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

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.

• 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.
• 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.
• 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.
• 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.

APA

Duffy, J. (2019). 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. Clean Air Task Force. https://cdn.catf.us/wp-content/uploads/2019/02/21093744/NSPS-Proposal-Testimony.pdf

Chicago

Duffy, Jay. 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. Clean Air Task Force, 2019. https://cdn.catf.us/wp-content/uploads/2019/02/21093744/NSPS-Proposal-Testimony.pdf.

Wikipedia

{{cite press release |last1=Duffy |first1=Jay |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=Clean Air Task Force |date=14 February 2019 |url=https://cdn.catf.us/wp-content/uploads/2019/02/21093744/NSPS-Proposal-Testimony.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{duffy2019comments, author = {Duffy, Jay}, 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 = {Clean Air Task Force}, year = {2019}, month = feb, url = {https://cdn.catf.us/wp-content/uploads/2019/02/21093744/NSPS-Proposal-Testimony.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }