York, Audubon has found that more birds are shifting their winter ranges further north in the State, clearly indicating that change is underway.

To combat this urgent threat, the federal government must set an example for the world and require all sources of greenhouse gas emissions to dramatically reduce their greenhouse gas emissions.  EPA’s proposed rule to  limit greenhouse gas emissions from new energy sources is taking a strong step forward to lower emissions from the energy generation sector which accounts for nearly forty percent of greenhouse gas pollution in the nation.  While we strongly support this progressive proposal, it will only be successful at driving down emissions if we also require similar reduction goals for existing power plants, and we look forward to working with the EPA on such a proposal in the near future. 

Also it is important to recognize that New York State continues to be a national leader in addressing global warming and reducing greenhouse gas emissions. According to the U.S. Energy Information Administration, the State reduced emissions from the power sector 35% between 2005-2011.  Much of this reduction has been achieved through the creation of the Regional Greenhouse Gas Initiative (RGGI), strong Renewable Energy and Energy Efficiency Portfolio Standards, launch of the NY Sun-Solar program, and creation of the new Green Bank.  

The State has also enacted a strong power plant siting law that goes above and beyond what the EPA is requiring in this current proposal, requiring new facilities regardless of fuel source that generate 25 megawatts or greater to limit carbon emissions to 925 lbs of CO₂/MWH. While the EPA proposal is a step forward and we support the separate standards for different fossil fuel sourced facilities.  We urge that you consider future emission limits to match New York’s strong requirements.  This will ensure consistency with the progress New York has made and achieve further limits in greenhouse gas emissions entering the atmosphere. 

 
Thank you again for consideration of these comments in support of the EPA’s new Standards of Performance for Greenhouse Gas Emissions From New Stationary Sources: Electric Utility Generating Units.