EPA Can Make The Clean Power Plan Even Better

The summer deadline is approaching for finalizing the Environmental Protection Agency’s first-ever limits on dangerous carbon pollution from the nation’s power plants, and opponents are ratcheting up their complaints.

Some 1500 mostly coal- and gas-fired power plants spew out more than two billion tons of heat-trapping carbon dioxide each year—40 percent of the nation’s total. The vast majority of the millions of public comments submitted last fall express strong support for the Clean Power Plan, which as proposed last June starts in 2020 and ramps emissions down gradually over the next decade.

But big coal polluters and their political allies have big megaphones.

Many hope to kill the proposal outright. For others the back-up agenda is to get the standards weakened and delayed past 2020. Their comments and speeches read like Armageddon is coming if power plants have to start limiting their carbon pollution in 2020—five years from now. Republican members of the Senate environment committee banged that drum over and over at a hearing last week. As on so many issues, they hope endless repetition will make their story seem true.

The truth is that the standards and timeline EPA proposed last June are quite modest and readily achievable. They can be met without any threat to the reliability of electric power. A new report from the highly respected Brattle Group shows that states can meet EPA’s proposal “while maintaining the high level of electric reliability enjoyed by U.S. electricity customers.” That’s because of the proposal offers many compliance strategies and because the U.S. power system is already transitioning away from older, higher polluting technologies of the past to a cleaner energy future. (My colleague John Moore has more on this report here.)

Indeed, we have the clean energy resources to significantly strengthen the standards. NRDC has done the analysis to show how we can cut dangerous carbon pollution faster while saving customers billions of dollars on their bills and creating hundreds of thousands of new clean energy jobs. This would bring huge public health and climate protection benefits worth 10 times their cost. You can find the full deal in our public comments; here’s a quick summary.

The plan as proposed in June sets state-by-state targets that, on an overall national basis, would cut power plants’ carbon pollution by 26 percent by 2020 and 30 percent by 2030, when compared to 2005 levels.

We found that with three specific improvements—I’ll describe them below—the plan could achieve 50 percent more carbon pollution reductions (36 percent by 2020 and 44 percent by 2030).

Here are the three factors:

First, the costs of clean energy are falling dramatically, and EPA’s June proposal was based on out of date cost and performance data for renewable electricity and efficiency energy. An NRDC issue brief published last fall details how sharply the cost and performance of energy efficiency and renewable energy have improved. When we factored in up-to-date data, our analysis shows that the Clean Power Plan’s state-by-state targets as proposed in June 2014 can be met at a net savings to Americans of $1.8–4.3 billion in 2020 and $6.4–9.4 billion in 2030. More reliance on energy efficiency and renewables will also create hundreds of thousands of good-paying jobs that can’t be shipped overseas.

The lower cost of clean energy technologies opens the door to getting substantially more carbon pollution reductions from the nation’s largest emitters.

We also took two other specific improvements into account:

  • In an October 2014 notice seeking further public comment, EPA explained that the formula it had used to calculate state targets in the June 2014 proposal did not correctly account for the emission reductions made by renewables and energy efficiency. The formula did not fully account for the reduction in generation at coal and gas power plants that occurs when additional renewables are added to the grid and when businesses and homeowners reduce how much electricity they need by improving the efficiency of our buildings, appliances, and other electricity-using equipment. NRDC corrected the formula in our updated analysis to capture the full emission reduction associated with ramping up renewables and efficiency.
  • EPA also asked for comment on an approach to better balancing state targets by adopting a minimum rate of transition from older high-emitting generation to lower-emitting sources. NRDC analyzed state targets that include conversion of 20 percent of coal generation in 2012 to natural gas generation over the period between 2020 and 2029.

These three factors—updating the cost and performance data for renewables and efficiency, correcting the target-setting formula, and including a minimum rate of transition from higher- to lower-emitting plants—produce the substantial additional carbon pollution reductions in our analysis, all at very reasonable costs.

With the extra carbon reductions will come large additional reductions in other power plant pollutants (sulfur dioxide and nitrogen oxides) that researchers from Harvard, Boston and Syracuse universities have shown contribute to thousands of premature deaths and tens of thousands of asthma attacks.

These much larger carbon and other pollution reductions can be accomplished at a cost of $6.4 billion in 2020 and $10.3 billion in 2030—substantially the same cost that EPA predicted in June 2014 ($7.5 billion in 2020 and $8.8 billion in 2030).

Here’s the big difference: The extra pollution reductions produce quantifiable climate protection and public health benefits that dwarf their compliance costs. We found health and climate benefits worth up to $76 billion in 2020 and up to a whopping $119 billion in 2030.

That’s more than 10 times the costs.

And these are just the benefits on which economists can place a dollar value; the damages from turning our climate upside down go well beyond that.

Here’s another benefit: By capturing additional carbon reduction potential from renewables and efficiency, our analysis shows lower natural gas consumption than EPA projected in the June proposal—about 10 percent less gas consumed in 2020, and 17 percent less in 2030.

At the Senate hearing last week, Janet McCabe, who leads EPA’s air office, testified that the agency was looking “very, very closely“ at the comments on the 2020 question. Some reporters mistakenly thought that was news and tried to divine hints of changes to come. But Administrator Gina McCarthy and Ms. McCabe have giving the same answer for months, on this and many other issues. Indeed, it’s the proper answer to give when the agency is still reviewing comments and moving towards the final rules.

We’re confident that when EPA looks at the facts and sorts away the hype, it will see that we can do more, not less, to cut the power plant that’s driving dangerous climate change.

About the Authors

David Doniger

Director, Climate & Clean Air program

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