Comments on the Clean Power Plan Proposed Rule, [GHG/Carbon Standards for Existing Power Plants, EPA Sec. 111(d)]
The Kentucky Environmental Foundation is an organization dedicated to securing solutions to environmental problems by safeguarding human health, promoting environmental justice and encouraging sustainability. In this capacity, we advocate for strong regulations to control the health impacts of carbon emissions in the state of Kentucky.
We appreciate the EPA’s attention to the urgency of addressing climate change, and urge the EPA to further strengthen the regulations for carbon pollution in the Existing Source Performance Standards (Clean Air Act section 111d) and the EPA’s Clean Power Plan.
Key areas for strengthening the Clean Power Plan:
Health Impacts: We would like to see the EPA demonstrate how each of their proposed methods for carbon reduction in the Clean Power Plan protects human health. Kentucky is a state that has elevated asthma rates and cardiovascular disease, both of which are linked to carbon pollution. The Clean Power Plan does not address environmental impacts to human health and externalities of the whole fuel-cycle as the basis for decision-making.
The American Public Health Association and the World Health Association have identified climate change as one of the biggest threats to public health in this era. Kentuckians face a wide range of risks associated with climate change including more extreme weather, extreme heat, drought, and shifts in vectors such as ticks and mosquitoes that carry life threatening diseases including Lyme disease and West Nile virus. And our state has already suffered significant damage from carbon pollution for many decades.
Pollution from fossil fuels is dangerous, particularly for children, because it can trigger asthma attacks and can permanently reduce lung function. Kentucky has some of the highest rates of asthma in the nation. According to the CDC, in 2008, adult lifetime asthma prevalence was 14.7% and adult current asthma prevalence was 9.7% compared with U.S. rates of 13.3% and 8.5%, respectively.
In addition, air pollution can affect cardiovascular diseases, where Kentuckians have significantly higher rates. According to Kentucky’s Cabinet for Health and Family Services, Cardiovascular disease accounted for 30% (12,547) of all deaths in Kentucky in 2009 and ranked 8th out of 50 states for cardiovascular death rates.
EPA’s proposed carbon pollution standards could protect our citizens more by reducing the smog that triggers asthma attacks and other health threats. But efforts by our state regulators and state enforcement efforts still leave Kentuckians near the bottom of every indicator compared to what is actually possible, or being achieved in other states.
State regulators are either unable or unwilling to strongly enforce local standards that protect human health from coal’s impacts. And the impact has been significant. A report by Kentucky Environmental Foundation called a “Health Impact Assessment of Coal and Clean Energy Options in Kentucky” outlined sources of data showing the relationships between the extraction, processing, transportation, burning, and disposal of coal combustion waste and health, while also outlining the health benefits of cleaner energy sources.
Environmental Justice: The Clean Power Plan does not do enough to address concentrations of localized pollution. We would like to see stronger incentives to protect low-income communities, who can be disproportionately affected by carbon pollution.
Stronger Reduction Goals: Even though the Clean Power Plan focuses on reducing carbon pollution from power plants 30% by 2030, the EPA estimated that we could make these reductions faster. We know we can go much further than 30% by 2030 because states are already going beyond EPA's proposal by retiring dirty power plants and scaling up renewables and energy efficiency.
For example in Kentucky, our Assistant Secretary for Climate Policy, John Lyons, recently stated that the average carbon emissions of Kentucky's fleet of coal-fired power plants should meet the new standard by 2020. That's because 11 coal boilers are already scheduled to shut down because of other EPA air quality regulations. So in other words, Kentucky can meet the Clean Power Plan standards simply by continuing their present course, with little incentive for additional innovation.
While we understand the desire for flexibility across states, that flexibility should not override strong incentives for states to “step up their game.” While the new EPA standards call for a 30 percent reduction in the nation’s carbon emissions by 2030, Kentucky’s specific goal is a cut of only 18.3 percent. Our state agencies will tell you this gives them the flexibility they need, but this degree of “flexibility” is a disincentive for real action.
We understand that states like Kentucky have a major challenge, given that 93 percent of the state’s electricity is generated from coal. However Kentucky’s progress to date allows it to remain at the very bottom of every indicator: from efficiency, to clean power, to protection of human health. The EPA’s Clean Power Plan continues the subsidization of obsolete coal-fired and nuclear power, making it more difficult to move our state forward onto cleaner resources.
Stronger Incentives for Energy Efficiency and Renewables: The Clean Power Plan incentivizes conversion of coal towards natural gas and nuclear, over conversion to wind, solar and most importantly for our state, energy efficiency. The plan focuses on end-of-stack emissions instead of the Best Available Technology approach, and only lists energy efficiency as an “option” not a mandate.
Efficiency is a particular issue for Kentucky. We are far behind many other states when it comes to diversifying our energy portfolio. Our state has no Renewable Energy Portfolio Standard or Energy Efficiency Resource Standards. And Kentucky ranks third among states in per customer electricity use while having some of the lowest per-capita income rates in the nation. In other words, our per capita energy consumption is among the highest in the nation. Energy efficiency is one of our best avenues for real progress.
What the EPA has proposed with the Clean Power Plan can move us forward. But not fast enough. Louisville, our largest city, is already the number one urban heat island in the nation. And our dependency on coal has made us economically vulnerable. Coal mining in Kentucky has collapsed, with a loss of 40% of the state’s coal mining jobs since 2011. Coal-related jobs are now less than 1% of statewide employment.
Clean energy and efficiency could create significant employment opportunities for the state. A recent study found that the Clean Energy Opportunity Act, a proposed state legislation requiring investments in renewable energy and efficiency, would result in over 28,000 jobs in ten years.
Because of our state’s strong historical ties to the coal industry, political will continues to under-value cleaner alternatives. Therefore we must rely on the EPA for those clean energy incentives.
 CDC: “Asthma in Kentucky” (2011) http://www.cdc.gov/asthma/stateprofiles/Asthma_in_KY.pdf
 Kentucky Cabinet for Health and Family Services “Cardiovascular Fact Sheet, 2010” http://chfs.ky.gov/NR/rdonlyres/738A1FCB-4F89-4C25-A6E1-548D3E36BE29/0/KentuckyCardiovascularFactSheet2010.pdf
 Kentucky Environmental Foundation: Health Impact Assessment of Coal and Clean Energy Options in Kentucky. January 2012. http://www.kyenvironmentalfoundation.org/uploads/1/8/5/9/18595042/kef_health_impact_assessment_energy_report_web.pdf
 “New EPA Rule Won’t Affect Power Plants,WBKO,July 3, 2014, http://www.wbko.com/home/headlines/Official-New-EPA-Rule-Wont-Affect-Power-Plants-265749521.html
 Governor’s Office of Energy Policy. 2008. “Kentucky Energy Watch Special Edition: Electricity in Kentucky.” Retrieved May 27, 2009 (http://www.energy.ky.gov/NR/rdonlyres/6BD66312-4950-4312-AAF7-263E70A58A4A/0/SpecialEditionElectric12008.pdf
 “Kentucky Coal Jobs Continue Their Record-Breaking Decline” Lexington Herald-Leader, Nov. 18, 2013. http://www.kentucky.com/2013/11/18/2939551/kentucky-coal-jobs-continue-their.html
 Rick Hornby, Dr. David White, Dr. Tommy Vitolo, Tyler Comings, and Kenji Takahashi: Potential Impacts of a Renewable and Energy Efficiency Portfolio Standard in Kentucky. Prepared for the Mountain Association for Community Economic Development & the Kentucky Sustainable Energy Alliance, January 12, 2012. http://www.maced.org/files/Potential_Impacts_of_REPS_in_KY.pdf