The Environmental Protection Agency has proposed repealing the Clean Power Plan, the nation's first limits on the nearly two billion tons of climate-changing carbon pollution coming from power plants each year, and replacing it with a Dirty Power Plan that will actually increase dangerous air pollution from coal-fired power plants. Here is the testimony I'll give Monday at the only public hearing EPA has scheduled, in Chicago, Illinois.

On behalf of NRDC’s three million members and supporters I want to register our strong opposition to the proposed repeal and replacement of the Clean Power Plan.

The Trump EPA’s so-called Affordable Clean Energy Standard is neither “clean” nor “affordable.” It is, in fact, a “Dirty Power Plan.” It means more climate-changing carbon pollution and more emissions that produce deadly fine particles and ozone smog. EPA’s own analysis shows this Dirty Power Plan could cause up to 1,630 more deaths in 2030—and a similar toll in years before and after – compared to the Clean Power Plan.

This summer has, again, given powerful, compelling witness to the unfolding climate catastrophe. Here in America and around the world we are seeing unprecedented wildfires, droughts, heatwaves, torrential rains, flooding, rising seas, and more powerful hurricanes.

This is what we see now. What’s coming will be far worse—a hell on earth—if we do not act. As the Washington Post reported last Friday, this Administration is shrugging off—even embracing—the “no-action” forecast that carbon dioxide levels will reach nearly 790 parts per million by 2100—nearly double today’s levels, and more than triple concentrations at the dawn of the industrial age. At those levels scientists project a 7 degree Fahrenheit rise in global average temperatures—more than double the temperature limit scientists say we must stay beneath to avoid devastating climate change.

As awful as life will become in America under the 7 degree scenario that this administration takes as inevitable, it will be even worse elsewhere. Vast stretches of the planet will become unlivable, especially for those in poverty. Millions of people will have two choices—move or die—making today’s migration issues look like child’s play.

The Clean Air Act places the duty on EPA to stem the pollution that is driving this climate catastrophe. Power plants, along with cars and trucks, are America’s largest sources of this pollution.

We are fortunate that market trends are moving the power sector away from dirty coal plants and toward cleaner generation and energy services faster than EPA anticipated in 2015. But that is no basis for complacency, because we need to move even faster towards a clean electric power grid.

The reason for having a Clean Air Act is to curb dangerous pollution that market forces alone do not capture. The Clean Power Plan was an initial effort to meet EPA’s duty under that law. But it is more than obvious that we can and must do much more to protect our children and grandchildren.

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A responsible, law-abiding EPA, led by appointees who cared about our children and grandchildren, would now be strengthening the Clean Power Plan.

If EPA were to update the Clean Power Plan applying the same methodology to the latest available data, the updated standards could achieve a 60 percent reduction below 2005 levels by 2030 (44 percent reduction below current levels). That’s nearly twice the original Clean Power Plan’s 32 percent reduction from 2005 levels.

That would be a major step toward the clean energy system we need to avoid climate disaster. And it would save thousands more lives and prevent hundreds of thousands more illnesses each year.

But Acting EPA Administrator Andrew Wheeler, a former coal lobbyist, and air program chief Bill Wehrum, a former power industry lawyer, have only one objective: to weaken the Clean Power Plan at the behest of coal barons and backward-looking remnants of the power industry.

Their Dirty Power Plan would violate the Clean Air Act in multiple ways:

The Dirty Power Plan misreads the Clean Air Act and mischaracterizes the Clean Power Plan.

The proposal wrongly claims the Clean Power Plan violated the law by not sticking to measures that can be “applied to or at” each source—supposedly requiring a source’s owner/operator to "implement measures on behalf of the source at another location."

This is doubly false. The Clean Power Plan’s limits do apply to each individual source, and it does not require any operator to control the actions of another plant.

The Clean Power Plan uses the same system of emission reduction that EPA has used for decades to curb power plant pollution, allowing each plant operator to meet its specific emission limit with a mix technological controls, fuel changes, or emission credits.

It is the new proposal that breaks with EPA’s historical approach to power plant pollution, not the Clean Power Plan.

The Dirty Power Plan has nothing more than minor efficiency tune-ups for coal plants, and exempts gas plants entirely.

Heat-rate improvements reduce emission rates only slightly—EPA assessed a maximum of 4.5 percent, but more likely just 1 to 2 percent.

Heat-rate improvements can even backfire. A coal plant that operates more efficiently may run more hours, increasing total CO2 emissions overall.

EPA is ignoring far more effective measures like fuel-switching and carbon capture and storage.

The Dirty Power Plan weakens the vital New Source Review program .

The proposal would illegally drop the sensible requirement that a coal plant must install up-to-date pollution controls if heat-rate improvements cause its total annual emissions of soot- or smog-forming pollutants to increase.

Weakening New Source Review would let coal plants operate more, allowing them to spew mo​re pollution, not less.

The Dirty Power Plan abandons EPA’s legal duty to say how much existing sources must clean up.

Instead, EPA would let each state decide how much each coal plant must clean up, if at all.

Coal barons and power companies will lobby their states to be pollution havens—re-igniting a “race to the bottom” we haven't seen in decades.

The Dirty Power Plan cooks the books on the costs and benefits of curbing dangerous pollution.

The Regulatory Impact Analysis shows all: Under every illustrative scenario EPA analyzed, the Dirty Power Plan would result in more CO2, SO2, and NOx than the Clean Power Plan.

Under some scenarios, compliance with the Dirty Power Plan actually costs more and achieves less than the original Clean Power Plan.

Flying in the face of sound science and economics, EPA's analysis radically under-counts the deaths, illnesses, and climate damages from power plants' soot, smog, and carbon pollution.

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The Dirty Power Plan puts irresponsible corporate polluters ahead of our health and environment. It is scientifically indefensible, morally inexcusable, and decidedly illegal. We will not let President Trump and EPA’s Wheeler and Wehrum turn a blind eye to science, justice, and law. We will not let them condemn our children to a hell on earth.