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Agency: Environmental Protection Agency (EPA)

Document Type: Rulemaking
Title: Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units
Document ID: EPA-HQ-OAR-2017-0355-0002

Comment:
New Mexico Business Coalition (NMBC) supports the Environmental Protection Agency (EPA) proposed repeal of carbon emissions guidelines for electric utility generating units, commonly referred to as the Clean Power Plan (CPP). This regulation is unlawful, unnecessarily costly, and a bad deal for America. It would drive up electricity costs for businesses, consumers and families, impose tens of billions in annual compliance costs, and reduce our nation's global competitiveness—without any significant reduction in global greenhouse gas emissions.

EPA estimates that the proposed repeal could provide up to $33 billion in avoided compliance costs in 2030. If the CPP is not repealed, American consumers would be left footing this bill, in the form of lost wages and jobs, and higher prices for energy and other goods and services. For example, in May 2016, the Energy Information Administration (EIA) within the Department of Energy released detailed modeling that projected the CPP would drive up electricity rates and bills, reduce GDP by an average of $58 billion per year, and result in 376,000 fewer jobs in 2030. Coming from the federal government's own top energy experts, these projections speak volumes. Industry analyses reached similar conclusions, with NERA Economic Consulting estimating that the rule could cause average annual electricity rates to increase between 11 and 14 percent nationwide, with 28 states potentially facing peak year electricity price increases of at least 20 percent

In our state alone, the CPP would have required New Mexico to reduce its electricity sector carbon emissions rate 36.3 percent by 2030. An independent analysis by NERA Economic Consulting projected that the rule would increase our state's electricity prices by an average of 10 percent and up to 14 percent in peak years.

Because of the above problems with the CPP (and more), nearly 160 entities filed suit, including 27 states, 71 utilities, 8 labor unions, and 25 different business associations. Additionally, 166 state and local business associations in 41 states filed an amicus brief in support of the legal challenge to the rule. NMBC was pleased to join in signing this legal brief. The Supreme Court recognized these legal concerns, and in February 2016 granted an historic and unprecedented stay blocking implementation of the rule until its legality could be decided upon by the courts.

Now, with EPA's proposed repeal, the Administration has an opportunity to preserve access to the abundant supplies of affordable and reliable energy that lower costs for families and businesses while spurring economic growth and job creation. With both abundance and diversity of supply, energy provides the U.S. economy a major competitive advantage in the increasingly competitive global economy. Swiftly finalizing repeal of the CPP would protect that advantage.

For these reasons, we strongly support the proposed repeal of the rule, and encourage EPA to instead pursue a more reasonable path forward that protects American jobs and the economy while fostering continued environmental progress.

Thank you for taking comments on this important issue and your consideration to the views of NMBC and the thousands of New Mexicans we represent.

Carla J. Sonntag, President and Founder
New Mexico Business Coalition