The Concerned Household Electricity Consumers Council (CHECC) announces that on February 26, 2018 it filed a Comment in response to EPA’s Advanced Notice of Proposed Rule Making (ANPRM) Clean Power Plan (CPP) Replacement.
This Comment provided EPA and the Trump Administration with Legal, Climate Science and Energy Economic analysis findings, each robustly supporting the conclusion that EPA should Repeal and Not Replace the Clean Power Plan.
SUMMARY OF RECOMMENDATIONS
Based on the Legal Analysis: The CPP should not be replaced with anything at all until a lawful, scientifically robust, highly influential scientific assessment (HISA)-compliant positive endangerment finding has been made. The 2009 EF analysis process was fundamentally flawed requiring that it must be rescinded and reconsidered.
Based on the Climate Science Analysis: The scientific basis for the 2009 Endangerment Analysis has been invalidated – in fact, by two separate and distinct analyses. Hence, a GHG endangerment reconsideration is highly unlikely to yield a new endangerment finding. And, thus CPP replacement would have no legal basis and then should not be replaced.
Based on the Energy Economic Analysis: The current Federal, State and private sector policies that are now increasing the fraction of electricity generation from Intermittent Renewables must be stopped/reversed in order to avoid/mitigate very severe micro and macroeconomic impacts and National Security ramifications involving skyrocketing electricity prices as well as dramatically reduced power grid reliability and resilience. The climate science findings suggest that taking such action will have no impact on the climate.