DECLARATION OF RIC O’CONNELL, MICHAEL O’BOYLE, AND BRENDAN PIERPONT IN SUPPORT OF ENVIRONMENTAL AND PUBLIC HEALTH RESPONDENT-INTERVENORS

The document argues that the U.S. coal fleet is already in a sustained economic decline, making the EPA's emissions rules a catalyst for prudent utility planning rather than a source of economic or reliability risk. It asserts that the 2032 compliance timeline is sufficient for utilities to procure replacement resources, citing hundreds of gigawatts of 'shovel-ready' projects in interconnection queues. The authors maintain that 'baseload' coal is no longer necessary for grid stability, as portfolios of wind, solar, battery storage, and low-utilization gas can meet peak loads and growing demand without compromising reliability.

• Coal use in the U.S. electricity sector is in a long-term decline, dropping from 45 percent of generation in 2010 to 16 percent in 2023. The fleet is aging and increasingly uneconomic, with the average plant built 43 years ago and expected to be over 50 years old by 2032.
• The economic viability of coal is severely pressured by the falling costs of renewables and storage. Research indicates that 99 percent of operating coal plants are more expensive to run than the cost of new wind and solar generation.
• The EPA's compliance timelines are sufficient for utilities to transition. There are hundreds of gigawatts of resources in interconnection queues ready for development, with an average project reaching commercial operation 25 months after interconnection agreement execution.
• The transition to clean energy is unlikely to cause significant rate increases or harm utilities. Planning costs are minimal and part of normal business, and for-profit utilities may actually see higher shareholder returns due to increased capital expenditures under current regulatory frameworks.
• Grid reliability does not depend on 'baseload' coal plants. Modern resource planning can maintain stability using a diversified portfolio of wind, solar, battery storage, and low-utilization gas combustion turbines.
• Several major U.S. utilities have already developed plans to end coal use without CCS or gas co-firing by 2032. For example, Florida Power and Light plans to retire over 700 MW of coal by 2028 and meet demand with 19 GW of solar and over 2 GW of storage by 2032.

APA

O’Connell, R., O’Boyle, M., & Pierpont, B. (2024). DECLARATION OF RIC O’CONNELL, MICHAEL O’BOYLE, AND BRENDAN PIERPONT IN SUPPORT OF ENVIRONMENTAL AND PUBLIC HEALTH RESPONDENT-INTERVENORS. Energy Innovation. https://energyinnovation.org/wp-content/uploads/EI-and-GridLab-Declaration-June-2024.pdf

Chicago

O’Connell, Ric, Michael O’Boyle, and Brendan Pierpont. DECLARATION OF RIC O’CONNELL, MICHAEL O’BOYLE, AND BRENDAN PIERPONT IN SUPPORT OF ENVIRONMENTAL AND PUBLIC HEALTH RESPONDENT-INTERVENORS. Energy Innovation, 2024. https://energyinnovation.org/wp-content/uploads/EI-and-GridLab-Declaration-June-2024.pdf.

Wikipedia

{{cite press release |last1=O’Connell |first1=Ric |last2=O’Boyle |first2=Michael |last3=Pierpont |first3=Brendan |title=DECLARATION OF RIC O’CONNELL, MICHAEL O’BOYLE, AND BRENDAN PIERPONT IN SUPPORT OF ENVIRONMENTAL AND PUBLIC HEALTH RESPONDENT-INTERVENORS |publisher=Energy Innovation |date=11 June 2024 |url=https://energyinnovation.org/wp-content/uploads/EI-and-GridLab-Declaration-June-2024.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{oconnell2024declaration, author = {O’Connell, Ric and O’Boyle, Michael and Pierpont, Brendan}, title = {{DECLARATION OF RIC O’CONNELL, MICHAEL O’BOYLE, AND BRENDAN PIERPONT IN SUPPORT OF ENVIRONMENTAL AND PUBLIC HEALTH RESPONDENT-INTERVENORS}}, publisher = {Energy Innovation}, year = {2024}, month = jun, url = {https://energyinnovation.org/wp-content/uploads/EI-and-GridLab-Declaration-June-2024.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }