U.S. EPA’s Carbon Rule

Presentation at National Tribal Forum by

National Wildlife Federation

How tribes can engage on Clean Air Act rulemaking to limit

carbon pollution from power plants

May 2014

• Climate change threatens Native Peoples’ access to traditional foods

• In the Southwest, particularly vulnerable to high temperatures, drought, and severe storms.

• Changes to the Colorado plateau have made the Navajo nation more susceptible to drought.

Latest Science: Action is Overdue

A dried up Trinity Lake, one of the largest reservoirs in California. Much of its water goes to agriculture and Reservations are often left dry.

“In Indigenous cultures, it is understood that ecosystems are chaotic, complex, organic, in a constant state of flux, and filled with diversity. No one part of an ecosystem is considered more important than another part and all parts have synergistic roles to play. Indigenous communities say that ‘all things are connected’ – the land to the air and water, the earth to the sky, the plants to the animals, the people to the spirit.”– Patricia Cochran, Inupiat Leader

Tackling the largest source of carbon pollution: power plants

• Top priority of the Administration as part of the President’s Climate Action Plan

• Under the Clean Air Act, the EPA has the authority to regulate carbon pollution

• Limits will be set for all new and existing coal and natural gas power plants

• Existing power plants account for 40% of U.S. carbon pollution

• Draft proposal due June 2nd.

• Likely 90 day comment period

• Due to be finalized by June 2015

The carbon rule: existing power plants

Feb March April May June July August Sep Oct Nov Dec

Carbon Standards Calendar

EXAMPLE TEXT

Draft standards in development

Draft Standards ReleasedPublic Comment Period Elections

Post-Election

Narrative

OMB2014

Jan Feb March April May June July August Sep Oct Nov Dec

Final Standards in development

OMB2015

Final Standards

Issued

Congressional Review Act likely

Jan Feb March April May June July August Sep Oct Nov Dec

2016

ElectionsState SIPs Due to EPA

Post-Election

Narrative

Power Plants & Tribal Communities

11% of existing power plants operate on or within 20 miles of reservation land

48 Tribes, 50 Reservations impacted

51 Generating Stations that are over 50 years old

Power plants of interest that may be impacted by the 111(d) standard:- Four Corners Generating Station, located on

the Navajo Reservation in northern New Mexico.

- Navajo Generating Station, located on the Navajo Indian Reservation in northern Arizona.

- Bonanza Power Plant, located near Vernal, Utah on the Uintah and Ouray Indian Reservation.

- Colstrip Generating Station, located east of Billings, Montana near the Northern Cheyenne Reservation.

Four Corners Generating Station, in northern New Mexico. Photo Credit: HuffingtonPost.com

The carbon rule: What is being discussed?

Key issues under discussion:

• Mass-based versus unit-based standard

• Compliance options over the fence line

• Role of state Renewable Energy Standards or regional trading programs

• For plants planning retirement: Worker transition

The carbon rule and the future of energy

• Can help spur innovation in new technologies and renewable energy

• Solar, onshore and offshore wind, energy efficiency, can be part of the mix to help meet carbon pollution reductions targets.

How tribes are part of the solution• Many tribes have initiatives to

address climate change

• Moapa solar plant: largest solar plant on tribal lands to date; generates 250 MW; employed 400 people in construction; powers 118,000 homes in L.A.

• Campo tribe has two wind power projects. The Kumeyaay Wind Project has 25 turbines that generate 2MW each, saving approx. 110,000 tons of greenhouse gases

Why this process is important• These rules are vitally important to

protecting our communities and wildlife from climate-disrupting carbon pollution.

• The EPA needs to hear from a variety of different voices and communities

• The public’s input is critical in helping shape the final rule

• The opposition will be strong so constructive engagement will be essential

How to Participate in the Rule-Making Process

• Submit written comments• Docket TBD after June 2nd

• Speak at a public hearing• Locations TBD. To submit a request for a public

hearing/meeting, contact:• EPA Office of Air and Radiation, Acting Assistant

Administrator, Janet McCabe (202) 564-7400

• Meet with state officials (Governor’s office, State Air Directors)

Weighing in with state agencies

• They play a critical role in determining how the rule will be implemented

• Support effective state plans

• Pass Resolutions stating support and desire for formal consultation in rule implementation

Felice Stadler, NWFSenior Director, Climate and Energy

202/797-6692; stadler@nwf.org

Garrit Voggesser, NWFNational Director Tribal Partnerships

303/441-5161; voggesser@nwf.org