Clean Power Plan Public Hearing Testimony

Bonner Cohen, Ph.D.

Arlington, Virginia

July 30, 2014


In proposing to reduce emissions of carbon dioxide (CO2) from new power plants to 30 percent below 2005 levels by 2030, EPA has created a scheme that is so complex that its implementation will undermine the nation’s energy security and impose intolerable costs on those least able to bear the burden, without having any measurable effect on the climate. I will confine my remarks to three observations.

EPA’s state-based approach is blatantly discriminatory and threatens to disrupt the supply of affordable electricity to tens of millions of consumers.

By treating states and regions differently, EPA plays favorites. It places lesser burdens on states with energy policies it likes, such as California’s and the Northeast’s RGGI (Regional Greenhouse Gas Initiative) cap-and-trade systems, while ignoring far-reaching efforts by other states to lower emissions and to produce electricity more efficiently. Mississippi is a case in point. Mississippi Power has invested $600 million to upgrade coal-fired Plant Daniel with modern pollution-control technology. The state’s Public Service Commission has recently approved one of the most ambitious energy efficiency programs in the Southeast. After a recent expansion of its production capacity, Entergy’s Mississippi-based Grand Gulf Nuclear Station is the largest single-unit power plant in the United States. Yet, under EPA’s Clean Power Plan, Mississippi will receive no credit from the agency for any of these steps.

For those states not basking in the glow of EPA favoritism, the marginal costs of compliance across the board will drive up the price of electricity. Coal-dependent states, primarily in the Midwest, will have to cope with their utilities’ frantic efforts to switch from coal to natural gas and will run the risk of brownouts and even blackouts if the transition does not go smoothly. The situation will be even worse if these states are coerced into a growing dependency on notoriously unreliable renewable energy, such as wind and solar.

EPA’s proposed rule will real effect on global man-made CO2 emissions.

This point has been made by many observers before, but it bears repeating. Efforts by the United States to curb its greenhouse-gas emissions will not be matched by the emerging major emitters of CO2, such as China and India. Both countries have made it abundantly clear that rapid industrialization is their top priority and that they will continue to expand their use of fossil fuels and whatever other sources of energy can propel their economies. Penalizing American consumers by denying them access to affordable energy in the name of combating climate change, formerly known as global warming, is an exercise in futility that will do great harm to an already sluggish economy and will provide absolutely no environmental benefits.

On the contrary, increasing U.S. reliance on politically fashionable but unreliable, intermittent, inefficient, and land-intensive renewable energy (notably, wind and solar) will put enormous strains on the nation’s already decrepit power grid and pose a threat to wildlife through whirling wind turbines that kill hundreds of thousands of birds and bats every year.

EPA cannot make a scientific case for its regulatory action.

Nowhere in EPA’s justification for its Clean Power Plan can the agency site a single bit of evidence, whether from the UN’s Intergovernmental Panel on Climate Change (IPCC) of any other source, showing a cause-and-effect relationship between manmade emissions of greenhouse gases, particularly CO2, and a warming of the planet. CO2 is a lagging indicator; it rises as a result of higher temperatures. It does not cause temperatures to rise. While CO2 levels have risen since the end of the Little Ice Age in the middle of the 19th century, the current level, 393 parts per million (ppm), is far lower than in previous times in the earth’s geological history. The lack of any warming over the past 17 years despite rising CO2 levels, even grudgingly admitted by the IPCC, directly contradicts the theory of human-induced global warming through manmade greenhouse-gas emissions.

If its Clean Power Plan rule is allowed to go into effect, EPA will subject the country to a wrenching transformation of its energy sector that cannot be justified by the available scientific evidence or the damage it will inflict on ordinary citizens and the environment.


  • Bonner Cohen, Ph. D.

    Bonner R. Cohen, Ph. D., is a senior policy analyst with CFACT, where he focuses on natural resources, energy, property rights, and geopolitical developments. Articles by Dr. Cohen have appeared in The Wall Street Journal, Forbes, Investor’s Busines Daily, The New York Post, The Washington Examiner, The Washington Times, The Hill, The Epoch Times, The Philadelphia Inquirer, The Atlanta Journal-Constitution, The Miami Herald, and dozens of other newspapers around the country. He has been interviewed on Fox News, Fox Business Network, CNN, NBC News, NPR, BBC, BBC Worldwide Television, N24 (German-language news network), and scores of radio stations in the U.S. and Canada. He has testified before the U.S. Senate Energy and Natural Resources Committee, the U.S. Senate Environment and Public Works Committee, the U.S. House Judiciary Committee, and the U.S. House Natural Resources Committee. Dr. Cohen has addressed conferences in the United States, United Kingdom, Germany, and Bangladesh. He has a B.A. from the University of Georgia and a Ph. D. – summa cum laude – from the University of Munich.