Tuesday, March 27, 2018

Implement the Clean Power Plan

While the President and EPA Administrator Scott Pruitt have made no secret of their hostility to the Paris Accords, the Clean Power Plan, or for that matter just about any other initiative to address the climate change crisis, the EPA is required by law to hold public hearings before its scraps or alters the rules, promulgated under the Obama administration, that created the Clean Power Plan. The following is a text of a letter to Director Pruitt in support of the CPP from 32 Montana legislators, submitted as written testimony at the EPA hearing in Gillette, Wyoming today. 

March 27, 2018

E. Scott Pruitt, Administrator
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20004

Dear Administrator Pruitt:

As elected members of the Montana State Legislature, we write in response to your request for comment on the proposed repeal and replacement of the Clean Power Plan (CPP). In our opinion, any weakening of the CPP would be a grave mistake and would seriously threaten the health and wellbeing of Americans and indeed our neighbors throughout the world.

Since the CPP was first proposed by the prior administration, evidence of the extent of climate change, its relationship to carbon emissions, and the severity of its effects has grown rapidly. In the state of Montana, climate change is adversely affecting our agricultural and recreational economies and eroding the quality of the natural environment and ecosystems, which are the heritage of not just Montanans, but all Americans. The disappearance of glaciers in Glacier National Park and the increasing frequency of catastrophic wildfires on national forests are two outstanding examples.

Globally, climate change is now clearly implicated in rising sea levels, species loss, increasing food insecurity, compromised health, and other deleterious effects that threaten the viability of the world economy and the stability of the political order. American military analysts have identified these effects of climate change as a serious national security threat.

Since it became apparent that the current administration did not intend to move forward with the CPP, several states have taken it upon themselves to impose firm, quantifiable and verifiable reductions on their carbon emissions. We applaud the effort of those states, but we are concerned that leaving control of carbon emissions to individual states acting in isolation is unlikely to result in adequate emission reductions. The reason in clear: while the benefits of emissions reductions demonstrably outweigh the costs, those benefits accrue nationally and internationally, while the costs are born locally. It is not reasonable to expect any one state to incur the costs of providing substantial benefits outside its borders unless it is acting in concert with other states and benefiting in turn from those states’ efforts. Achieving such concerted action clearly requires direction in the form of a national policy such as the CPP.

There are several economic aspects of the CPP that we urge you to consider. One is that while efforts (such as the CPP) to control emissions are often perceived to be costly and accordingly, economically inefficient, the fact is that there is now extensive research that demonstrates that the economic magnitude of the damages avoided when emissions are reduced far outweighs the costs of achieving the reductions in the first place. It is clear that in Montana, for example, failing to arrest climate change will seriously damage both the agricultural and outdoor recreation industries which are significant contributors to the state’s economy.

When the CPP was first proposed, several national opposition studies predicted that its implementation would impose unacceptably high costs on the national economy. Since that time, however, emissions from the electric power sector have dropped at a rate comparable to that contemplated in the CPP, strictly as a result of the cost advantage conferred by switching from coal to natural gas for thermal generation and replacing fossil fuel generation with renewables. This suggests that implementing the CPP would be far less costly than critics predicted, and greater reductions could be achieved at acceptable cost.

As legislators in a coal producing state, we are aware of the potential impacts of the CPP on communities that depend on coal for their livelihoods. We believe that the country and energy companies have an obligation to assist such communities in transitioning to a lower carbon and less coal dependent energy system.  Indeed, this is an issue which we already face in Montana and which we have confronted and will continue to confront in the legislative arena. But we also believe that we have an equally compelling obligation to address the very serious threat of climate change, which we cannot do without Federal direction such as that provided for in the Clean Power Plan.


Senator Dick Barrett, Missoula
Senator Carlie Boland, Great Falls
Senator Jill Cohenour, East Helena
Senator Tom Facey, Missoula
Senator Jen Gross, Billings
Senator Margaret MacDonald, Billings
Senator Sue Malek, Missoula
Senator Nate McConnell, Missoula
Senator Mike Phillips, Bozeman
Senator JP Pomnichowski, Bozeman
Senator Diane Sands, Missoula
Senator Frank Smith, Poplar
Senator Lea Whitford, Cut Bank
Rep. Kim Abbott, Helena
Rep. Bryce Bennett , Missoula
Rep. Laurie Bishop, Livingston
Rep. Ellie Hill Smith, Missoula
Rep. Willis Curdy, Missoula
Rep. Amanda Curtis, Butte
Rep. Mary Ann Dunwell, Helena
Rep. Jenny Eck, Helena
Rep. Janet Ellis, Helena
Rep. Dave Fern, Whitefish
Rep. Moffie Funk, Helena
Rep. Jim Hamilton, Bozeman
Rep. Denise Hayman, Bozeman
Rep. Shane Morigeau, Missoula
Rep. Andrea Olsen, Missoula
Rep. Rae Peppers, Lame Deer
Rep. Jean Price, Great Falls
Rep. Marilyn Ryan, Missoula
Rep. Tom Woods, Bozeman