NRDC's Public Comments on the Clean Power Plan: How EPA Can Make Its Good Plan Even Better

NRDC submitted our public comments yesterday on the Environmental Protection Agency’s proposed Clean Power Plan to cut the climate-disrupting carbon pollution from the nation’s electric power plants.  NRDC supports EPA’s action under the Clean Air Act to clean up our power plants, and we show how EPA can make its good plan even better.  You can read the executive summary of our comments here, and the full comments are posted here.

Climate change is the central environmental challenge of our time, threatening our children with growing risks of rising seas, widening deserts, soaring heat, raging storms, runaway fires and withering drought.  Those threats are growing more urgent: the first ten months of 2014 have been the hottest, globally, since record-keeping began in 1880.  We have an obligation to protect future generations from the dangers of this widening scourge.

Power plants are the nation’s number one source of the dangerous carbon pollution that is driving climate disruption.  More than two billion tons of carbon dioxide — 40 percent of the nation’s total — spew forth each year from more than 1500 fossil fuel-fired power plants across the United States.  The Clean Power Plan will put the first-ever national limits on that pollution to protect our health and the stability of the climate.

Here are the main points we made to EPA: 

First, NRDC strongly supports the leadership of President Obama and EPA in issuing the Clean Power Plan under the Clean Air Act, the landmark law that after four decades continues to protect our health and our environment from dangerous pollution.  Poll after poll shows that the public is solidly behind the Clean Air Act, and solidly behind setting standards for carbon pollution from the nation’s power plants (see here, here, and here).  Americans have raised their voices to submit an unprecedented 8 million written comments in support of EPA’s carbon pollution standards for new and existing power plants.

Second, EPA can and must make its good plan even better — even more effective at cutting carbon pollution, saving customers money, and creating clean energy jobs.  NRDC has done the analysis, using the same modeling platform that EPA and industry use (the IPM® model), to show that we can cut power plant carbon pollution even more than EPA proposed for substantially the same cost as EPA’s plan, with huge public health and climate protection benefits that dwarf those costs.

The plan as EPA proposed it in June calls for cutting carbon emissions from the nation’s dirty power plants by 26 percent by 2020 and 30 percent by 2030, when compared to 2005 levels.  

By comparison, NRDC’s IPM analysis of the standards — analyzing the impact of three specific improvements that I’ll review below — yields carbon pollution reductions of 36 percent by 2020 and 44 percent by 2030, again compared to 2005 levels.  There will also be large additional reductions in sulfur dioxide and nitrogen oxides. These much larger pollution reductions can be accomplished at a cost of $6.4 billion in 2020 and $10.3 billion in 2030 (as compared with EPA’s June estimates of $7.5 billion in 2020 and $8.8 billion in 2030). 

The quantifiable value of climate protection and public health benefits from these reductions dwarfs those compliance costs.  NRDC finds climate protection and public health benefits worth up to $76 billion in 2020 and up to a whopping $119 billion in 2030.  And these are just the benefits on which economists can place a dollar value; the damage from turning our climate upside down goes well beyond that. 

What are the primary drivers of our new results?

NRDC’s comments suggest many improvements in the EPA proposal, but our modeling analysis focuses on three specific factors.

First, the costs of clean energy are falling dramatically, and EPA’s June proposal was not based on current cost data for renewable electricity and efficiency energy.  An NRDC issue brief published last month details how the costs and performance of energy efficiency and renewable energy have improved. We factored in up-to-date cost and performance data, and our analysis shows that the Clean Power Plan state-by-state emission reduction targets that EPA 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. And the lower costs of energy efficiency and renewable generating technologies open the door to getting substantially more carbon pollution reductions from the nation’s largest emitters.

We also took into account two other specific improvements in EPA’s proposal: 

• In an October notice seeking further public comment, EPA explains that the original formula used to calculate state targets in its proposed rule did not correctly account for the emission reductions generated by renewables and energy efficiency. As EPA explains, the formula used in the proposed rule failed to fully account for the reduction in generation at coal and gas power plants that will occur when additional renewables are added to the grid and when we improve energy efficiency.  EPA sought comment on a corrected formula, and we used that 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.  We 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 to fully reflect the emission reductions from renewables and efficiency, and including a minimum rate of transition from higher- to lower-emitting fossil-fueled plants — produce the substantial additional carbon pollution reductions in our analysis, all at very reasonable costs.

Because NRDC’s analysis captures additional carbon pollution reductions from renewables and efficiency, we expect substantially 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.  The Clean Air Act empowers states to go beyond EPA’s minimum requirements, and we will work to ensure that their state plans maximize use of energy efficiency and renewable energy and minimize reliance on fossil fuels.

At the same time, NRDC is pressing EPA to curb dangerous leakage of methane — the second most important climate pollutant — from the oil and gas infrastructure that delivers gas to our power plants, as well as to our homes and businesses.  The reality is that while we work with the states to maximize reliance on clean energy, natural gas will be part of our energy mix for some time.  Practical, low-cost measures are available today that can cut methane leakage in half. The Obama administration is expected to decide on oil and gas methane standards this fall.  The Clean Power Plan plus action on methane are the critical one-two punch we need in the fight against climate change.

NRDC’s comments also recommend changes to make the Clean Power Plan more verifiable and enforceable.  Right now, EPA has proposed that carbon pollution cuts in each state be averaged in over a ten-year period between 2020 and 2029.  A further target takes hold in 2030.  We recommend setting five-year compliance periods — starting in 2020, 2025, and 2030, with a regular review every five years starting in 2020 to update the targets in light of new information, and to set targets for the out-years (e.g., 2035) based on the best forecasts at the time.  This is a structure that will keep the standards current as technology and costs continue to improve, and that will drive towards the long-term carbon pollution cuts we need to prevent unmanageable climate disruption. 

Many states and a number of power companies support the Clean Power Plan.  Still, we know that some quarters of the fossil fuel industry — and, of course, some politicians — will continue to howl at the proposal, and even more so at the improvements NRDC recommends.  They’ve claimed the sky is falling every single time EPA acts to clean the air, and every single time they’ve been wrong.

Some are out there saying we should put fossil fuel profits ahead of our children’s future. We’re not going to do that.  We cannot continue with business as usual and leave our children and future generations a world turned upside down by unchecked climate change. 

Others are deliberately misleading the public about this plan’s impact on coal companies and coal miners. Mechanization and market shifts are the main reasons why coal jobs have been declining, and that’s been happening while clean energy jobs are on the rise. We need to do a better job linking the opportunities of the growing clean energy sector to the skills of many in the coal mining industry who are struggling to hang on to their jobs, and we are committed to help with that as EPA completes its standards and as states write their implementation plans.

Still others warn of power shortages if we dare to move forward into the clean energy future. Most of the recent studies simply fail to account for the potential of renewables and efficiency.  Moreover, the Clean Power Plan will phase in progress in a way that complements the systems we have in place to ensure reliable and affordable energy for all Americans.  We can have both cleaner and reliable power.

Let the industry and its political allies cry wolf, as they always do. The people who built this country, and will lead it into the future, have always looked forward, not back. Looking forward, we see an American economy powered into the 21st Century by the clean energy solutions of tomorrow. We see a nation committed to protecting future generations from the dangers of climate change. And we see a people healthier, more prosperous and more secure tomorrow, because of what we choose to do today.