The Trump Administration has proposed a rollback of the Clean Power Plan (CPP), the nation’s first-ever limits on climate pollution from power plants. If the CPP is repealed, the United States will have no nationwide plan to reduce emissions from one of the country’s largest sources: electric power generation.
Businesses have a critical role to play in determining the future of the CPP. Under the law, the EPA must take public comments into account when developing a new rule or withdrawal. By filing public comments in support of the CPP, you are speaking up for action on climate change, access to clean energy, and accelerating low-carbon innovation and job growth in the United States.
Here’s why businesses should file comments with the EPA by April 26th, 2018:
- Shape the future of the power sector
By limiting climate pollution from power plants, the CPP impacts the entire electricity market – providing incentives for greater access to and investment in clean energy, as well as energy-saving efficiency investments that reduce energy bills for businesses and families.
As a major purchaser of electricity, your company has a critical stake in policies affecting the power sector. But your views will only be considered if you speak up. The way to do that is to file comments with the EPA, attend public hearings and make your voice heard through op-eds, blog posts and other communications.
It’s essential to remind the world that the partnership of good policymaking includes a broad swath – not a narrow swath – of the business community. Businesses have both a cost stake and a sustainability stake in electricity, and have a lot to contribute to the ongoing evolution of the power sector.
— Joe Goffman, Executive Director, Harvard Law School Environmental Law Program
- Walk the talk on climate and clean energy
Speaking up for smart climate and energy policies like the CPP shows your stakeholders you’re walking the talk on sustainability. It should be a no-brainer for companies that have made commitments to cut greenhouse gas emissions or shift to renewable energy, or signed on to We Are Still In.
Your stakeholders expect you to advocate for smart policies like the CPP:
- Investors and shareholders are increasingly scrutinizing companies’ engagement in public policy, and demanding consistency with their sustainability goals.
- Customers and employees broadly support policies that cut carbon pollution and protect human health.
- Millennials, in particular, care deeply about climate change and are significantly more likely to support companies they perceive to have strong environmental values.
- Speed the transition to a thriving, low-carbon economy
The CPP is central to the U.S.’s ability to achieve the emission reductions we committed to in Paris in 2015. It also establishes a predictable framework for reducing carbon pollution from the power sector, and creates a stable environment for planning and investment for companies across all sectors.
Rolling back the CPP would slow job growth by reducing demand for clean energy, a sector that is adding jobs far faster than the rest of the economy. It would also put U.S. manufacturers of low-carbon technologies at a disadvantage globally if demand for their products shrinks here at home.
The Clean Power Plan is a driver for U.S. jobs and manufacturing and the ability to export American ingenuity abroad. It’s absolutely fundamental to our economic prosperity here, which obviously equates to VF’s business success. That’s why I’m so bullish on the Clean Power Plan, and why I’m committing the time and energy of our leaders to encourage the Administration to keep it.
— Letitia Webster, VP of Global Sustainability and Responsibility, VF Corporation
How to Submit Public Comments
Submit your comments via the regulations.gov page for “The EPA Proposed Rule: Repeal of Carbon Pollution Emissions Guidelines for Existing Stationary Sources: Electric Utility Generating Units” by April 26, 2018.
* Note: We recommend that businesses prioritize comments on the proposed repeal of the Clean Power Plan, and not the recently announced—and separate—EPA request for input on whether and how to replace the Clean Power Plan, as EPA has not committed to move ahead with that process and finalize a replacement.
Please review the Federal government's checklist and tip sheet for submitting effective comments. A single, well-supported comment can carry more weight than a thousand form letters. In particular:
- Identify your credentials and business experience to make your comments stand out.
- Explain the economic impact of the proposed CPP repeal on your company, using quantitative and/or qualitative data.
Here is a suggested outline for company comments in support of the CPP.
Additional CPP Resources
Links to previous filings
Many companies have already submitted filings in support of the CPP, which provide good examples of the advantages the plan offers for business:
- Amazon, Apple, Google, Microsoft (“Tech Amici”)
- Adobe, Mars, IKEA North America, Blue Cross/Blue Shield of Massachusetts (“Business Amici”)
- Sustainable Business Organizations
- VF Corporation's op-ed: Why the Clean Power Plan is good for business
- EDF’s CPP webpage and blog post (Three reasons for companies to defend the CPP).
- Recording of a November 28, 2017 Ceres-EDF webinar on the CPP.
- Ceres press release: Trump Proposal to Abandon Clean Power Plan Out of Step with the Business Community.