These documents provide the Club's analysis of the EPA Carbon rule,  These are intended to be internal documents, so please do not forward to outside entities, even if they are 'friendly'.  Please take the time to study these carefully, and share questions with the Chapter Climate Action Team.  This is the technical 'homework we need to do in order to speak intelligently, so buckle down!

Bottom line; the rule does a fair job of reducing carbon emissions.  The flexibility written into the rule allows states like WV to have lower emissions requirements than the national average.  EPA's rule therefore assures that the standard is technically achievable in EVERY state, and is legally defensible in court.  You can be sure that if industry succeeds in overturning this rule in court that it will be a long time before we get another initiative like this one.  So this is one we HAVE to win.

Two points I take from this.

First, while the 'flexibility' in the rule means that states like WV will have emissions requirements less stringent than the national average, it also means that we will receive fewer health benefits than if we had to met a uniform national standard,, Upwind states including KY, OH, and IN also have targets lower than the national average, so WV will continue to receive a higher than average pollution impact.

I am reminded of a map put out by the Clean Air Network ten years ago that color coded states by the number of deaths from power plant pollution.  Clean states were in blue or green, more polluted states were yellow, then orange or red.  A few pollution hotspots were in purple.  WV was the only state entirely within that 'purple zone of death'!  Under the 'flexibility' in EPAs plan, WV will remain an air pollution sacrifice zone.

Congressman Mckinley on Monday introduced HR 4813 to block both of EPA's power plant rules (this one for existing power plants as well as the earlier one setting carbon emission standards for new plants), as well as prohibiting EPA from any 'substantially similar' rule for five years. Co-sponsored by Rahall, Capito, and 72 others, the bill would relegate WV to continued deaths from power plant pollution.  (Perhaps that should be a theme of a press response, media event or something?)

The second point is that states that plan carefully for implementing the rule should be able to avoid significant economic impacts.  With a heavy investment in efficiency and renewables, West Virginians may actually see more jobs and lower electric bills from implementing a well-designed plan.  But a state strategy of blind opposition to the rule, as currently being proposed by Tomblin, Morrisey, et al, is the strategy MOST likely to cost jobs and raise electric rates.

Would someone (or each of us) be willing to write a short letter to the editor highlighting one or two key messages from the analysis, or the points above?  We need to start getting LTEs in demonstrating support, especially here in WV, for EPAs Carbon rules.

Jim Kotcon