State of Florida submits comments on federal rule regarding Greenhouse Gas Standards and Guidelines for Fossil Fuel-Fired Power Plants

BY JENNIFER CABRERA

TALLAHASSEE, Fla. – Yesterday, Florida Department of Environmental Protection (FDEP) Secretary Shawn Hamilton submitted comments on the U.S. Environmental Protection Agency’s proposed rule regarding Greenhouse Gas Standards and Guidelines for Fossil Fuel-Fired Power Plants. 

The United States Environmental Protection Agency (EPA) proposed regulations on May 23 repealing the Affordable Clean Energy Rule and establishing performance standards and emission guidelines for Greenhouse Gas Emissions for Fossil Fuel-Fired Electric Generating Units.

After reviewing the proposed rules, FDEP has formally requested that the EPA terminate rulemaking and decline to adopt the proposed rules. FDEP submitted comments stating that the EPA relies on a “hydrogen economy” that does not currently exist to expedite the “transition” of the nation’s power grid through unfounded technologies; Hamilton’s letter concluded that the EPA is placing “the reliability, affordability, and capacity of the nation’s energy supply at risk.”

The FDEP’s letter, which can be found here, states, “It is unclear if the EPA is truly seeking constructive feedback or if it is attempting to expedite rule adoption to support the ‘net-zero world’ that the World Economic Forum so desires.”

The letter from FDEP focusea on Florida’s superior air quality; the lack of evidence that the sequestration and co-firing strategies mandated by the proposed rules would even be workable or meet the capacity needs for a state like Florida; the proposed rules’ inconsistency with existing federal law; and the harms the rule presents to Floridians, especially in times of widespread power outages resulting from natural disasters.

The above chart shows that Florida’s air quality continues to improve (emissions continue to fall) while economic activity increases.

Rules rely on unproven technologies

The letter argues that the EPA’s determination that carbon capture and sequestration have been adequately demonstrated is based on demonstration projects that have failed to reliably capture carbon at levels comparable to those in the proposed rule and that the EPA fails to adequately consider grid reliability.

In addition to reliance on unproven technologies, the letter argues that the EPA removes Florida’s ability to rely on flexibility to dispatch generation facilities in times of high demand, like in the aftermath of a major hurricane or when record high temperatures increase capacity needs. The letter states, “The concept that emergency response personnel would not tap into all available resources to restore power following mass outages to support emissions thresholds places arbitrary targets above public safety and welfare.”

The letter concludes, “It is clear the EPA has placed an emphasis on transitioning to a ‘net-zero world’
above the electric needs of Americans. Florida’s superior air quality is a result of ingenuity and smart governance. The proposed rules put states like Florida at greater risk, by attempting to force unproven transitional energy practices ahead of generating the energy capacity necessary to meet the demand of our residents, visitors, and businesses.”