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CGS Director Nathan Hultman Provides Testimony for Hearing on Clean Power Plan Repeal

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Nathan Hultman

On January 11, Center for Global Sustainability Director Nathan Hultman provided testimony at a hearing on the proposed repeal of the Clean Power Plan. The hearing was organized by the Maryland Office of the Attorney General and the Maryland General Assembly. Hultman’s testimony was as follows.


Testimony on the Repeal of the Clean Power Plan

Prof. Nathan Hultman

Director, Center for Global Sustainability

School of Public Policy

University of Maryland


Presented to

The Maryland Office of the Attorney General and

The Maryland General Assembly

Annapolis, Maryland

January 11, 2018


Attorney General Frosh, Senate President Miller, and Speaker Busch, thank you for the invitation to testify today.

The EPA’s recent proposal to repeal the Clean Power Plan would have several significantly negative consequences. First, it would steer the United States, and the State of Maryland, away from further accelerating the creation of clean energy to favor specific industry actors, most of whom are outside of Maryland, such as owners of coal fired power plants. Second, it would encourage costly misallocation of investment in polluting energy sources that may end up being made obsolete when future policy begins to address climate change. Third, it would constitute a major blow to recent advances to put the United States on a trajectory to reduce climate pollution to safer levels. Finally, it would damage America’s position in the world as a leader on essential issues of global human well-being, environmental health, and economic prosperity.

The CPP in contrast was designed to accelerate an ongoing transition toward cleaner energy sources that would provide benefits such as clean energy jobs, improved health for our citizens in Maryland and the United States, and a safer climate. It is grounded in legislation that reflects and implements our country’s early, global leadership on environmental issues – the Clean Air Act – and was built from a careful and thoroughgoing process of stakeholder consultation across industry, NGOs, and citizen groups. As Marylanders, we are already being impacted by climate change. We nevertheless can be part of the solution while building our own economy. Repeal of the CPP would slow efforts by those in the United States who want to lead the way toward a safer climate and a cleaner and healthier future. Let’s take a closer look at the potential benefits of the Clean Power Plan for the U.S. economy, jobs, health, and the environment. [1]


The CPP would support jobs in growing industries

First, the CPP would support jobs in growing industries. A recent Department of Energy report [2] noted that there are roughly three million jobs in the U.S. that are supported by clean energy and only about 160,000 that are supported by coal, and only 57,000 in coal mining. In Maryland, solar power jobs (over 7,000) already outnumber those for fossil fuel generation (under 4,000 jobs, of which only 2,400 in coal). [3] Undoing the CPP provides unnecessary and counterproductive favors to the owners of coal plants and coal mines while threatening job opportunities in the flourishing clean energy sector. While it is important to be mindful of any potential economic hardship that people working in the coal industry may face in transitioning to a less polluting power grid, even insiders acknowledge that the coal sector is not going to recover due to market trends and automation, rather than due to the CPP. Repealing the CPP will not in itself reverse the trends in energy markets that have increasingly favored gas and renewable energy sources.

Moreover, the long-term pressures to increase clean energy globally will not go away just because the Federal government chooses to ignore them. Within the United States, broader market forces will continue to advance cleaner energy supply and efficiency technologies. Unlike large fossil fuel generation, clean energy technologies are rapidly becoming cheaper over time. In the past eight years, we have seen costs for wind drop by 40 percent, solar by over 75 percent, and energy-saving LED lights by 90 percent.[4],[5] In many places, clean energy is already cost-competitive, and is even cheaper than coal power in some cases as renewable technology costs drop. These trends bolster the case that clean energy is an attractive, innovation-oriented growth option for our economy. Wind and solar energy, as well as other clean energy technologies like electric vehicles, energy storage, and efficiency, can advance energy independence while still delivering jobs and a cleaner environment.

When looking at the overall benefits, not just to a single industry, there are clearly estimated benefits to the American economy from the CPP. EPA estimated that the action would produce net benefits because of improved health and avoided climate change, including $14-34 billion per year in benefits just from improved health alone. Bolstering this perspective, it is worth noting that Maryland, in partnership with eight other states, recently strengthened our regional approach to reducing emissions in the Regional Greenhouse Gas Initiative, or RGGI. Analysis suggested long run economic impacts to the region, even before considering the avoided and significant damages expected from climate change. Specifically, one analysis of RGGI indicated that strengthening RGGI it would yield more than 130,000 additional job-years over the modeling period, and more than $9 billion in additional gross state product for the RGGI region.


The CPP would improve health and save lives

Second, the CPP would improve health and save lives. The CPP was expected to produce significant benefits for health through improved air quality, which was of course part of the original motivation for the Clean Air Act. Reduced coal burning would reduce a number of pollutants entering the air. For this reason the CPP was anticipated to prevent nearly 3,600 deaths per year by the time it was completed in 2030. It was also expected to prevent roughly 1,700 heart attacks, 90,000 asthma attacks, and 300,000 lost school and workdays each year. Among other populations, children are susceptible to air pollution and CPP would have provided benefits for reducing asthma and other respiratory ailments for kids. By dismantling the CPP, the U.S. will lose out on these health benefits for all populations.


Maryland and the United States are experiencing impacts of climate change

Third, the CPP would also have created significant benefits by reducing American emissions that contribute to climate change. Climate change poses a significant threat to natural and human systems, including national economies and economic sectors. It is now broadly agreed and scientifically non-controversial that (1) the earth’s climate is warming, (2) this warming is primarily driven by anthropogenic greenhouse gas emissions, (3) climate change is impacting natural and human systems, and (4) these impacts will intensify unless actions are taken to significantly curtail greenhouse gas emissions in the very near future.[6] The economic system is deeply entwined with these impacts, and effects are already being seen at global, national, and local levels. In 2016, the United States experienced 15 distinct “weather and climate disasters” costing over $1 billion each and in aggregate exceeding $45 billion.[7] Munich Re estimates that 2017 saw the highest weather-related losses ever, with the hurricane season in the North Atlantic proved particularly costly and accounting for $215 billion in overall losses.[8]

As many of us are aware, Maryland’s coastal and Chesapeake Bay geography makes the state vulnerable impacts of climate change through sea level rise and flooding. Recent flooding – such as last year’s once-in-1,000-year flood in Ellicott City—has shown vulnerability to the kinds of changes expected from climate change.[9] In Maryland, where sinking land and eroding beaches have resulted in greater sea level rise than in most coastal areas, the chronic effects of climate change are of great concern.[10] Our state has 3,190 miles of shoreline and approximately 265,000 acres of both urban and rural land located less than five feet above the high-tide line. In Dorchester County, wetlands have already become inundated by rising sea water, and by the end of the 21st century, as much as 50% of the county may be under water, causing irreversible damage to the state’s coastal ecosystems and local economies.[11] 25% of structures in Ocean City are vulnerable to flooding, and on the lower Eastern Shore, communities like Hooper’s Island, Smith Island, and parts of Crisfield are so low that water in ditches along the streets rises and falls with the tides.[12]


The CPP is an important component of a global solution to a global problem

Fourth, the CPP is an important component of a global solution to a global problem. The CPP aimed to reduce greenhouse gas emissions from the electricity sector—responsible for approximately 30 percent of America’s overall greenhouse gas emissions—by roughly 32 percent by 2030. In reducing our own carbon pollution, the CPP was part of a strategy to lead internationally to ensure that the other countries of the world, like China, are also taking major steps to reduce their emissions. Many of the most inexpensive and economically efficient opportunities for emissions reductions exist in the power sector. Repealing the CPP would imply a costly delay in implementing what in the long run will be necessary reductions in our overall greenhouse gas emissions over time. This also has implications for broader U.S. engagement in international climate policy. Rolling back the CPP would remove an important component of our American climate strategy and make it more difficult to achieve longer-term U.S. climate targets. Other players, including big emitters like China, the European Union, and India, have re-committed to continuing to pursue their own climate goals under the Paris Agreement, in part because they view doing so as good for their own domestic politics and economies. Here too at home, a significant group of non-Federal actors, including States, Cities, and Businesses, representing in aggregate the equivalent of the world’s third largest economy, have committed to their own climate goals under the America’s Pledge and We Are Still In efforts.[13] Nevertheless, such a retreat from responsibility by the world’s second-largest emitter of greenhouse gases represents an obstacle to the ambitious global goals for climate stabilization set out in recent years. The long-term success of the global approach to climate change depends on continued broad engagement to encourage a cycle of positive action across the global community. Repealing the CPP threatens this important process.



In conclusion, repealing the Clean Power Plan would have negative implications for the State of Maryland, the United States, and the world. The CPP was developed over many years of consultation with industry, health advocates, states, and other stakeholders. While higher-polluting sources like coal-fired power plants would need reduce emissions to meet the rules, the CPP provides a reasonable approach to reducing the most harmful emissions and steering the economy toward a sounder energy system for the future. Marylanders participated in the long consultative process to bring the CPP to fruition, and the voices of Marylanders should be heard before the EPA takes any action on this important regulatory action. In parallel, mindful of the importance of the topic to our citizens and economy, we can and ought to consider ways that we can continue to move our state toward a clean energy economy that can provide benefits to jobs, health, and the state economy, and also reduce our emissions. Continued engagement by states and other actors, working together wherever possible, will be important to bolster global ambition to tackle this challenge.


[1]Elements of this testimony were drawn from previously published works by the author, including “Trump’s Executive Order on Energy Independence,” available at and “Climate Change Risk and the Maryland State Retirement and Pension System,” by M. Binsted, N. Hultman, W. Hanson, A. Miller, T. St. Clair; Center for Global Sustainability Report, 49 pp., Oct 2017. Available at

[2]U.S. Department of Energy. United States Energy and Employment Report. Jan 2017, 84 pp.


[3]U.S. Department of Energy. “Maryland Energy and Employment 2017” in: United States Energy and Employment Report: Jan 2017, Available at:

[4]U.S. Department of Energy, Revolution Now. DOE/EE 1478, Sep 2016, 26 pp.â€Now%202016%20Report_2.pdf

[5]Bloomberg New Energy Finance “Global wind and solar costs to fall even faster, while coal fades even in China and India.” Research Note, June 2017.

[6]Intergovernmental Panel on Climate Change (IPCC) (2014). “Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change.” [Core Writing Team, R.K. Pachauri and L.A. Meyer (eds.)]. IPCC, Geneva, Switzerland. Online. pdf.

[7]Smith, Adam, Neal Lott, Tamara Houston, Karsten Shein, Jake Crouch, and Jesse Enloe (2017). “U.S. Billion- Dollar Weather & Climate Disasters: 1980–2016.” NOAA National Centers for Environmental Information. 2017. Online. https://www.ncdc.noaa. gov/billions/events.pdf.

[8]Low, Petra (2018) “Hurricanes cause record losses in 2017 - The year in figures.” Munich Re Research Note.

[9]Cox, Erin (2016). “Lawmaker: ‘Did climate change kill two people in Ellicott City?’.” The Baltimore Sun. 01 Aug 2016.

[10]United States Environmental Protection Agency (EPA) (2016). “What Climate Change Means for Maryland.” EPA. Aug 2016. production/ les/2016-09/documents/climate- change-md.pdf.

[11]Boesch, Donald, et al. (2013). “Updating Maryland’s Sea-level Rise Projections.” Scientific and Technical Working Group, Maryland Climate Change Commission. 26 June 2013. les/pdfs/ SeaLevelRiseProjections.pdf.

[12]United States Environmental Protection Agency, “What Climate Change Means for Maryland.” EPA. Aug 2016.

[13]America’s Pledge Phase 1 Report: States, Cities, and Businesses in the United States Are Stepping Up on Climate Action. Nov 2017, 123 pp. Available at

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