Thank you for the opportunity to comment on the U.S. Environmental Protection Agency’s (EPA) Clean Power Plan Proposed Rule. The City of Philadelphia (City) fully supports the Clean Power Plan’s necessary efforts to curb carbon pollution nationwide, and we commend EPA for recognizing that both reducing demand and decreasing the carbon intensity of our electricity supply are necessary and productive steps to that end.
Since the release of our comprehensive sustainability plan in 2009, the City has been working hard to improve our air quality and reduce our energy consumption and greenhouse gas emissions. Five years of tracking data on these goals has underscored to us that while local action is a critical piece of achieving large scale greenhouse gas reductions, it is insufficient without the type of national support provided by the Clean Power Plan.
We support the establishment of context-specific goals for each state and for allowing flexible options for states to meet their requirements. The City believes that EPA’s proposed use of the “four building blocks” approach will achieve greater carbon emission reductions at a lower cost than simply reducing emissions from the affected Electric Generating Units (EGUs). The City is particularly supportive of EPA allowing states to use decreased demand resulting from energy efficiency work to meet their requirements. We know that in Philadelphia more than 60% of carbon emissions from EGUs are generated to provide energy for buildings. The City’s building energy benchmarking program has helped identify the large magnitude of potential carbon emission reductions from energy efficiency improvements. We encourage EPA to include in its calculation of energy efficiency benefits not only additional zero-emission generation capacity, but also replacement of baseline fossil fuel generation.
In particular, the City endorses the proposed provisions for allowing multiple states to join together to reach their carbon reduction goals. States that are part of the same Regional Transmission Organization acting in unison can help allocate limited resources in ways that will produce greater, more cost efficient emission reductions. In order to support this type of collaboration, EPA should provide additional time for states to submit multi-state plans in consideration of their varied legislative and rule making schedules.
The City of Philadelphia is proud to support EPA’s Clean Power Plan.
Sincerely,Michael A. Nutter Mayor