Montana energy interests, environmentalists and others this week weighed in on the Environmental Protection Agency’s proposed rules to limit carbon emissions at existing power plants, raising scores of questions about the rules’ workability.
Filed with the EPA as public comments on Monday, the concerns ran the gamut, with some industry groups saying the rules should be withdrawn entirely and a leading environmental group saying they should be tougher.
The EPA rules would limit carbon emissions to combat global warming and climate change. The agency plans to finalize the rules next year, but give states the flexibility to draw up their own plans to comply.
For Montana, the EPA is proposing the state reduce its level of carbon emissions 21 percent by 2030.
The harshest criticism came from some electricity providers, natural-resource industries -- including coal, oil, mining and timber -- and the state Public Service Commission, which said the EPA may not even have the authority to impose the controversial rules.
“We urge EPA either to abandon the rule as beyond its legal authority or to substantially revise it, to comply with the law recognizing the technical and policy limitations,” wrote Dave Wheelihan, CEO of the Montana Electric Cooperatives Association, which represents two dozen rural electric co-ops across the state.
The Treasure State Resource Industry Association, which represents mining, oil, construction, agricultural and other business and labor interests, said the rules could lead to “forced closure” of existing coal-fired power plants in Montana and elsewhere, devastating coal mining in the state.
The group urged the EPA to “move away from its regulatory approach to eliminate coal from America’s energy portfolio” and look for ways to transition to more efficient power plants and carbon-capture technologies.
Even Gov. Steve Bullock -- who supports the rules’ goal of combating climate change -- said he has concerns about the rules, and that he’d like to keep Montana’s coal-fired plants operating “until the end of their useful lives.”
He and others said EPA shouldn’t use 2012 as the baseline year, from which to measure reductions, and instead use a several-years average, that would account for recent environmental improvement at coal-fired plants in Montana.
At the other end of the comment spectrum was one of the state’s leading environmental groups, the Montana Environmental Information Center, which said the state should be required to reduce carbon emissions by “far more than the 21 percent targeted by EPA.”
The Helena-based group said a more reasonable goal is 30 percent, and that Montana could easily reach that goal by increasing generation of wind and solar power and increasing energy-efficiency programs -- and save consumers money and create jobs.
“Montana’s currently coal-dominated electricity mix is unsustainable and outdated, and does not represent our vast clean-energy potential,” the group said.
Other specific comments and concerns included:
Consumer impacts: Both NorthWestern Energy, the state’s largest electric utility, and Montana’s rural electric co-ops said the rules could lead to higher costs, which would be passed on to their electricity customers.
Many co-ops rely heavily on coal-fired power and have a limited ability to enact energy-efficiency programs, the co-ops’ group said. NorthWestern also said it already has plenty of non-polluting power, like hydropower, but could be forced to buy more renewable power it doesn’t need, at higher prices.
MEIC, however, said renewable power in Montana, such as wind, often has shown itself to be less expensive than coal-fired power, so a shift away from coal power would save consumers money.
Deadlines: Several groups said the timelines proposed by EPA are unrealistic. The co-ops’ group called them “absurdly short,” and that states should have five rather than two years to develop a compliance plan. State environmental officials also said a deadline for increasing the efficiency of coal-fired plants should be lengthened, and that states should be able to revise their goals, if economic growth changes substantially.
Legal questions: Critics questioned whether EPA has authority to impose the sweeping rules. They say the rules don’t allow states to consider the “remaining useful life of existing (power plants),” as required by law. They also said EPA can’t enforce power-plant emission limits by requiring steps unrelated to power plants, such as energy-efficiency standards and more renewable power production.
Electric grid reliability: NorthWestern Energy, the Western Electricity Coordinating Council, which oversees the electric transmission system in the West, and the state PSC said they have concerns about how multiple state plans and changes in power sources might affect the stability of the regional “grid” or transmission system.
The PSC said the EPA should include a rule to prevent adoption of state plans that might destabilize the grid.