Climate 411

Misguided Legal Attacks on Clean Power Plan Seek to Undermine Clean Air Act, Public Participation

Source: iStock

Source: iStock

The Environmental Protection Agency (EPA) will finalize rules establishing the nation’s first limits on carbon pollution from the power sector – the largest source of greenhouse gas emissions in the United States – by mid-summer of this year.

This timetable will allow EPA to carefully consider and respond to the approximately four million public comments it has received on almost every aspect of these vital and common-sense standards, which were proposed in draft form last summer as the Clean Power Plan.

Unfortunately, several states and a major coal producer have attempted to short-circuit this process by filing highly unusual legal challenges to these proposed standards. The challenges were filed in the U.S. Court of Appeals for the D.C. Circuit in two related cases, Murray Energy Corporation v. EPA (Nos. 14-1112 & 14-1151) and West Virginia v. EPA (No. 14-1146).

EDF — along with other environmental groups, a coalition of states, and a major power company — participated in these suits in support of EPA, and briefs were filed in both cases this week. (Read our brief in Murray Energy here and our brief in West Virginia here).

These lawsuits are untimely, legally unfounded, and seek to undermine a critically important democratic process.

One of the bedrock principles of administrative law is that standards developed by federal agencies go through a procedure whereby draft standards are published, the public has an opportunity to comment, and agencies review and respond to those comments in the final standards — all before legal challenges to those rules can be filed.

This process ensures that the public has a meaningful chance to weigh in on agency actions. It also helps agencies themselves ensure their decisions are well-informed and firmly grounded in law and science. In fact, proposed rules often undergo substantial changes as a result of the comment process. The rule against judicial review of proposed rules respects the importance of this process, and keeps courts and agencies from wasting valuable time and judicial resources on litigation over rules that may change as a result of public comments.

Disregarding this basic principle, the petitioners in these two cases argue that the proposed Clean Power Plan is unlawful – and demand that the court set the proposed rule aside before EPA has even finished its review of comments, much less issued a final rule.

But this fundamental jurisdictional obstacle is only the start of the problems with the petitioners’ case, which rests on an implausible reading of the Clean Air Act that would undermine the very health protections Congress sought to establish there.

EPA’s Clean Power Plan is authorized by section 111(d) of the Act, which requires EPA to administer a process by which states submit plans to regulate certain pollutants from existing sources of harmful air pollution. When enacted in 1970, section 111(d) clearly required that states establish such standards for any pollutant except those regulated under section 108 of the Clean Air Act (which addresses national air quality standards) and section 112 (which applies to acutely toxic “hazardous air pollutants” or HAPs).

For more than forty years, section 111(d) has been understood to serve a vital “gap-filling” role in the Clean Air Act – ensuring the protection of human health and welfare from harmful air pollution from existing sources, where that pollution is not adequately regulated under other provisions of the Clean Air Act.

Ignoring that sensible and long-standing framework, the petitioners in these cases have advanced an unusual theory — that EPA is barred from regulating carbon pollution at all under section 111(d) of the Clean Air Act because the Agency is already regulating different pollutants from the power sector (mercury and other air toxics) under section 112 of the Clean Air Act.

As EPA explained in its brief in West Virginia, this theory amounts to a “pick your poison” approach to the Clean Air Act – arbitrarily limiting EPA to regulating either HAPs like mercury (under section 112) or non-HAPs like carbon pollution (under section 111(d)) for any given source, but not both.

The petitioners’ interpretation not only defies logic and the basic structure of our nation’s clean air laws, it also stands in sharp contrast to arguments that industry itself made to the Supreme Court in the case of American Electric Power v. Connecticut (2011).

There, the Court specifically found that section 111(d) “speaks directly” to the problem of carbon pollution from the power sector, and held that EPA’s authority to regulate carbon pollution under section 111(d) displaces federal common law.

In oral argument in American Electric Power, attorneys for some of the country’s largest power companies told the Court in no uncertain terms that EPA does have authority to regulate carbon dioxide under section 111(d):

“We believe that the EPA can consider, as it's undertaking to do, regulating existing nonmodified sources under section 111 of the Clean Air Act, and that's the process that's engaged in now… Obviously, at the close of that process there could be APA challenges on a variety of grounds, but we do believe that they have the authority to consider standards under section 111.”

Four years later, petitioners now claim that EPA is required to adopt their interpretation as a result of changes made to the text of section 111(d) as part of the 1990 Clean Air Act Amendments.

In 1990, in an effort to update a cross-reference to the hazardous air pollution program under section 112, the Senate and House each passed technical amendments making minor changes to the same language in section 111(d). Congress then enacted, and the President signed into law, both amendments to the statute.

Even petitioners do not contest that the language of the Senate Amendment clearly preserves EPA’s long-standing authority to regulate carbon pollution under section 111(d) (as well as other pollutants not regulated under sections 108 or 112). However, petitioners have seized on the House amendment, which amended section 111(d) to require that EPA regulate “any pollutant” which is not “emitted from a source category which is regulated under [section 112].” This language, they claim, prevents EPA from regulating carbon dioxide from existing power plants —because power plants are subject to emission standards for mercury, acid gases, and other HAPs under section 112.

This argument finds no support in the Act’s text, structure, or legislative history.

First, the petitioners’ theory would radically change the structure of the Clean Air Act in a way that Congress could never have intended. Under the Petitioners’ theory, section 111(d) would not apply to any pollutant, no matter how harmful, that is emitted by the dozens of industrial source types regulated under section 112 of the Clean Air Act. Significant categories of harmful pollution, not limited to carbon dioxide, would be placed beyond the scope of regulation under the Clean Air Act. In all of the extensive debate, committee reports, and other legislative history that led up to the enactment of the 1990 Clean Air Act amendments, there is not a shred of evidence that Congress intended to create loopholes in section 111(d) as the petitioners claim.

Second, the 1990 amendments include a provision stating that standards under section 112 must not be “interpreted, construed or applied to diminish or replace” more stringent requirements under section 111 – a strong indication that Congress intended for section 112 to work seamlessly with, not displace, section 111(d).

Third, the petitioners’ theory is completely at odds with the purpose of the 1990 Amendments, which strengthened the Act in numerous ways in order to ensure that harmful air pollution was being effectively addressed.

Petitioners also urge the court to disregard what Congress actually did by ignoring the Senate amendment, which even petitioners agree clearly preserves EPA’s authority to regulate carbon pollution under section 111(d). But the Senate amendment was passed by both houses of Congress and signed into law by the President. As the law of the land, the Senate Amendment cannot be cast aside.

Instead, the petitioners emphasize a strained interpretation of the House Amendment that is not only unreasonable on its face and inconsistent with the Supreme Court’s opinion in AEP, as described above, but is contrary to all of the actions taken by every administration in the twenty-five years since the 1990 amendments were enacted.

As documented in a compelling brief filed by NYU’s Institute for Policy Integrity, EPA has adopted the view that section 111(d) applies to any pollutant not regulated under section 112 or section 108 in multiple rulemakings since 1990 — not just in the Obama Administration, but also the George W. Bush Administration, the Clinton Administration, and the Administration of George H.W. Bush, who actually signed the 1990 amendments. This long record shows that the House amendment is most reasonably interpreted to preserve the historic “gap-filling” role of section 111(d).

It is regrettable that petitioners have resorted to premature litigation rather than allow the administrative process to run its course.

EPA undoubtedly possesses the authority to limit carbon pollution from existing power plants under section 111(d) of the Clean Air Act. That's good news for families and communities that are afflicted by mercury and carbon pollution from fossil fuel power plants — the nation's single largest source of both health-harming contaminants. Congress did not intend for our children to have to "pick their poisons," but instead created a seamless framework – which Republican and Democratic administrations alike have long carried out — to safeguard our children's health from all harmful air pollution.

Cecilia Segal, a legal intern at EDF, helped to prepare this post.

Posted in Clean Air Act, Clean Power Plan, EPA litgation, Greenhouse Gas Emissions, Policy| Comments closed

A Significant Milestone for Opening Up the Discussion About Geoengineering

Geoengineering is the deliberate large-scale manipulation of the Earth’s climate system to counteract the impact that pollutants are having on our climate. The proposals sound like the stuff of science fiction – spraying particles in the upper atmosphere to deflect some sunlight, for instance – and EDF’s experts have been following the topic with concern.

Most of the focus on climate change has been about transitioning our economy to clean, renewable energy – removing the cause of the malady. But some are worried that won’t happen fast enough and that a more radical intervention may be necessary. Indeed, a 2014 report from the International Panel on Climate Change indicated that the world may require some form of climate engineering in order to stay within a hoped for two-degree limit to global temperature rise. But these proposals raise a serious risk of unintended consequences.

Geoengineering is in the news because of the release of a new report from the National Academy of Sciences. It’s the first study commissioned by the U.S. government that explains our current understanding of the science, ethics, and governance issues presented by geoengineering technologies. I was a member of the panel that drafted the NAS report, and its release is also meaningful for me — and for my colleagues here at EDF — because of our involvement with the Solar Radiation Management Governance Initiative (SRMGI).

Specifically, NAS was asked to conduct a technical evaluation of a limited number of proposed geoengineering techniques, including albedo modification and carbon dioxide removal. The new report comments on the potential impacts of these technologies.

What is Albedo Modification?

Albedo modification (AM), also known as “solar radiation management,” describes a controversial set of theoretical proposals for cooling the Earth by reflecting a small amount of inbound solar energy back into space.

These techniques have attracted attention because they could — in theory — reduce global temperatures quickly and relatively cheaply. BUT – these techniques would have unknown adverse impacts.

The new NAS report makes clear that AM is not an alternative to deep reductions in carbon pollution.

AM does not address ocean acidification and other non-temperature-related climate change impacts. It can at most serve as a temporary tool to reduce temperatures while lowering the atmospheric burden of greenhouse gases.

AM technologies have potentially serious and uncertain environmental, political, and social risks. The distribution and balance of benefits and risks are currently unknown.

AM research will require governance mechanisms to ensure that if research is undertaken, it is done transparently, safely, and with international agreement.

Unlike the NAS report just released, EDF has not called for small-scale AM research. We are in favor of accelerated discussion and development of a governance framework that would cover any potential geoengineering research.  

Why should research governance involve a global conversation?

The scientific, ethical, political, and social implications of AM research could be global. That means discussions about AM research governance should be global as well. To date, however, most discussions on the governance of AM research have taken place in developed countries — even though people in developing countries are those most vulnerable, both to climate change and to any potential efforts to respond to it.

In recognition of that fact, the Royal Society, EDF and TWAS (The World Academy of Sciences) launched SRMGI in 2010. SRMGI is an international NGO-driven initiative to expand international discussions on AM, particularly to developing countries.

SRMGI promotes early and sustained dialogue among diverse stakeholders around the world, informed by the best available science, in order to increase the chances of any AM research, should it be undertaken, being managed responsibly, transparently, and cooperatively.

The new NAS report offers an important opportunity to expand that dialogue.

It’s critical that we aim for transnational cooperation and information exchange on climate engineering research governance. That’s because even low-risk climate engineering research presents controversy.

AM’s potentially cheap deployment and quick effect on global temperatures could lead to the rapid and unilateral development of AM research programs, which could engender international tension and conflict.

Furthermore, deployment of AM would not benefit all populations equally.

And, while discussions about geoengineering are necessary, they cannot be considered as a substitute for reducing carbon pollution. The billions of tons of carbon pollution we put into our atmosphere every year are causing dangerous changes to our climate, and we must rapidly and consistently reduce that pollution. No climate engineering technology we can conceive of could keep up with the impacts of rapidly accelerating emissions.

What Comes Next?

The new NAS report should spur the U.S. and other governments to take the governance challenges of research into AM technologies seriously. An important next step is to foster wider international dialogue, including developing countries, on how to responsibly manage AM research.

It’s a dialogue that we at SRMGI, and at EDF, welcome. And the new NAS report is a welcome contribution to this dialogue.

Posted in Geoengineering, Greenhouse Gas Emissions, News, Partners for Change, Science| Comments closed

Clearing the air: Why we need strong smog standards

Smog over Dallas Skyline. Source: WikiCommons

This week and next, the U.S. Environmental Protection Agency (EPA) is holding hearings across the country on the proposed updates to our national smog (ground-level ozone) standards from their current level of 75 parts per billion (ppb) to 65 to 70 ppb. Exacerbated by the combustion of fossil-fuel power plants and car exhaust, ground-level ozone is the single most widespread air pollutant in the United States and is linked to severe respiratory health outcomes. Ozone poses a great threat to public health across America.

What is the issue?

Smog is a dangerous air pollutant that is linked to premature deaths, asthma attacks, and other serious heart and lung diseases. It is estimated that more than 140 million people live in areas with unhealthy levels of smog pollution. The very air we breathe is putting us at risk for adverse health outcomes such as premature deaths, increased asthma attacks and other severe respiratory illnesses, as well as increased hospital visits.

Does the proposal go far enough?

While EDF supports EPA’s proposal to strengthen these critical health protections, we believe that going even further, to 60 ppb, would provide the strongest protections for Americans and would be in line with what leading medical associations like the American Lung Association recommend.

Can this be achieved?

America has decades of experience innovating and cost-effectively cleaning up the air – and we can do so again to reduce smog pollution. From the Tier 3 tailpipe standards to the proposed Clean Power Plan, which would set the first-ever national limits on carbon pollution from existing power plants, the air across the country is becoming cleaner, showing us that we can have healthy air and a strong economy.  In some American cities, we estimate that ozone is already declining each year thanks to important air regulations such as the Cross State Air Pollution Rule, but there is still work to do.

What can you do?

Voice your support for strong clean air standards! A strong smog standard will help ensure Americans know whether the air they are breathing is safe, and will drive much-needed pollution reductions. Our communities, our families, and our children are counting on EPA’s leadership in setting a strong ground-level ozone standard.

This post was adapted from an earlier post on EDF’s Texas Clean Air Matters blog

Posted in Cars and Pollution, Health, Policy| Comments closed

New study: America’s biggest carbon market delivers for economy and climate

Source: Flickr/Chris Goldberg

Would you believe there's a state that cut pollution and cleaned up its air, while creating jobs and sustaining economic growth?

And where economic incentives, rather than costly regulations, are stimulating innovation and investment?

California passed the earliest, most comprehensive law to set a cap on carbon pollution, along with numerous other complementary policies to help the state transition to a low-carbon, clean-energy economy.

The results are now coming in and the present – and future – looks bright.

Two years after it was fully implemented, California's cap-and-trade program is thriving, a new report [PDF] from Environmental Defense Fund shows.

The program is now ramping up as the state economy is growing, paving the way for California to pass even stronger climate policies. Perhaps most important, it's laying the groundwork for other states and nations to move forward with similar steps.

The four top findings from our report:

1. California’s cap is driving down greenhouse gas pollution while allowing the economy to grow. 

The state has been able to grow its economy significantly while keeping greenhouse gas pollution from rising, too.

Emissions capped under the program decreased by almost 4 percent during the first year of the program. What’s more, California’s ambitious climate change and clean energy policies have created a thriving economy that is growing faster than the overall national economy and attracting considerable amounts of investment.

Since 2006, California has received more clean-tech venture capital investment than all other states combined and leads the rest of the nation in clean-tech patent registration.

2. California has built a robust carbon market that is getting progressively stronger.

Companies can purchase allowances through quarterly auctions or on the secondary market. The results of nine successful auctions to date reflect a healthy level of interest for carbon allowances and confidence among companies in the long-term health of the program.

In addition, California successfully linked its program with Quebec’s over the past year, proving that motivated governments can work effectively together and do more in partnership than they can alone.

This outcome may inspire similar linkages around the world.

3. Companies are taking the program seriously.

Every single company regulated by California’s carbon cap acquired enough allowances to meet their first compliance deadline.

This proves, in a strong way, that companies are incorporating the price on carbon into their business models and actively planning how they will comply with the regulation.

4. Success begets confidence and commitment in climate policies.

During the 2013-2014 California legislative session, several bills designed to strengthen the cap-and-trade program passed, while measures that would have harmed or derailed the program all failed to move forward.

Gov. Jerry Brown and other state government leaders have called for more ambitious goals to be set beyond the current 2020 goal.

California’s success creates momentum for national and global climate action, offering lessons and insights to other states and nations all over the world that are weighing similar actions to help avert the worst effects of climate change.

In fact, cities, states, and regions are at the front lines of developing effective solutions chart the path for climate progress on a much bigger scale.

Cap-and-trade is not the only answer to climate change.

But the results from California’s program show that with a long-term vision and strong leadership – along with effective collaboration between government, businesses and communities, stakeholders –  it’s one of the strongest answers we’ve got.

This post originally appeared on EDF Voices.

Posted in Greenhouse Gas Emissions, Policy| Comments closed

Court Hears Arguments on Fuel Efficiency and Greenhouse Gas Standards for Big Freight Trucks

The U.S. Court of Appeals in Washington D.C. heard oral arguments today in challenges seeking to overturn historic, first-generation standards to improve fuel efficiency and reduce greenhouse gas emissions from large trucks and buses.

The standards were finalized by the U.S. Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) in 2011.

The standards apply to vehicles manufactured between 2014 and 2018. They are based on commonsense, highly cost-effective technologies that will make our nation’s fleet of large trucks and buses more efficient — reducing harmful climate-destabilizing pollution, limiting our dependence on foreign oil, and saving money for both truckers (in the form of lower fuel costs) and consumers (in the form of lower shipping costs).

EPA estimates that, over the lifetime of vehicles sold between 2014 and 2018, the standards will:

  • Reduce climate pollution by more than 270 million metric tons of carbon dioxide equivalent
  • Reduce oil consumption by more than 530 million barrels
  • Result in net savings of up to $73,000 in avoided fuel costs over the lifetime of a new long-haul truck.

These cross-cutting benefits engendered broad-based support for the standards, including support from our nation’s truck and engine manufacturers, from states, and from public health and environmental groups.

In response to the President’s announcement of these first generation standards in 2010, many of these organizations sent letters of support. Here are just a few examples:

Cummins Inc. recognizes the benefits for the country of a National Program to address greenhouse gases (OHOs) and fuel efficiency from medium and heavy-duty trucks and buses. Cummins fully supports the adoption of such a National Program and welcomes this opportunity to be a partner in helping to advance that goal.

[Daimler] is committed to working with EPA and NHTSA, the states, and other interested parties to help address three of the most pressing issues facing the U.S. today and into the future: greenhouse gas reductions, fuel efficiency improvements, and increased energy security.

As 2015 begins, these clean air measures are now in their second year of effectiveness, and they are driving technological innovations that are cleaning the air and helping American truck manufacturers to thrive.

Through October of 2014, sales of fuel efficient trucks were 20 percent higher than their 2013 levels. 2015 is projected to be even stronger, with forecasts suggesting it will be the third strongest year ever for truck sales.

Martin Daum, president and CEO of Daimler Trucks North America, put it succinctly:

[T]hese standards “are very good examples of regulations that work well.”

None of these truck and engine manufacturers were in court today challenging the first generation truck standards, which are based on rigorous technical information and firmly grounded in the law. The standards are a testament to the fact that collaboration among truck manufacturers, states, and other interested parties can reduce pollution, enhance our nation’s energy security, and save truckers and consumers money.

That is very good news, because President Obama recently announced that EPA and NHTSA will issue second-generation greenhouse gas and fuel efficiency standards for large trucks.

Many of the same companies that stood with the President in announcing a blueprint to develop the second phase standards also collaborated on the first generation clean trucks standards. Among those supporting the President’s announcement of second phase standards included the nation’s major manufacturers and fleets such as Conway, Cummins, Eaton, Wabash National, Waste Management and the American Trucking Association.

When our nation stands together, we can forge big gains in strengthening our economy and protecting our environment.

Posted in Cars and Pollution, Economics, Greenhouse Gas Emissions, News, Partners for Change| Comments closed

The Clean Power Plan Wins Support from Millions of Americans, and a Broad Array of Diverse Groups

Americans rally for the Clean Power Plan

Americans rally for the Clean Power Plan

January is a time for New Year’s resolutions, hot chocolate and the tantalizing possibility of snow days.

For me, it’s also a time when I reflect on what the past year has meant for me, my family, and our world.

Right now, I’m focusing on climate change through these three interwoven lenses. Fortunately, this year I have a lot of significant and positive steps to reflect on.

Here’s the one I’m thinking about the most: the Clean Power Plan.

The Clean Power Plan will set the nation’s first-ever carbon pollution standards for power plants. It’s one of the biggest steps we’ve ever taken to address the pollution that harms our climate.

EDF strongly supports the Clean Power Plan, of course, but we’re certainly not alone.

These urgently needed standards have already won broad support from the faith community, moms, health and medical associations, businesses, power companies, Latino groups, states, and others – as well as from EDF and other environmental groups.

And more than three and a half million Americans sent comments in support of the Clean Power Plan to the Environmental Protection Agency (EPA).

Here are just a few quotes highlighting the Clean Power Plan’s support among diverse groups, and demonstrating the broad support about the need to protect our climate:

Climate change poses grave threats to public health. To protect our communities and the public, the United States must significantly reduce carbon pollution from the largest source, which are existing power plants. Our organizations support EPA’s overall approach with the Clean Power Plan, but urge EPA to strengthen the final plan to provide greater protection to public health.

  • Comment Letter from medical and public health associations: American Academy of Pediatrics, American Heart Association, American Lung Association, American Public Health Association, American Thoracic Society, Center for Climate Change and Health, Health Care Climate Council, Health Care Without Harm, Public Health Institute, and Trust for America’s Health

We applaud EPA for proposing a rule that will place the United States on a path to achieving meaningful reductions in carbon pollution, although we recognize that greater overall reductions will be necessary to meet the challenge of climate change. Our states are already demonstrating that significant, cost-effective reductions can be achieved from the power sector through the “system” EPA identifies as the basis for its proposed emission guideline. We therefore support EPA’s general approach to setting the emission guideline.

  • Joint Comments of state environmental agency leaders, energy agency leaders, public utilities commissioners from 14 states: California, Connecticut, Delaware, Illinois, Massachusetts, Maryland, Maine, Minnesota, New York, New Hampshire, Oregon, Rhode Island, Vermont, and Washington

We support the proposed rule’s overall objective of achieving meaningful emission reductions from existing power plants and encouraging investment in a clean energy future, and these technical comments are offered for the purpose of constructively supporting that objective. We agree with EPA that meaningful emission reductions can be achieved from the electric sector while maintaining electric system reliability.

 We strongly support EPA in moving forward with the proposed Clean Power Plan in the strongest form possible. We know that communities of color and low-income communities, including the Latino community, are frequently among those most negatively impacted by carbon pollution. Whether it is exposure to health damaging copollutants associated with carbon emissions or the present and worsening effects of climate change, these impacts are both direct and indirect and they threaten the social and economic order of overexposed and overburdened communities.

As businesses concerned about the immediate and long-term implications of climate change, we, the undersigned, strongly support the principles behind the draft Carbon Pollution Standard for existing power plants. The Environmental Protection Agency’s (EPA) proposed Carbon Pollution Standard for existing power plants represents a critical step in moving our country towards a clean energy economy…Our support is firmly grounded in economic reality. We know that tackling climate change is one of America’s greatest economic opportunities of the 21st century and we applaud the EPA for taking steps to help the country seize that opportunity.

  • Letter signed by 223 companies, BICEP, CERES, CDP, and The Climate Group. Companies signing the letter include Unilever, Kellogg Company, Solar City, and SunPower

EPA's efforts to limit dangerous carbon pollution from power plants will protect public health, fight climate change, and help our economy by sparking innovation in clean energy technologies. Our communities, our families and our children are counting on your leadership. Please enact strong limits on carbon pollution from America's existing power plants.

And, while delivering more than 10,000 comments in support of the Clean Power Plan, The Reverend Sally Bingham, founder and president of Interfaith Power and Light said:

[W]e urge the EPA to move forward with the proposed standards for existing power plants so that we can reduce carbon pollution as quickly as possible to address climate change, protect human health, and care for all of Creation.

It has been a great privilege to work on the Clean Power Plan at EDF during the past year. That’s one of the things I’m reflecting on personally.

It’s true that climate change is an immense issue with far-reaching impacts. But the immensity of the challenge has united an extraordinary number of Americans, and moved a wide range of diverse groups to take action — and that is something we can all celebrate this New Year.

Posted in Clean Air Act, Clean Power Plan, Partners for Change, Policy| Comments closed
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