It's been a month since the D.C. Circuit heard oral arguments on the Clean Power Plan, and the nation is in wait-and-see mode. But our report, Untapped Potential: The Carbon Reductions Left Out of EPA's Clean Power Plan, released today by the Center for Progressive Reform, shows that, even if the Plan is upheld, continued climate initiatives to control existing power plant emissions are warranted and workable.
Our analysis demonstrates that EPA identified numerous available reduction opportunities that were not incorporated into the Clean Power Plan's requirements. By 2030, these opportunities could have reduced emissions from existing sources by almost 400 million tons of carbon per year in comparison with the Clean Power Plan's requirements.
Whether EPA should or shouldn't have incorporated them into the Clean Power Plan is not the point. What is the point: given the pressing risks of climate change and extensive data on achievable reduction opportunities, policymakers should not just "wait-and-see" what happens to the Clean Power Plan. Continued administrative and legislative efforts to reduce emissions, including emissions from existing power plants, are needed regardless of the Clean Power Plan's fate.
Our report focuses on a little-discussed methodological choice that had significant ramifications for the Clean Power Plan's stringency: EPA's decision to establish relatively weak uniform national performance rates for coal and natural gas plants that left out significant reduction opportunities in the western states.
In developing the Plan, EPA initially assessed regional opportunities, focusing on the nation's regional grids: the Eastern, Western, and Texas Interconnections. Based on the opportunities it identified, EPA developed achievable regionally tailored performance rates, rates that diverged dramatically given much greater reduction opportunities in the west. EPA determined that, in the western states and Texas, coal-fired power plants could reduce their effective emissions rates significantly by taking advantage of extensive opportunities to shift generation to much less polluting natural gas plants and by developing available renewable energy opportunities.
As a result, after taking into account these reduction opportunities, the effective emissions performance rates for coal-fired power plants was 360 pounds of carbon dioxide per megawatt hour of electricity generated (lbs CO2/MWh) in the Western Interconnection and just 237 lbs CO2/MWh in the Texas Interconnection. By comparison, fewer reduction opportunities in the Eastern Interconnection resulted in much higher allowable emissions: an effective emissions rate of 1,305 lbs CO2/MWh in the Eastern Interconnection.
Instead of applying the regionally tailored performance rates, EPA selected the least stringent regional rates – from the Eastern Interconnection – and applied them nationwide. In other words, even though EPA had determined that coal-fired power plants could sharply reduce their effective emissions – down to 360 lbs CO2/MWh – in the western states, these states and their utilities are allowed, under the Clean Power Plan, to emit at much higher levels. Most importantly, the Clean Power Plan does not incorporate or incentivize many of the achievable reductions, through shifts to natural gas or investments in renewables, that EPA had identified.
The gap between what EPA required and what EPA determined could be done has important implications for the U.S. electric power sector and U.S. climate policy:
In terms of next steps, we do not argue that the Clean Power Plan should be re-opened; EPA undertook a major effort and EPA and the states should move forward with its important contribution. Nor do we think that the regional rates would necessarily have been the ideal strategy: EPA would have encountered potential legal questions in applying regional rather than uniform rates, and would most certainly have encountered withering political opposition from the western states, which would have received much more demanding targets.
Instead, our "what if" analysis of the use of regional rates is designed to highlight the gap between the reduction opportunities available on our regional grids and the reductions actually expected from the Clean Power Plan. The analysis shows that, even if not doable through the Clean Power Plan, we can do more to reduce existing source emissions.
At the regional level, states and regions should continue to explore emission-reducing strategies that go beyond the Clean Power Plan. A critical component of such strategies, however, will be ensuring that regional reductions beyond Clean Power Plan goals are "retired," so they do not simply enter into national allowance pools and end up being purchased by utilities choosing to maintain heavy carbon emissions. If "extra" reductions in one place merely enable more emissions elsewhere, then extra regional efforts will not result in effective net emissions reductions.
At the federal level, congressional climate action, however remote it may appear at present, remains critical. We are not "done" with power sector emissions, and policymakers should continue to explore national strategies to require or incentivize the opportunities that were revealed but not incorporated into the Clean Power Plan.
Showing 2,818 results
Alice Kaswan | October 27, 2016
It’s been a month since the D.C. Circuit heard oral arguments on the Clean Power Plan, and the nation is in wait-and-see mode. But our report, Untapped Potential: The Carbon Reductions Left Out of EPA’s Clean Power Plan, released today by the Center for Progressive Reform, shows that, even if the Plan is upheld, continued […]
Matthew Freeman | October 26, 2016
Whatever else may be said about Ken Bone, the red-sweatered citizen questioner at the second presidential debate earned an important place in the pantheon of presidential debates: He’s the only person to ask a debate question remotely related to climate change in the last eight years. As it happens, his question wasn’t all that direct, since it didn’t actually […]
David Flores | October 18, 2016
To date, climate adaptation and resilience planning efforts on the local, state, and federal levels have largely focused on protecting residential, commercial, and municipal infrastructure from sea level rise and deadly storm surge through such structural practices as shoreline armoring. However, a growing number of advocates are raising concerns about the threat that extreme weather […]
Evan Isaacson | October 17, 2016
Today, the Center for Progressive Reform (CPR) is releasing an assessment of the plans and progress of Baltimore City and the nine largest counties in Maryland to comply with their federal stormwater permits, a key component of the ongoing effort to clean up the Chesapeake Bay and restore it to health. The analysis looks carefully […]
Brian Gumm | October 12, 2016
NEWS RELEASE: Center for Progressive Reform Welcomes New Climate Adaptation Policy Analyst Today, the Center for Progressive Reform (CPR) announced that David Flores has joined the organization as its new policy analyst. Flores will serve alongside the group’s staff and Member Scholars in their efforts to protect public health and the environment, with a particular focus […]
James Goodwin | October 10, 2016
Originally published by the Oxford Business Law Blog. Reprinted with permission. Forced arbitration clauses are now almost impossible to avoid in consumer contracts for financial services and products ranging from credit cards to private student loans. Despite their ubiquity, most consumers aren’t even aware of them. This is because companies frequently bury them deep in […]
Katie Tracy | October 5, 2016
When it comes to worker health and safety, preventing injuries and illnesses is the number one goal. It was for this very purpose that Congress enacted the Occupational Safety and Health Act (OSH Act) and tasked the Occupational Safety and Health Administration (OSHA) with setting and enforcing strong workplace standards. But when preventative measures fail […]
William Funk | October 3, 2016
Originally posted at Notice & Comment, a blog of the Yale Journal on Regulation and the American Bar Association Section of Administrative Law & Regulatory Practice, as part of an online symposium entitled Reflections on Seminole Rock: The Past, Present, and Future of Deference to Agency Regulatory Interpretations. Reprinted with permission. The Separation of Powers […]
Matthew Freeman | September 30, 2016
In a story published yesterday, the Center for Public Integrity takes a deep dive into the public health impact of the nation’s “super polluters,” a collection of industrial polluters that account for an outsized share of toxic air pollution and greenhouse gas emissions in the United States. Produced in collaboration with USA Today and The […]