Climate 411

The case against the Trump administration’s rollback of the Clean Power Plan

The Environmental Protection Agency will file a legal brief today defending its decision to dismantle the Clean Power Plan and replace it with the harmful and cynically misnamed Affordable Clean Energy (ACE) rule.

But nothing EPA says can alter the fact that ACE is destructive, costly, and unlawful. EPA projects that ACE will reduce power sector emissions by a mere 0.7 percent by 2030, and will increase pollution at nearly one in five of the nation’s coal plants, two-thirds of which are located in minority and low-income communities.

In the face of a growing and ever-perilous climate crisis calling for meaningful action, we expect EPA will claim the Clean Air Act does not permit the agency to do more to reduce emissions from the nation’s largest industrial source of carbon pollution. This claim severely distorts the statutory requirements.

EDF filed suit last summer as part of a broad coalition of states, cities, other health and environmental advocates, power companies, and clean energy trade associations. In April, the coalition filed legal briefs showing that EPA has ample authority — and a clear obligation — under the Clean Air Act to require meaningful reduction of carbon pollution from power plants. These briefs collectively demonstrate that EPA’s repeal of the Clean Power Plan is based on a gross misreading of the Clean Air Act, and the agency’s replacement rule, premised on the same misreading, fails to live up to the statutory command that power plants use the “best system of emission reduction” to limit their carbon pollution.

Here are the key arguments we’ve made against the Clean Power Plan rollback and ACE.

Read More »

Posted in Clean Air Act, Clean Power Plan, EPA litgation, Greenhouse Gas Emissions, News, Partners for Change, Policy / Comments are closed

The pollution-enabling impacts of the Clean Power Plan “replacement”

EPA Administrator Andrew Wheeler has suggested that ACE – the Trump administration’s harmful and deeply flawed replacement for the Clean Power Plan – is just as effective in protecting climate and public health as its predecessor.

Wheeler is wrong.

ACE will achieve virtually no reductions in carbon pollution from power plants and will increase health-harming pollution in many communities across the country. This harmful rule represents a huge step backwards at a time when communities across the nation are increasingly suffering devastating impacts from climate change – such as wildfires, extreme weather, coastal flooding, and intense heat waves – that underscore the need for rapid reductions in carbon pollution.

Following the finalization of the ACE rule in June, Wheeler said that when the rule is fully implemented, “we expect to see U.S. power sector CO2 emissions fall by as much as 35 percent below 2005 levels.”

What that claim fails to acknowledge is – that based on EPA’s own analysis – these reductions are projected to occur whether or not there is a federal policy in place. In other words, the ACE rule will accomplish no significant carbon pollution reductions beyond business-as-usual. By claiming credit for reductions that would happen anyway, Wheeler is simply masking the inefficacy of the rule.

The Clean Power Plan was the first-ever policy to set national limits on harmful carbon pollution from existing power plants. The ACE rule, in contrast, contains no binding limits on carbon pollution. Instead, the rule merely provides a list of “heat rate improvement measures” that would incrementally improve the operating efficiency of coal plants, leaving it up to the states to decide which – if any – of those measures to apply.

When the Clean Power Plan was finalized in 2015, EPA projected that power sector carbon pollution would be 17 percent below 2005 levels in 2030 under business-as-usual with no federal policy. Due to the plummeting costs of clean energy technologies and the ongoing market shift towards cleaner electricity sources, EPA now projects that power sector carbon pollution under business-as-usual with no federal policy will be much lower, at 35 percent below 2005 levels in 2030. According to EPA, the ACE rule is projected to achieve a trivial 0.7 percent reduction in carbon pollution compared to business-as-usual in 2030.

Worse still, EPA’s own numbers show that the rule would have the perverse impact of incentivizing some coal-fired power plants to operate and pollute more – leading to more carbon pollution in many states compared to no policy at all.

Experts have warned that under the ACE rule, many parts of the country would also see increases in the health-harming pollution that leads to soot and smog. While the Trump administration has tried to downplay the public health consequences of the rule, EPA’s projections show that vulnerable communities around the nation will likely suffer the most from these dangerous pollution increases.

In addition to disregarding the health and well-being of Americans, the years-long effort by the Trump administration to dismantle the Clean Power Plan represents a squandered opportunity to cost-effectively achieve urgently needed reductions in pollution. EDF filed comments on the proposed rule that demonstrate that fact. Our updated analysis using the same power sector model that EPA relies upon shows that carbon pollution reductions of more than 50 percent below 2005 levels in 2030 are possible at similar costs to what the original Clean Power Plan envisioned. The U.S. Energy Information Administration has also found that even greater reductions of 68 percent below 2005 levels can be achieved by 2030 – along with steep reductions in dangerous soot and smog-forming pollution – at modest cost.

Not only are significant reductions in carbon pollution from the power sector possible, they are also long overdue. We are already facing serious consequences from carbon pollution. The latest reports from the Intergovernmental Panel on Climate Change make it frighteningly clear that the country and the world are facing unprecedented threats from climate change – and that rapid reductions in climate-destabilizing pollution are needed by 2030 in order to avoid the worst impacts. The devastation from climate change-fueled disasters across the U.S. and the millions of Americans suffering from the health impacts of air pollution underscore the pressing need for reductions in pollution from the power sector, one of the nation’s leading contributors to carbon pollution.

We need real protections against the dangerous carbon pollution that threatens both our environment and our health – not spin from Administrator Wheeler that hides the real impacts of his pollution-enabling rule behind misleading statistics.

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

Wheeler’s Clean Power Plan rollback misses a huge opportunity for cost-effective pollution reduction

Co-authored by Laura Supple and Rama Zakaria

The Trump administration is expected to soon finalize a rule that will throw out the Clean Power Plan – the first and only nation-wide limit on carbon pollution from existing power plants – and replace it with a “do-nothing” rule. Unlike the common-sense, market-based approach of the Clean Power Plan, the final rule is expected to mirror Wheeler’s proposed replacement–which contains no binding limits on carbon pollution, leaving it to the states to establish standards based on only a narrow and ineffective menu of operational efficiency tweaks for coal-fired power plants.

EPA’s own analysis has shown that this proposed replacement would increase climate pollution and dangerous soot and smog pollution, causing thousands of additional deaths and childhood asthma attacks every year compared to the Clean Power Plan, and may even increase pollution in several states compared to having no policy at all. In addition to disregarding the health and wellbeing of Americans, the proposed rule represents a tragic lost opportunity to achieve the deep, cost-effective reductions in pollution that are needed to address the urgent threat of climate change – and move the U.S. forward into a clean energy economy.

Here are four reasons why:

Power companies are making bold commitments to cut pollution, investing in cleaner technologies that deliver high-quality power at low cost to consumers

Power companies are setting ambitious goals to reduce pollution and increase the share of renewable technologies in their energy mix. Some of the largest power providers in the country have recognized the long-term economic value of renewable power and cleaner energy, setting their own targets to reduce pollution well below what the Clean Power Plan requires.

Xcel Energy, a utility serving 3.6 million customers across 8 Midwestern states, has already reduced carbon pollution by about 38% below 2005 levels while keeping costs low for its consumers. According to Xcel, its residential customer electric bill has decreased 3% in the past five years and is on average $28 lower per month than the national average. Xcel also recently ramped up its own ambitions, committing to cut carbon pollution 80% below 2005 levels by 2030, and achieve 100% clean power by 2050.

Other companies are also joining the trend towards decarbonizing their electricity mix, including Idaho Power, which has committed to 100% carbon-free electricity by 2045, and Platte River Power Authority, which aims to provide 100% renewable energy by 2030.

States and cities across the country are also setting bold targets to reduce pollution and expand the use of renewable energy. Seven states, 11 counties, and 125 U.S. cities have committed to 100% renewable energy, and at least 27 states have long-term policies establishing quantitative energy savings targets. These initiatives are making energy supplies more robust, reliable, and affordable, demonstrating that ambitious pollution reduction strategies can be good for the environment, good for business, and good for consumers.

Power sector trends have made deeper reductions achievable and cost-effective

Thanks in part to the ongoing market shift towards a cleaner electricity resource mix, the power sector is decarbonizing faster than was predicted just a few years ago.

In 2015, when the Clean Power Plan was finalized, the Energy Information Administration (EIA) projected baseline power sector carbon dioxide pollution would drop 10% from 2005 levels by 2030. Based on recent trends and technological developments, however, EIA’s most recent projections estimate that power sector carbon pollution would be at 34% below 2005 levels by 2030 – surpassing Clean Power Plan targets – even without federal climate regulation.

To be clear, we need the long-term regulatory signal established by meaningful federal regulation to ensure these trends continue and secure pollution reductions. Now more than ever, it is imperative that EPA use this momentum to set even greater climate protection targets in order to achieve the rapid reductions in carbon pollution that scientists say are necessary to avoid the worst impacts of climate change.

Plummeting costs of clean energy technologies are making pollution reduction more affordable and economical than ever

Targets for the Clean Power Plan relied on the National Renewable Energy Laboratory’s (NREL) 2015 Annual Technology Baseline projections of renewable energy costs. In its latest 2018 report, NREL predicted that the costs of onshore wind in 2030 would be 28% lower than 2015 projections, and utility-scale solar PV costs could be up to 68% lower.

These projections match trends we see on the ground. Recent filings from Xcel Energy to the Colorado Public Utilities Commission include proposals for wind power between $11 to $18/MWh – cheaper than the operating cost of all existing coal plants in Colorado – and solar-plus-storage bids not much higher than standalone solar. Last year, NV Energy reported even lower bids, setting record-low prices in its solar and solar-plus-storage request for proposals.

Overall, electricity from renewables is already cheaper than electricity from fossil fuels in many parts of the country. PacifiCorp, a majority-coal power provider, recently found it could save money by retiring 60% of its coal fleet by 2022 and replacing those units with renewables. In a 2019 analysis, Energy Innovation reported that the U.S. has officially entered the “coal cost crossover,” finding that local (within 35 miles) wind and solar generation could replace 74% of U.S. coal plants at an immediate cost savings to customers. By 2025, 86% of coal power plants could be replaced with local renewable generation.

Recent modeling shows far more ambitious and cost-effective pollution reductions can be achieved

Several studies demonstrate just how ambitious climate targets could be – with the right set of regulatory and market-based strategies. A range of analyses show that far greater reductions in carbon pollution can be achieved at low cost.

In 2015, EPA estimated the cost of achieving the Clean Power Plan targets to be in the range of $24 to $37 per ton of carbon over the 2022 to 2030 compliance period. Recent updated analysis using the same power sector model, however, found that much more ambitious carbon pollution reductions of more than 50% below 2005 levels are possible at similar costs to the Clean Power Plan.

EIA also found that even greater reductions of 68% below 2005 levels could be achieved by 2030 at modest cost. A 2016 study by the Union of Concerned Scientists showed that in a “Mid-Cost Case”, power sector carbon pollution limits of 76% below 2005 levels by 2030 could be cost-effectively achieved. Modeling by Columbia University Center and Rhodium Group also suggest that similar strategies could cut power sector carbon pollution by 72 to 76% below 2005 levels by 2030.

At a time when the threats of climate change have never been more apparent, EPA must move forward on climate action with emission reduction targets that surpass the ambition of the Clean Power Plan and protect human health and the environment from dangerous pollution. Instead, Wheeler’s proposed replacement misses a tremendous opportunity to secure deep reductions in carbon pollution and propel the U.S. into a clean energy future.

Posted in Clean Power Plan, Economics, Energy, Health, News / Comments are closed

Four reasons why Wheeler’s Clean Power Plan “replacement” will lead to more pollution

EPA Administrator Andrew Wheeler has sent a draft rule that would roll back the Clean Power Plan to the White House for review – a step that suggests the rule is close to being finalized and released.

If this final rule looks anything like the hopelessly flawed and inadequate proposal that was released last August, it will scrap the Clean Power Plan – our nation’s only national limit on carbon pollution from the power sector – in favor of a “do-nothing” program that could actually increase pollution from inefficient, highly-polluting coal-fired power plants.

Even as the nation reels from wildfires, flooding, and hurricanes exacerbated by climate change, Wheeler’s proposal would place no meaningful limits on one of our nation’s largest contributors to climate-destabilizing pollution.

If our experience with the proposal is any guide, we can also expect the release of the final rule to be accompanied by a bevy of misleading assertions that Wheeler’s “replacement” for the Clean Power Plan is just as effective in protecting climate and public health.

Wheeler has already been making such claims. For instance, in testimony before the House of Representatives last month, Wheeler said that EPA’s proposed replacement for the Clean Power Plan would reduce carbon pollution from the power sector by 34 percent once fully implemented, and would go a long way towards meeting our carbon reduction goals for the country. These comments build on Wheeler’s claims during his Senate confirmation process that equated his replacement to the Clean Power Plan.

Here are four reasons why his claims are false: Read More »

Posted in Clean Air Act, Clean Power Plan, EPA litgation, Greenhouse Gas Emissions, Health, News, Policy / Comments are closed

Clean Power Plan “Replacement” Will Increase Carbon Pollution in Many States – New Study

A new study is now confirming what our earlier analysis found – the Trump Administration’s proposed replacement for the Clean Power Plan would actually be worse than doing nothing in many states.

The Clean Power Plan sets America’s only nationwide limits on carbon pollution from power plants. Trump’s Environmental Protection Agency has formally released a cynical proposal to scrap the plan and “replace” it with a do-nothing framework that sets no binding limits on carbon pollution at all. The agency recently finished taking public comments on that dangerous proposal – appropriately enough, on Halloween.

EDF undertook an analysis last year that concluded the Trump administration’s sham proposal would be a step down from doing nothing in many states. Now the new study by researchers at Resources for the Future and Harvard, Boston, and Syracuse Universities confirms that conclusion. Read More »

Posted in Clean Power Plan, Greenhouse Gas Emissions, News, Policy / Comments are closed

The Trump administration’s Clean Power Plan replacement – for many states, worse than doing nothing

The Trump Administration’s proposed “replacement” for the Clean Power Plan would not only increase dangerous climate pollution and cost American lives – it would actually be worse than doing nothing at all in many states.

The proposal would severely weaken our nation’s only limits on carbon pollution from existing power plants. It would increase climate and health-harming pollution from those plants, and would lead to more premature deaths compared to leaving the Clean Power Plan in place.

But that’s not all – EPA’s own numbers show that the proposal would also increase pollution in many states compared to a world without the Clean Power Plan.

In many states, this proposal would leave communities worse off than if the Environmental Protection Agency (EPA) had done nothing at all.

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Posted in Clean Air Act, Clean Power Plan, Greenhouse Gas Emissions, Health, News, Policy, Setting the Facts Straight / Comments are closed