Joint Comments on Treatment of Biomass (PDF)
October 31, 2018 Joint Comments of Clean Air Task Force, Natural Resources Defense Council, Center for Biological Diversity, Clean Air Council, Clean Wisconsin, Conservation Law Foundation, Dogwood Alliance, Partnership for Policy Integrity, and Sierra Club on the Treatment of Biomass-Based Power Generation in EPA’s 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 (83 Fed. Reg. 44746 (August 31, 2018) Docket No. EPA-HQ-OAR-2017-0355 Submitted via regulations.gov Environmental and public health organizations Clean Air Task Force, Natural Resources Defense Council, Center for Biological Diversity, Clean Air Council, Clean Wisconsin, Conservation Law Foundation, Dogwood Alliance, Partnership for Policy Integrity, and Sierra Club hereby submit the following comments on the “best system of emission reduction” and other issues EPA’s proposed rule “Emission Guidelines for Greenhouse Gas Emissions from EXisting Electric Utility Generating Units; Revisions to Emission Guideline Implementing Regulations; Revisions to New Source Review Program,” 83 Fed. Reg. 44,746 (Aug. 31, 2018). [I] Overview Climate change continues to intensify and threaten public health and welfare. A recent report from the Intergovernmental Panel on Climate Change (IPCC) concludes that if greenhouse gas (GHG) emissions continue at the current rate, the atmosphere will warm by as much as 1.5°C (or 2.7°F) by 2040.1 “Climate-related risks to health, livelihoods, food security, water supply, human security, and economic growth are projected to increase with global warming of 1.5°C and increase further with 2°C.”2 The power sector was responsible for 29 percent of the climate-warming GHGs emitted in the United States in 2017,3 making it imperative that the U.S.
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