WASHINGTON (August 10, 2023) — The American Chemistry Council (ACC) issued the following statement after submitting joint comments to the U.S. Environmental Protection Agency (EPA) on its proposed Greenhouse Gas Standards and Guidelines for Fossil Fuel-Fired Power Plants. Other signatories were the Aluminum Association, American Iron and Steel Institute, American Forest & Paper Association, American Wood Council, and Industrial Energy Consumers of America.
“This proposal is a prime example of regulatory overreach that could harm energy reliability and affordability – making it more difficult for U.S. manufacturers to compete and innovate. Our sectors create products used around the world and employ millions of Americans in high-paying jobs. Maintaining a reliable and affordable supply of electric power and other energy is critical to our operations.
“While we support effective and proven efforts to reduce emissions in the electric power sector, this cannot come at the expense of accessible, affordable electricity. Manufacturers could experience these impacts under a variety of scenarios, such as purchased electricity, mandated carbon capture and storage (CCS) for the use of fossil fuels, or mandated fuel-switching, such as from natural gas to low-GHG hydrogen.
“The proposed rule fails to recognize the importance of manufacturing industries such as ours in meeting climate goals. We create many of the ‘inputs’ for applications that help society save energy and reduce emissions. In the chemistry industry, this includes semiconductors, electric vehicles (EVs), solar and wind power, advanced battery storage, high-performance building solutions, lightweight vehicle parts, and more.
“EPA’s proposal is unprecedented in scope and exceeds its authority and expertise. It would directly and indirectly reshape the power sector, impose tens of billions of dollars in costs, and require the rapid development and regulation of wholly new national infrastructure and industries for CCS and low-GHG hydrogen.
“EPA should consider potential unintended effects on important efforts to reduce global GHG emissions. U.S. manufacturers are among the most energy-efficient in the world, and our economy has a carbon intensity, as measured in CO2 emissions per dollar of GDP, that is one-third lower than the global average. The proposal could result in a net increase in global emissions as activity and growth shift to countries that produce and use energy less efficiently. Meanwhile, higher energy costs could dampen or delay investments in innovative technologies to further improve energy efficiency and lower emissions.
“The U.S. business of chemistry continually invests in energy efficiency and other measures that help reduce emissions. Our companies are among the leaders and participants in exploring the development and use of innovative technologies such as CCU and clean hydrogen. We look forward to engaging with EPA on this proposal.”