MIT Energy Initiative director opposes US EPA proposal to weaken emission guidelines

The following comment was submitted by Robert Armstrong, Director of the MIT Energy Initiative, in opposition to the proposed “Emission Guidelines for Greenhouse Gas Emissions from Existing Electric Utility Generating Units; Revisions to Emission Guideline Implementing Regulations; Revisions to New Source Review Program,” issued by the Environmental Protection Agency, published August 31, 2018 at 83 FR 44746


Docket No. EPA-HQ-OAR-2017-0355

October 30, 2018


On behalf of the MIT Energy Initiative (MITEI), I write to register our opposition to the proposed “Emission Guidelines for Greenhouse Gas Emissions From Existing Electric Utility Generating Units; Revisions to Emission Guideline Implementing Regulations; Revisions to New Source Review Program,” (“the Proposed Rule”) and recommend that the Administrator of the Environmental Protection Agency withdraw it from further consideration.

The Proposed Rule is lengthy and complex, and it is not our intention to comment on all of its provisions and impacts. However, we are concerned that, according to the Regulatory Impact Analysis prepared by EPA (EPA-452/R-18-006, August 2018)(“RIA”)[1], one effect of the Proposed Rule would be to increase the total emissions of carbon dioxide by power plants for the years 2025 through 2035. (RIA at ES-8)

Carbon dioxide is a gaseous pollutant released by the burning of fossil fuels. The accumulation of carbon dioxide in the Earth’s atmosphere is the dominant cause of the observed warming of the Earth over the past century and continues to exacerbate the ongoing changes to the Earth’s climate. The Special Report on Global Warming issued by the United Nations’ International Panel on Climate Change on October 8, 2018 (“the IPCC Special Report”) is only the most recent and among the most concerning statements from the world’s scientific community on the current reality of climate change and the risks of unprecedented future consequences for the Earth’s ecosystems, its people, and other species if we continue on our current course.

While there remain aspects of the climate system that require additional study and uncertainties about how future climate scenarios will unfold, there is no longer any reasonable debate about the existence of the climate change problem. The overwhelming consensus of the scientific community is that human activities are its dominant cause, and that its consequences threaten to do irreparable harm to natural systems upon which human society depends.

A range of projected CO2 emissions increases of approximately 1 to 3 percent may appear to be of small significance, but such increases do matter.  Ameliorating climate change is not an all or nothing exercise. Humans, other species, and the Earth’s systems are already feeling the effects of climate change in a world where average global temperatures have increased approximately one degree centigrade since the beginning of the Industrial Revolution. The IPCC Special Report states that limiting global warming to 1.5 degrees centigrade will very likely require deep reductions in emissions in all sectors, and that even that level of increase will be exceeded unless global CO2 emissions begin to decline significantly well before 2030.

Furthermore, there is strong evidence that some effects of the accumulation of carbon dioxide and other greenhouse gases on the Earth’s climate system are not linear. Climate changes of the distant past indicate that there are thresholds beyond which disruptions of climate that would be catastrophic for society could occur. We must take all reasonable opportunities available to us to reduce the risks associated with humanity’s contributions to the buildup of these substances in our atmosphere.

The technology to accomplish the emission reductions required under the current regulations is available and affordable. For the United States to retreat from its previous commitment to reduce emissions from power plants would be harmful in itself and would send the wrong signal to other nations. Furthermore, the energy system globally is shifting towards lower carbon technologies; and we will weaken our position as a technological and commercial leader in the energy sector by allowing this to happen.

In submitting this comment, it is not our intention to take a position on particular policies or mechanisms to achieve emissions reductions. But the United States should not be needlessly weakening its policies to reduce CO2 emissions.  We recommend that the Proposed Rule be withdrawn.

Furthermore, we urge the EPA to ground its policies in the scientific community’s clear consensus on the reality of anthropogenic climate change and the unacceptable risks of continuing our current levels of carbon emissions.  Other recent proposals that would increase CO2 emissions, such as the weakening of clean car standards, also need to be reconsidered.  In that case, the agencies seemed to accept significant climate change as inevitable and to argue that efforts to make discrete reductions in CO2 emissions were pointless.  Such an attitude is not consistent with the science of climate change, and is literally a recipe for disaster.

Thank you for the opportunity to comment.


Robert Armstrong
MIT Energy Initiative