Contact: David Arkush, Public Citizen, 202-454-5132 | Linda Sherry, Consumer Action, 202-544-3088

WASHINGTON, D.C. – Although the U.S. Environmental Protection Agency’s (EPA) plan to curb climate change-inducing carbon emissions from existing power plants will provide significant benefits to consumers, it should be strengthened and made more consumer-friendly, Public Citizen said in comments (PDF) filed today with the agency. Consumer Action and Ohio Partners for Affordable Energy joined the filing, which can be read here (PDF).

The EPA in June proposed the plan, called the Clean Power Plan, which is designed to curb greenhouse gas emissions by 30 percent by 2030. States will have latitude in deciding how best to comply. The deadline for comments is today.

The agency overestimated the relative costs and underestimated the carbon-reducing potential of the most consumer-friendly policies: energy efficiency measures and the use of renewable energy, Public Citizen said. The EPA did the reverse for natural gas and nuclear generation. The agency’s proposal:

• Falls short of reducing carbon emissions at the pace required to prevent global warming more than 2 degrees Celsius;
• Treats energy efficiency measures and renewable energy as adding to the overall pool of electricity generation, rather than replacing fossil fuels. This means that the plan’s targets for emission cuts are far more modest than they would be had the agency assumed that efficiency and renewables are used in the most sensible way – to retire fossil-fuels;
• Overstates the costs and understates the potential emission reductions from energy efficiency, which is the lowest-cost, most effective way to reduce emissions;
• Overstates the cost and understates the potential for renewable energy sources, which soon will provide the cheapest and most reliable sources of electricity for consumers, and in some places already does;
• Calls for an increase in the use of natural gas, even though we must phase out natural gas as soon as possible due to greenhouse gas emissions; and
• Relies a small amount on nuclear power, which carries exorbitant costs that consumers typically must subsidize through their utility bills. The agency also made extraordinary errors that led it to grossly underestimate the costs of nuclear generation.

“The EPA’s rulemaking to curb carbon pollution presents an extraordinary opportunity to benefit consumers by fighting climate change, promoting cost-saving efficiency measures and spurring a faster transition to cheaper and more reliable renewable energy sources,” said David Arkush, managing director of Public Citizen’s climate program. “We strongly support the agency’s effort to reduce greenhouse gas emissions. We also urge the agency to strengthen the proposed plan, make it more consumer-friendly and give states better guidance on how to comply with the plan in the most cost-effective manner.”

“It’s vital that consumers have an opportunity to learn about regulators’ plans and to have a chance to comment,” said Linda Sherry, director of national priorities for Consumer Action. “We are strongly aligned with Public Citizen in the need to involve consumers and their advocates in plans being made at the state and regional level.”

Recommendations to the EPA include:

• Strengthen the proposal to put the U.S. on pace to do its part in preventing 2 degrees Celsius of global warming;
• Correct errors in its cost analysis and growth projections for each component of the plan, which should lead to higher reliance on energy efficiency and renewable energy sources, significantly less use of natural gas and little to no nuclear generation. Correcting the proposal’s errors also would give states strong guidance on how they can comply with the rule with the least cost; and
• Require states to solicit input from consumers while they develop their plans and ensure that consumers help oversee and implement the plans. In addition to providing public notice and the opportunity for the public to comment, states should hold regional public hearings, convene consumer advisory panels and conduct other outreach to consumer advocates.

“Consumers will benefit immensely from sound state policies and bear the brunt of poor state implementation choices,” Arkush said. “As a matter of fairness, they deserve a strong role in the formulation and execution of state plans. But consumer participation is valuable for another reason: There is substantial overlap between the policies that are best for reducing emissions and those that are best for consumers.”

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Public Citizen is a national consumer advocacy organization with over 350,000 members and supporters.

Through multilingual financial education materials, community outreach, and issue-focused advocacy, Consumer Action empowers underrepresented consumers nationwide to assert their rights in the marketplace and financially prosper.

Ohio Partners for Affordable Energy (OPAE) is a 501(c)(3) nonprofit membership organization created to advocate for affordable energy policies for moderate and low-income Ohioans. Sixty-four OPAE member agencies provide essential energy services, including bill payment assistance, weatherization and energy efficiency, and housing services to over 440,000 households statewide annually.