The Clean Power Plan is an extraordinary and unprecedented government overreach

In this hyper-partisan environment, it is good to know that a majority of Senators can still agree on an issue. When such a rare moment happens, the rest of us should pay attention, as it is probably something very important.

On September 11, 53 Senators (43 Republicans and 10 Democrats) signed a letter to Gina McCarthy, Administrator of the Environmental Protection Agency (EPA), begging for a 60-day extension of the comment period for the “Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating Units”—also known as the Clean Power Plan (CPP). The original 120-day comment period—which is already longer than the traditional 60-day comment period—is coming to a close within the next 30 days (October 16).

Regarding the EPA’s new plan, the letter calls the coordination needed between multiple state agencies, public utility commissions, regional transmission organizations, and transmission and reliability experts: “Unprecedented, extraordinary, and extremely time consuming.” The Senators ask for more time so that states and stakeholders can “fully analyze and assess the sweeping impacts that the proposal will have on our nation’s energy system.” It also points out: “The EPA proposal provides no mechanism for adjusting the state emission rate targets once they are adopted”—which makes it imperative that the states can fully “digest” the rule, review the 600 supporting documents, and collect the data and justification for the states’ responses.

It is not just the majority of Senators who have concerns about the EPA’s proposed rule, a diverse and growing coalition, including the Exotic Wildlife Association, the Foundry Association of Michigan, California Cotton Growers Association, Texas Aggregates and Concrete Association, The Fertilizer Institute, Georgia Railroad Association, Nebraska Farm Bureau Federation, electric utilities and co-ops, and city and state Chambers of Commerce from coast-to-coast, has sprung up in opposition to the plan. Yet most people are unaware of the potential impacts or of the pending deadline for public comment.

I have written on the CPP twice in the past few months—originally when it was first announced on June 2 and then after I gave testimony in Atlanta at one of the EPA’s four scheduled “listening sessions.” Upon release, we didn’t really know much—after all, it is, as the Senators’ letter explains, complex and sweeping. But as more and more information is coming out, we see that the impact to the economy and U.S. energy security will be devastating.

Despite my efforts to spread the word—with my second column on the topic being one of my most popular ever, I find that the CPP isn’t even on the radar of the politically engaged (let alone the average person). Because this is an issue of utmost importance, I am, once again, bringing it to the attention of my readers with the hope that you will share it with everyone you know. At this point, we don’t know if the EPA will extend the comment period, so please take time now to get your comments in. The Hill reports: “Adding 60 days to the comment period could make it harder for the EPA to finalize the rule by June 2015, as President Obama has ordered.”

I’ve written this week’s column with the specific intent of giving you verbiage that you can simply cut and paste into the comment form.

The CPP will radically alter the way electricity is generated, transmitted, distributed and used in America—all with dramatic cost impacts to the consumer. It is based on the discredited theory that climate change is a crisis caused by the use of fossil fuels emitting carbon dioxide into the atmosphere. It aims to reduce overall carbon dioxide emissions by 30 percent below 2005 levels by 2030. The combination of the CPP and previous regulation will shut down more than 40 percent of coal-fueled generation—representing 10 percent of all electricity-generation capacity—within the next 6 years.

What will this forced, premature elimination of America’s electric capacity do?

The proposed EPA plan will seriously threaten America’s electric reliability

Unless the EPA backs down on its harsh regulations and coal-fueled power plants get a reprieve, blackouts are almost guaranteed—especially in light of the projected cold winter. About the 2014 “polar vortex” that crippled the U.S., Alaska Republican Senator Lisa Murkowski, at an April Senate hearing on grid reliability, stated: “Eighty-nine percent of the coal electricity capacity that is due to go offline was utilized as that backup to meet the demand this winter.” Murkowski’s comments were referencing coal-fueled power plants that are already due to be shut down based on regulations from five years ago, before the proposed CPP additionally reduces supply. Affirming Murkowski’s comments, Nicholas Akins, president and CEO of Ohio-based American Electric Power Company Inc., sees the 2014 near crisis as a warning sign. At that same hearing he said: “The weather events experienced this winter provided an early warning about serious issues with electric supply and reliability. This country did not just dodge a bullet—we dodged a cannonball.” And, Federal Energy Regulatory Commissioner Philip Moeller said: “the country is undergoing an unprecedented energy shift in a very short time frame.” And added: “grid operators in the Midwest are struggling to gauge whether they will have sufficient capacity to handle peak weather during the next five years.” While these comments are about the 2014 severe cold, Texas experienced a similar scare in 2011, when a protracted heat wave resulted in razor-thin reserve electric capacity margins. A Reuters report titled: “Heat waves pushes Texas power grid into red zone,” stated: “Texas has the most wind power in the country, but the wind does not blow during the summer.” Just a few months earlier, Texas ice storms forced rolling blackouts for hours because electric supplies dropped below demand.” All of these reports are before the projected closure of an additional 75 megawatts of coal-fueled electricity generation due to the new regulations. If McCarthy was serious when, prior to the release of the proposed regulations, she stated: “Nothing we do can threaten reliability,” she’d withdraw this plan, as it will do just that.

The proposed EPA plan will chase away more American industry

While the CPP appears to be about forcing the power sector into reducing carbon-dioxide emissions, there are spillover impacts of higher electricity rates on overall economic activity—especially energy-intensive industries such as steel, manufacturing, and chemicals. America’s abundance of affordable, reliable energy provides businesses with a critical operating advantage in today’s intensely competitive global economy. The EPA’s proposal will reduce America’s advantage, as it’s acknowledged that the proposed regulations will raise electricity rates in the contiguous U.S. by 5.9% to 6.5% in 2020. Europe, and especially Germany, is threatened by an industry exodus due to its higher energy costs that have been created by its move to increase green energy. Germany’s pharmaceutical and chemical giant Bayer is already making significant investment in its Chinese manufacturing operations, with expansion also taking place in Brazil and India. If industry continues to leave the U.S., the CPP will have the opposite effect. Emissions will increase as companies move to countries with lower labor costs, cheaper energy, and lax environmental policies. An additional unintended consequence will be more jobs lost in manufacturing.

The proposed EPA plan will kill hundreds of thousands of jobs

In late July, the International Brotherhood of Electrical Workers (IBEW) International President Edwin D. Hill said: “If these rules are implemented as written, dozens of coal plants will shut down and with no plans to replace them, tens of thousands of jobs will be lost and global carbon emissions will rise anyway.” Investor’s Business Daily reports: “The IBEW has now joined the United Mine Workers of America, the Boilermakers and several other unions opposed to the new anti-carbon rules.” The United Mine Workers of America has estimated that the rule will result in 187,000 direct and indirect job losses in the utility, rail, and coal industries in 2020 and cumulative wage and benefit losses from these sectors of $208 billion between 2015 and 2035. The EPA rules hitting industry in rapid succession create uncertainty—and, as we’ve seen with Obamacare—uncertainty thwarts investment and hiring. The same industries that will be taking the regulatory hit from the CPP, are expecting additional impacts from the follow-on rules that are yet to be promulgated. No wonder the economy is sluggish and the jobs picture is bleak.

The proposed EPA plan will cause harsh economic consequences while having virtually no impact on the reported goal of stopping global climate change

From increased energy costs to job losses, the CPP will damage the economy. A statement from the International Brotherhood of Electrical Workers on the EPA proposal, points out: “estimates regarding the damage to jobs and the economy created by poorly planned climate regulations have consistently been shown to be true in comparison to the overly optimistic predictions made by the EPA.” Perhaps these economic consequences would be worth it, if they actually did anything to really reduce carbon-dioxide emissions—assuming what humans breathe out and plants breathe in is actually the cause of global warming. But even the EPA acknowledges that the CPP is less about reductions and more about being a global leader to “prompt and leverage international decisions and action.” In Hillary Clinton’s September 4 speech at Senator Harry Reid’s National Clean Energy Summit, she stated that the U.S. needs to lead other countries in green energy and that we need to show the world we are committed. Yet, the U.S., which did not ratify the Kyoto Protocol, is the first country to actually reduce carbon dioxide emissions and meet the Kyoto requirements. We are already a leader, but the other countries aren’t following—instead they are abandoning the sinking green ship and Germany, which claims to still be committed to the green ideology, is actually increasing its number of coal-fueled power plants and CO2 emissions. Carbon dioxide emissions from non-Organisation for Economic Co-operation and Development countries—such as China and India—are projected to grow by nine billion tons per year. The Partnership for a Better Energy Future reports: “for every ton of CO2 reduced in 2030 as a result of EPA’s rule, the rest of the world will have increased emissions by more than 16 tons.” Our reduction in 2030 would offset the equivalent of just 13.5 days of carbon-dioxide emissions from China. The CPP will become the definition of “all pain and no gain.” Or, as economist Thomas Sowell calls it: “replacing what worked with what sounded good.”

The EPA’s October 16 deadline will be upon us before you know it. Take a few minutes now to send them your comments here, here or directly to the EPA. Pick any of the above suggestions, customize them as you please, and send them on to the EPA. For America to grow, we need energy that is effective, efficient, and economical, rather than that which is threatened by the EPA’s flood of excessive and burdensome regulations.