{"query_echo":{"q":"","filters":{"analysis_type":["regulatory testimony"]},"warnings":[{"code":"facet_value_not_in_vocabulary","message":"Value 'regulatory testimony' for facet 'analysis_type' is not in the controlled vocabulary."}]},"total":{"value":1,"relation":"eq"},"page":1,"page_size":20,"self":"https://climateinsightsdirectory.org/api/v1/search?analysis_type=regulatory+testimony","stability":"beta","ai_marking":{"digital_source_type":{"uri":"http://cv.iptc.org/newscodes/digitalsourcetype/trainedAlgorithmicMedia","name":"Created using Generative AI"},"notice":"Summary and key insights are generated using artificial intelligence."},"results":[{"id":"catf-001104","url":"https://climateinsightsdirectory.org/document/catf-001104","title":"Comments of Jay Duffy; Clean Air Task Force, Attorney at Public Hearing on Proposed NSPS for Greenhouse Gas Emissions from New, Modified, and Reconstructed EGUs","publisher":{"name":"Clean Air Task Force","organization":"clean-air-task-force"},"document_type":"statement","language":"en","date_published":"2019-02-14","source_url":"https://cdn.catf.us/wp-content/uploads/2019/02/21093744/NSPS-Proposal-Testimony.pdf","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"Jay Duffy of the Clean Air Task Force testifies that the EPA's proposed increase of the CO2 emission rate for new coal plants to 1,900-2,200 lbs. CO2/MWh-g is unsupported by technology and science. He argues that carbon capture and sequestration (CCS) is more cost-effective and available than in 2015, citing projects like Petra Nova and Boundary Dam and the expanded 45Q tax credit. Duffy claims the proposed weaker standards would allow a single 600 MW plant to emit 1.1 million additional tons of CO2 and 500 additional tons of SO2 annually, offsetting gains from other EPA proposals.","ai_generated":true,"unit":"catf-001104#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"The EPA's proposal to set the emission rate for new coal plants at 1,900-2,200 lbs. CO2/MWh-g is criticized as being based on efficiency technology from 30 years ago, whereas international advanced ultrasupercritical capacity currently operates below 1,500 lbs. CO2/MWh-g.","ai_generated":true,"unit":"catf-001104#insight-1","date_modified":"2026-10-23"},{"text":"Carbon capture and sequestration (CCS) is presented as a cost-reasonable and demonstrated technology that is more available and cost-effective than it was in 2015. Evidence includes the Petra Nova retrofit, which captured over 2 million tons of CO2, and the Boundary Dam retrofit, which captured over 2.5 million tons of CO2.","ai_generated":true,"unit":"catf-001104#insight-2","date_modified":"2026-10-23"},{"text":"The expansion of the 45Q tax credit in 2018, which increased rates to $20/ton for enhanced oil recovery and $50/ton for saline sequestration, could enable the capture and storage of nearly 49 million tonnes of CO2 annually from US coal- and gas-fired power plants by 2030.","ai_generated":true,"unit":"catf-001104#insight-3","date_modified":"2026-10-23"},{"text":"The proposed standards are estimated to harm public health; specifically, a new 600 MW plant operating at the low-end proposed rate of 1,900 lbs. CO2/MWh-g would emit an additional 1.1 million tons of CO2 and 500 tons of SO2 per year.","ai_generated":true,"unit":"catf-001104#insight-4","date_modified":"2026-10-23"}],"climate_tags":["greenhouse gas emissions","coal-fired power station","carbon capture and storage"],"geography_discussed":["Washington, D.C."],"frame_perspective":[],"analysis_type":["policy analysis","regulatory testimony"]}]}