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Joint Public Comments on the Social Cost of Carbon to DOE and HUD

On May 16, we submitted joint comments on the social cost of carbon to two Department of Energy energy efficiency rules and to another energy efficiency rule proposed jointly by the Department of Housing and Urban Development and the Department of Agriculture. They are substantially similar to those we submitted for EPA’s proposed New Source Performance Standards rule on May 9th. The comments to DOE are available here, and the comments to HUD are available here.

Both sets of comments make recommendations that, if taken, would maximize the impact of the rules:

EPA should consider the cost savings associated with a flexible, multi-year compliance period when determining the “degree of emission limitation achievable” under the “best system of emission reduction” for coal-fired generating units.

Given that EPA’s forthcoming rule for greenhouse gas emissions from existing power plants is likely to encourage emissions trading between existing coal- and gas-fired units, EPA should group its performance standards for new coal- and gas-fired units within a single regulatory subpart. Treating all types of generating unit as a single source category will put future trading on a stronger legal footing.

EPA should expand its proposed performance standards to encompass all greenhouse gases emitted by generating units, not just carbon dioxide.

EPA should also make clear that carbon capture and storage can be “adequately demonstrated” without referring to projects funded by the Energy Policy Act of 2005.

Finally, EPA should explain more fully why it exempts oil-fired and peak-demand units from the proposed standards.