NRDC Analysis Shows EPA Can Achieve Deeper Power Plant Carbon Pollution Cuts by Adopting More Clean Energy

WASHINGTON (December 1, 2014) – The Environmental Protection Agency can ramp up energy efficiency and renewable power, and achieve substantially deeper cuts in carbon pollution from power plants than it has proposed, the Natural Resources Defense Council said in public comments submitted to the agency today.

Such improvements would deliver major savings for consumers on utility bills, trigger a boom in clean energy jobs and reduce power plant carbon pollution by more than 40 percent by 2030, according to NRDC’s analysis. That would far surpass the 30 percent by 2030 goal President Obama outlined when the EPA first proposed its Clean Power Plan last June.

These recommendations and more are contained in NRDC’s analysis of the proposal to limit, for the first time, carbon pollution from the nation’s existing fleet of power plants. NRDC released its formal comments on the proposal to EPA today; the deadline for delivering public comments. 

“The president’s plan is a vital step toward protecting future generations from the dangers of climate change, and the administration can make this good plan even better,” said David Doniger, director of NRDC’s Climate and Clean Air Program and a contributing author of NRDC’s comments. “Let’s recognize the full potential for cutting dangerous carbon pollution by investing more in energy efficiency and renewable power. We’ll get more with less, save people money on their electric bills, and put people back to work building and installing clean energy systems for tomorrow.”

NRDC strongly supports the proposed Clean Power Plan’s system of enabling each state to develop its own plan for meeting its carbon reduction target. At the same time, NRDC’s comments outline ways for EPA to make the plan stronger, more flexible and more effective in curbing power plant carbon pollution, in its final Clean Power Plan standards, which are due by June 2015.

For example, NRDC finds  prices for energy efficiency investments and renewable power costs are substantially lower than EPA assumed in its analysis, and their performance is continually improving.

Improvements in products like LED light bulbs, energy thermal windows and other building materials that cut down on energy losses have made it easier for the nation can be smarter about its energy use. That’s important, because improving efficiency is the fastest and cheapest way to cut our carbon footprint.

Specifically, the cost of installing solar panels on homes has fallen 46 percent since 2010, and similar price drops are being seen in wind. Those two sources accounted for 44 percent of all the new electricity generating capacity installed in 2012 and 2013, federal data shows.

As a result of these improvements and trends, the EPA’s figures underestimated the potential for renewable generation in 2020 by at least 60 percent because the agency’s analysis didn’t fully capture the recent price reductions for getting power from the wind and sun. Similarly, the EPA’s projections underestimate what’s possible through energy efficiency.

EPA determined that energy efficiency could supplant 1.5 percent of retail electric sales. This figure, NRDC says, is too low because EPA didn’t include potential energy efficiency gains through such measures as building codes, transmission and distribution and voltage optimization. Factoring in those opportunities, NRDC calculates that energy efficiency can achieve savings equal to 2 percent of retail sales each year.

By updating renewable power and efficiency potential, NRDC shows that the nation can cut more carbon more cheaply and create even more jobs than the agency’s analysis has projected.

“Clearly, with more efficiency and more renewable power, there’s room for the EPA to readily cut power plant carbon pollution by more than 40 percent in 2030, compared to 2005 levels,” said Doniger.  “We should commit to at least that much of a cut in this dangerous carbon pollution, and demonstrate with actions, not words, that we’re serious about protecting future generations from the dangers of climate change.”


An executive summary of NRDC’s comments to EPA on the Clean Power Plan is available here:

The comments can be found here:

NRDC President Frances Beinecke also has a new blog on this issue, here:


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