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Jack Harrison's remarks on repeal of carbon pollution emission guidelines for existing stationary sources




As prepared for delivery

Testimony of

Jack Harrison

on behalf of the

American Petroleum Institute

Public Meeting on the

Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources:

Electric Utility Generating Units

EPA-HQ-OAR-2017-0355

November 28, 2017

Good morning, my name is Jack Harrison, and I am the former director of the American Petroleum Institute’s West Virginia office. I am currently a consultant for API and I am speaking today on behalf of the organization. API is the only national trade association representing all facets of the oil and natural gas industry, which supports 10.3 million U.S. jobs and 7.6 percent of the U.S. economy. API’s more than 625 members span the industry.

For perspective on our comments, please note that recent record U.S. production and refining are happening alongside greater environmental progress: carbon dioxide emissions from power generation are down to near 30-year lows, thanks in large part to greater use of natural gas. Also, cleaner burning transportation fuels and industry investments have dramatically reduced emissions of criteria pollutants. 

The natural gas and oil industry has succeeded despite the unprecedented level of federal regulatory actions that targeted our industry in the past. In contrast, and consistent with President Trump’s stated objectives of American energy independence and economic growth, EPA and other federal agencies should embrace smart, cost-effective regulations while continuing to promote public health, safety and the environment that both industry and citizens support.

API is preparing detailed written comments addressing the proposed repeal of the Clean Power Plan. Today I would like to highlight three key points: on climate change, this rulemaking, and the role of natural gas.

First, the natural gas and oil industry considers climate change to be a very important issue and is engaging constructively to address this complex global challenge. United States climate policy must recognize the vital role of petroleum products in modern society, and the many benefits that natural gas and oil provide our nation and the world. The natural gas and oil industry is taking a variety of actions and investing in technologies across the value chain that reduce GHG emissions and will continue to be an integral part of the effort to address climate change.

Second, API has supported the Trump administration’s review of the Clean Power Plan as promulgated on October 23, 2015 and supports the administration’s current proposal to repeal the CPP.  Our 135 page December 1, 2014 coalition comments concluded that the CPP rule would be:

“….arbitrary, capricious, and unlawful for the reasons set forth above. The EPA should immediately withdraw the proposed rule. Should the EPA wish to consider regulating GHGs emissions from existing fossil fuel-fired EGUs under Section 111(d), it should first issue an advanced notice of proposed rulemaking in order to foster an open, unbiased dialogue with all affected and interested parties.”

 Of note, even without the Clean Power Plan’s implementation, our nation has reduced greenhouse gas emissions from power generation by 25 percent since 2005 thanks largely to the increased use of clean, reliable, and affordable natural gas.  Even as we have become the world’s top producer and refiner of natural gas and oil, carbon emissions are near 25-year lows throughout our nation’s economy.

Third, if and when EPA replaces the Clean Power Plan, the Agency must leverage the benefits of clean, reliable, and affordable natural gas. These have been the three big benefits of natural gas. And together they have changed the energy and environmental landscape in this country and beyond.

The American natural gas renaissance fundamentally altered the world's energy equation and natural gas now serves as a primary fuel for the power we use in our homes and businesses. Power generators have turned to natural gas to ensure they can produce the electricity they need. In fact, natural gas produces about one-third of America’s power and produced more electricity than any other fuel source in 2016.  And the U.S. Energy Information Administration reported that almost two-thirds of the reductions in CO2 emission from –2005 - 2016 came from the fuel mix shifting toward natural gas.   It is in the states’ interest to have reliable fuel for power generation. Clean and abundant natural gas is a key driver of reliability in power generation.  Any replacement of the CPP should contemplate states relying on natural gas for compliance and all activities that reduce emissions – including increasing use of natural gas generation – should be counted and included by states as contributors to compliance. 

In conclusion, we look forward to further working with Administrator Pruitt, EPA leadership and staff on this and other rulemakings. Regulatory actions should be rooted in sound science and data, with a consideration of the costs and benefits, while protecting public health and the environment.