The new proposal would take us backward on climate, tilt the grid toward coal, and actually kill people.
This Is Your Plan?
The U.S. Environmental Protection Agency this week released its long-awaited replacement for the Clean Power Plan, President Obama’s initiative to reduce carbon pollution from power plants. When Obama announced the plan, in 2015, he called it “the single most important step America has ever taken in the fight against global climate change.” In President Trump’s plan, climate change is an afterthought. In nearly 300 pages, the proposal mentions the phrase “climate change” just three times.
The absence of the double-c phrase isn’t just an optics issue. It’s going to cause the Trump team trouble when they try to defend the proposal in court. The EPA created the Clean Power Plan under its authority to combat the greenhouse gas emissions that contribute to climate change. When repealing existing rules, a new administration must provide a rational basis for its decision. There is no rational basis for the new rule, because it doesn’t represent an effort to combat climate change.
The Trump proposal withdraws the obligatory emissions targets for states, thus removing a backstop that would ensure the closure of the aging, inefficient coal-fired power plants that contribute a large share of greenhouse gas emissions. Trump’s plan allows states and the utility market carte blanche in deciding whether we should even bother to address climate change.
According to one early estimate, the Trump proposal would result in 63 percent greater carbon emissions than under the Clean Power Plan—that’s nearly the same emissions as under a business-as-usual scenario. “Letting whatever happens, happen” cannot be described as a plan to combat greenhouse gas emissions.
The kicker is that Trump’s redo is unlikely to help the coal industry. Utilities around the country have been shuttering coal-fired power plants for years. Coal’s share of U.S. electricity generation dropped from 51 percent in 2008 to 31 percent in 2016, and more than 200 coal-fired power plants have closed since 2010. The industry’s decline has nothing to do with the Clean Power Plan, which still hasn’t gone into effect. Four percent of the nation’s remaining coal-fired power plants are scheduled to close this year alone, with most of those closures announced after President Trump took office. It’s simple economics. Natural gas (which comes with its own problems) and, in many areas, renewables are cheaper than coal, and the price of renewable energy continues to fall. Since those economics are unlikely to change, there is no prospect of a coal-fired comeback.
Like Premature Death? You’ll Love This Plan
Trump’s power plan is bad for our atmosphere, legally dubious, and unlikely to help the coal industry. But wait, there’s even more to not like. According to the EPA’s own analysis, by 2030 the proposal would cause up to 1,400 deaths annually and up to 15,000 cases of upper respiratory problems.
The science is relatively straightforward. The Clean Power Plan aimed primarily to reduce carbon pollution, but by closing coal-fired power plants, it would also cut the emission of tiny particulate matter that gets into our lungs and causes mayhem in our respiratory and circulatory systems. Public health researchers have been collecting data on deaths from utility-based air pollution for decades. The research is robust and beyond debate.
Air pollution from power plants alone is a significant cause of American mortality, contributing to as many as 52,000 deaths per year. That’s more people than those who die in car crashes or by suicide, and nearly as many as those who die from pneumonia and flu. Taking a step backward on air pollution from power plants is an indefensible public health mistake.
The Fine Print
Buried deep in Trump’s plan is a consequential change to existing law. Under current rules, coal plant operators need a permit to make any modifications that would increase annual carbon emissions. This system, known as “new source review,” works as a brake on greenhouse gas emissions.
But instead of looking at annual increases in emissions, the new proposal requires only permits for increases in hourly emissions rates. The change is subtle, but it would make a big difference.
Let’s say you’re running a coal plant that emits 100 metric tons of carbon per hour. (This is a completely made-up number. Emissions rates for actual coal-fired power plant vary according to a number of factors.) Because coal is economically noncompetitive, you’re able to run the plant only 40 percent of the time, when there is high demand for electricity. Your total annual carbon emissions would be 350,400 metric tons.
But say you want to install a new component that would increase efficiency by 5 percent. Now, rather than emitting 100 metric tons of carbon per hour, you emit 95 metric tons. Under the Trump plan, you wouldn’t need to go through the permit process. But you would have to under existing rules, and here’s why: The increased efficiency likely makes you more price-competitive. So instead of running 40 percent of the time, you will run your plant 50 percent of the time, which results in your annual emissions actually going up by 65,700 metric tons.
Becoming more reliant on coal-fired power plants, even if they’re slightly more efficient than before, is a significant loss in terms of climate change mitigation. An upgrade may decrease a coal-fired plant’s hourly emissions rate, but the plant would still be belching out far more carbon than renewables and natural gas—the power sources it would be displacing. If the goal is to continue to cut greenhouse gas emissions (and remember, that is the original plan’s goal), we shouldn’t be doing any favors for coal-fired power plants.
Stay up-to-date on Trump’s environmental antics by visiting NRDC’s Trump Watch.
