Published in the Abilene Reporter News.

As the Environmental Protection Agency (EPA) weighs nationwide mandates on carbon emission standards for power plants, coal-heavy states currently utilizing large percentages of coal for power generation must demand flexibility with EPA standards on existing plants. These standards are targeted at the coal-fired power generation that provides Texans with reliable, affordable electricity. The repercussions of an overreaching, one-size-fits-all model would create an unreasonable burden and complicated regulatory framework for energy providers.

While states already are looking toward a future of alternative energy sources, such as natural gas, states also are working on strategies for best implementing the gradual change in energy sources. EPA’s carbon emission standards likely would be used to immediately shift power generators in states away from coal and toward new natural gas-powered plants by forcing plants to retire prematurely. The standards could be aggressive and not leave states utilizing coal for the majority of their power sources opportunity for adjustment to meet requirements.

If such inflexible rules emerge, this likely would cause significant cost for consumers on electric rates and manufactured goods, and generate reliability issues for domestic manufacturers. Furthermore, it could have detrimental effects on U.S. competitiveness in world markets, halt America’s energy boom and manufacturing renaissance and cost the U.S. economy. The rules could lead to the loss of jobs in mining, energy development, electric generation and manufacturing industries that Texas and other states have created.

In an effort to stage public discourse in favor of more stringent carbon emission standards on existing power plants, EPA is laying the necessary groundwork to build its case to be heard before the Supreme Court. The Supreme Court last month announced that it would consider a challenge to EPA’s authority to regulate carbon emissions from stationary sources, including power plants, refineries and factories. EPA has scheduled Public Listening Sessions throughout the U.S. designed to gather public input on the agency’s approach to carbon emission regulations on existing power plants. EPA stated in its September press release that the feedback from these sessions “will play an important role in helping EPA develop smart, cost-effective guidelines that reflect the latest and best information available.”

It is essential to note EPA’s underhanded effort in that sessions are scheduled only in major metropolises — Boston, New York, Philadelphia, Atlanta, Dallas, Chicago, San Francisco and Seattle. Despite the fact that proposed rules will have the most significant effect on states obtaining the majority of its power supply from coal, the tour fails to stop in areas where coal represents the bulk source for electric generation. Texas and other coal-heavy states must ensure their voices are heard.

States need an “all of the above” energy policy until further energy sources are able to economically support consumers’ needs in electric markets. EPA’s proposals run contrary to a balanced energy approach. In considering power plants currently on the grid, states cannot meet a stringent rate-based emission standard of the kind EPA put forward for new power plants last month. State public utility commissions will be tasked with a near impossible undertaking in ensuring that state compliance plans do not undermine the reliability of power supplies or cause rates to skyrocket.

Emission standards that are economically feasible for states are crucial. EPA must work to craft a flexible rule that can be applied to states with different energy profiles based on their own unique conditions. States that have a plan in place to cut carbon pollution from power plants should have the chance to make a case to federal regulators that their program offers a viable model for other states.

It is imperative that you provide your comments to EPA at the Texas Listening Session. If you are able to appear in person, the Listening Session is scheduled from 10 a.m.-3 p.m. Thursday at the J. Erik Jonsson Central Library, 1515 Young St., in Dallas. The hearing will be held in the first-floor auditorium. To attend, you must register at http://www2.epa.gov/carbon-pollution-standards/public-listening-session-registration.

EPA also is accepting input at this website: http://www2.epa.gov/carbon-pollution-standards/forms/carbon-pollution-standards-contact-us. Or send email to carbonpollutioninput@epa.gov.

Texans, please make your voices heard.