Climate 411

Proof that the Clean Power Plan’s strategy for cutting carbon pollution is the industry standard

The public comment period is just about to close on EPA Administrator Scott Pruitt’s reckless attempt to repeal the Clean Power Plan, and thousands of Americans — including mayors, CEOs, energy experts, and citizens concerned about the threats Pruitt’s actions pose to our children’s health and future — have already spoken out in vigorous opposition to the misguided repeal effort.

There is a lot at stake. The Clean Power Plan would prevent 4,500 early deaths and 90,000 childhood asthma attacks each year. It would cut carbon pollution by 32 percent from 2005 levels, and would substantially reduce other harmful air pollutants from power plants.

By slashing air pollution and helping mitigate the threats of climate change, the Clean Power Plan would secure significant benefits to public health while growing the clean energy economy.

Yet, as Pruitt continues his misguided effort to turn back the clock on lifesaving climate protections, momentum is growing in states and the power sector to slash carbon pollution and usher in a clean energy future.

States and companies are moving away from carbon-intensive sources of electricity generation, and are increasing their use of cleaner technologies — deploying the same cost-effective strategies to cut carbon pollution that EPA relied upon when establishing emission reduction targets under the Clean Power Plan. Pruitt’s attempt to repeal the Clean Power Plan is putting this flexible approach to ambitious and low-cost emission reductions under attack.

Meaningful federal actions to reduce carbon pollution, such as the Clean Power Plan, remain essential to mitigate climate change. But in the meantime, states and companies – by making continued progress toward emission reductions through time-tested methods – are providing solid evidence that the Clean Power Plan’s approach is not only reasonable, but is the industry-standard for reducing carbon pollution from the power sector. 

The clean energy transformation is accelerating

Carbon pollution from the power sector fell to 27 percent below 2005 levels in 2017, continuing a clear downward trend since the mid-2000’s even as the U.S. economy continues to grow. Carbon pollution levels from the power sector in the U.S. have now fallen below emissions from transportation, demonstrating remarkable progress in cleaning up our electric grid.

The rapid decarbonization of the U.S. power sector continues to be driven by a shift toward clean energy technologies. Renewable energy including solar, wind, and hydropower generated a record 18 percent of U.S. electricity in 2017, and new renewables comprised nearly half of utility-scale generating capacity installed in 2017. As more and more high-polluting coal plants become scheduled for retirement, power companies and regulators from Colorado to New Mexico to Wisconsin are increasingly replacing them directly with renewables.

A precipitous drop in costs has made the outlook for clean energy increasingly bullish in recent years. The cost of utility-scale solar power fell by more than 77 percent from 2010 to 2017. Worldwide, the cost of solar and onshore wind power declined by 18 percent in the last year alone.

As of 2017, the lifetime cost of unsubsidized wind and utility-scale solar is now below that of coal and on par with the cost of natural gas combined cycle technology.

Low-cost projections for clean energy are increasingly becoming a reality on the ground. In Colorado, for example, a recent solicitation for new renewables resulted in bid prices for wind and solar plus energy storage that are cheaper than the operating cost of nearly all coal plants in the state.

States and power companies continue to lead

Across the country, state governors and major power companies have continued to ramp up forward-looking commitments to cut carbon pollution and deploy clean energy — recognizing these clear power sector trends and driving increasingly ambitious climate progress.

Here are some recent examples:

Power companies

  • American Electric Power, the nation’s largest generator of electricity from coal, laid out a strategy in February to reduce carbon pollution by 60 percent below 2000 levels by 2030, and 80 percent by 2050. “There is no question the electrification of our economy is accelerating,” said CEO Nick Akins. “Today, we are taking a longer-term view of carbon by setting new goals for carbon dioxide emission reductions for the future based upon resource plans that account for economics, customer preferences, reliability and regulation.”
  • Southern Company, the nation’s third largest power producer, announced a goal this month to reduce carbon pollution by 50 percent below 2007 levels by 2030 and to achieve “low- to no-carbon operations by 2050.” The commitment comes in the wake of a rapidly changing generation mix for Southern, with its share of generation from coal declining to 28 percent in 2017 from 70 percent in 2010.
  • In March, Oregon’s Portland General Electric committed to reducing carbon pollution by more than 80 percent by 2050, in part by achieving Oregon’s target of 50 percent renewable energy by 2040 and transitioning away from coal by 2035.
  • PacifiCorp subsidiary Rocky Mountain Power plans to add more than 1,300 megawatts of wind power by 2020 — a $1.5 billion investment.

Across the Midwest, a slate of electric utilities recently committed to slash carbon emissions and transition away from coal:

  • PPL Corporation plans to reduce emissions by 2050 to 70 percent below 2010 levels, including retiring the bulk of the company’s coal plants in Kentucky.
  • Wisconsin’s largest utility, WEC Energy Group, plans to reduce carbon pollution by 40% below 2005 levels by 2030.
  • In Indiana, Vectren announced plans to reduce carbon pollution by 60 percent by shuttering three coal-fired power plants.
  • Ameren Missouri committed to reducing emissions to 80 percent below 2005 levels by 2050, and plans to invest $1 billion to add at least 700 megawatts of wind power by 2020.
  • In February 2018, Michigan utility Consumers Energy announced plans to reduce emissions by 80 percent and phase out coal by 2040.

States

  • This month, New Jersey lawmakers passed a sweeping clean energy bill that will put the state on a path to becoming a national clean energy leader. Governor Phil Murphy directed the state to begin negotiations to rejoin the Regional Greenhouse Gas Initiative (RGGI) – a multi-state program to reduce carbon pollution from the power sector. Governor Murphy also signed an order adding New Jersey to the U.S. Climate Alliance of states committed to upholding the Paris Agreement goals, and has outlined a goal of powering the state with 100 percent clean energy by mid-century.
  • In a show of bipartisan commitment to ambitious climate action, Maryland also joined the U.S. Climate Alliance this January, and participated in a multi-state process to strengthen RGGI.
  • Alaska Governor Bill Walker — an Independent — signed an order in October 2017 establishing an advisory team to propose actions, including “statutory and regulatory changes,” for the state to reduce carbon pollution and support the goals of the Paris Agreement.
  • Just last week, environmental and energy regulators from thirteen states — California, Colorado, Connecticut, Delaware, Massachusetts, Minnesota, New York, North Carolina, Oregon, Rhode Island, Vermont, Virginia, and Washington delivered a letter to Administrator Pruitt opposing repeal of the Clean Power Plan and highlighting important progress across states to reduce carbon pollution from the power sector. “Low natural gas prices, declining costs of renewable energy technologies, and low demand growth are all existing power sector trends that have allowed our states to reap positive economic benefits from reducing emissions. The CPP would amplify these trends and make emissions reductions easier and more cost-effective,” the states write in the letter.

Shared prosperity under a stable climate

As the impacts of climate change — from wildfires to hurricanescontinue to threaten vulnerable communities across the U.S. and around the world, concerted actions to cut climate pollution are more important than ever.

At the same time, efforts to transition to a clean energy economy are delivering myriad benefits — from millions of good-paying clean energy jobs, to critical public health protections, to more affordable and more reliable electricity.

The leadership demonstrated by a growing group of states and major power companies to advance climate progress is critical to securing the benefits of a stable climate and clean energy future for millions of Americans. With continued leadership, and a return to meaningful federal action, America will see a global clean energy transformation and secure shared prosperity for all.

Also posted in Clean Air Act, Clean Power Plan, Economics, EPA litgation, Greenhouse Gas Emissions, News, Policy, Pruitt / Comments are closed

Still cheaper than coal – a report on the economics of solar power in Colorado

Workers install solar panels on a building in Superior, Colorado. Photo: SolarDave.com

(EDF’s Graham McCahan co-authored this post)

A newly-updated report is shedding light on what President Trump’s solar trade tariffs may mean for one state – and underscoring a tremendous opportunity to move forward toward clean energy, with all the benefits it can bring.

Xcel Energy filed its 30-day bid report update with the Colorado Public Utilities Commission on March 1. The update follows Xcel’s filing at the end of last year, in response to an “all-source solicitation,” as part of its Electric Resource Plan and its proposed Colorado Energy Plan.

Xcel’s plan would shut down two units at the Comanche coal plant in Pueblo, Colorado, and replace the capacity with a mix of lower carbon resources. Earlier results were unprecedented, with more than 80 percent of the bids coming from renewable energy and storage at incredibly cheap prices.

Xcel then provided bidders an opportunity to refresh their bids following President Trump’s final decision in the Suniva/SolarWorld trade case in January, which imposed tariffs on imported solar equipment.

The refreshed bids in Xcel’s updated report show minimal change relative to last year’s results and confirm that new wind and solar power in Colorado continues to be cheaper than existing coal plants – despite the trade tariffs.

According to the report, Xcel “received bid affirmation and refresh responses from all but one of the 400 plus bids.”

Of these responses:

“58% of the bids affirmed no change in pricing, 16% increased pricing, and 26% decreased pricing.”

The solar photovoltaic (PV) median bid price increased by only $1.5 per megawatt hour, and the median bid for solar PV with battery storage increased by $2.3 per megawatt hour – still the cheapest solar plus storage bids in the U.S. to date.

Based on analysis by Carbon Tracker, this means that the median bid price for solar is lower than the operating cost of all existing coal units in Colorado, while the median solar plus storage bid is lower than roughly 70 percent of operating coal capacity.

Federal renewable energy tax credits are likely buffering some of the solar trade tariff effects. While recent analyses show significant cost declines for renewable energy, with wind and solar becoming increasingly competitive with conventional generation even on an unsubsidized basis, the renewable tax credits are still a significant factor contributing to favorable wind and solar economics in the short-term and in the face of the Trump solar tariffs. That said, it’s important to recognize that coal generation has enjoyed state and federal incentives for a century, and continues to do so.

The tax credits are being phased down in the next few years, with the production tax credit for wind phasing out in 2019 and the investment tax credit for solar in 2021. So it will be critical to act now to take advantage of those credits to deploy clean energy at lowest cost and secure the associated economic and public health benefits.

Colorado is an example of this tremendous opportunity to move forward now to lock in incredibly low-cost resources, with no fuel costs and therefore no medium- to long-term volatility or risk to consumers. The Xcel bids show that there is a lower-cost clean energy alternative to keeping the polluting Comanche units online in Pueblo, and it no longer makes sense to continue to operate and maintain these units at the expense of Colorado customers and Colorado air quality.

There is even the potential for low-cost utility-scale on-site solar to be used by Evraz Rocky Mountain Steel – a steel mill and the single largest manufacturer in Pueblo and largest producer of premium rail in North America – to help cut costs and keep manufacturing jobs in Pueblo.

Evraz is Xcel’s largest retail customer in Colorado, and the 175-200 megawatt Evraz solar project that the company is considering would provide a cost-effective option to meet Evraz’s growing needs, help guarantee Evraz low and stable electricity rates in the future, and therefore help keep Evraz in Colorado.

We are already witnessing some of the impacts of Trump’s solar tariffs on jobs in some areas of the U.S., and the potential for these tariffs to stall American competitiveness and innovation – for instance, American solar company SunPower recently announced that it will lay off hundreds of workers, largely from its research and development and marketing positions.

But the Xcel refresh bids in Colorado – a state blessed with high solar and wind potential – provides an important first look at what the solar tariffs mean for the competitiveness of clean energy in a state where clean energy conditions are favorable.

In Colorado, it is clear that the advantages of clean energy for consumers and the local economy remain compelling. Despite the tariffs – and in the presence of renewable tax credits, rapid technological advances, and plummeting costs of solar and storage technologies – solar still outcompetes fossil fuels. It also helps lower costs to consumers, and protects local manufacturing jobs.

The state should act now to lock in those benefits for the people of Colorado.

Also posted in Economics, Policy / Comments are closed

The Winter Olympics on hostile terrain: How climate change is harming winter sports

The 2018 Winter Olympics have drawn to a close, and four years will pass before the world’s next opportunity to celebrate the Winter Games.

During that time, emerging athletes and innovations in training methods will inevitably change the face of the sports. But another more malevolent force of change is brewing – one that has begun to shift the landscape of the Games into hostile terrain.

As climate change continues to progress, adverse weather conditions threaten our beloved winter sports as we know them.

Familiar locations no longer suitable for outdoor sports

Researchers from the University of Waterloo recently determined that shifting weather conditions due to human-induced climate change will render 13 of the previous 19 hosts of the Winter Olympics too warm for outdoor sports by the end of the century.

Even recent host cities have faced new challenges in our changing climate. The 2014 Winter Olympics in Sochi, Russia, for example, experienced peak temperatures of 61 degrees Fahrenheit, inducing poor snow conditions that led to various delays and injuries throughout the weeks of competition.

Winter sport athletes have also begun to find their trusted off-season training locations unrecognizable. Glaciers that once provided ideal conditions for outdoor summer training have been slashed by trails of melt water and are rapidly disintegrating. U.S. athletes who previously looked to the Rocky Mountains to support their off-season practice must now travel across the globe to regions such as Switzerland, further exacerbating global warming as increased international travel pumps greenhouse gases into our atmosphere.

Accessibility diminishes for potential athletes

In the years of practice before an athlete may secure sponsorships or funding from national Olympic Committees, training and associated travel costs must be self-supported. The necessity of cross-continental travel thus not only makes tangible the effects of our changing climate, but confines potential talent pools from which Olympic athletes may emerge to socioeconomic groups able to financially support international travel.

The U.S. National Hockey League (NHL) has voiced similar concerns about athletes’ future training access. While the development of indoor rinks has allowed hockey to be played globally, the sport has traditionally relied on backyard rinks and ponds to provide players with their first introduction to skating. These more accessible venues are becoming progressively more limited as global temperatures continue to rise.

Informal backyard matches are not the only events threatened by climate change, as historic outdoor hockey events including the NHL Winter Classic, Heritage Classic, and Stadium Series may also be lost to warming conditions.

Widespread economic implications

We can shift these winter sports indoors or to higher latitudes in order to extend their lifetimes, but what happens to the regions left behind?

In the U.S. alone, snow-based recreation generates $67 billion per year and supports over 900,000 jobs. In a single year with poor snow conditions, more than $1 billion in revenue and 17,350 jobs can be lost.

Such threats are not looming in the distant future – changes are already taking shape.

As precipitation begins to fall as rain rather than snow throughout winter months, U.S. ski resorts are forced to spend more than 50 percent of their annual energy budgets on artificial snowmaking.

Canada’s average 4.5 degree Fahrenheit temperature rise between 1951 and 2005 has been matched with a 20 percent decrease in the country’s outdoor hockey season.

Future impacts are only expected to worsen, with the U.S. ski season projected to be cut in half by 2050.

Athletics are recognizing the impacts of climate change

Many competitors and athletic associations have already acknowledged the undeniable role of climate change in threatening the livelihood of these winter sports:

  • The National Ski Areas Association adopted their Climate Challenge program, aiming to help reduce greenhouse gas emissions and costs of energy use for participating ski areas.
  • Preceding the 2014 Winter Games, 75 Olympic medalists in skiing and snowboarding wrote a letter to then-President Barack Obama calling for a firmer stance on climate change mitigation and clean energy development.
  • The NHL used their 2014 sustainability reportto voice their “vested interest” in climate change, historically participating in the Paris Agreement conference discussions a year later.
  • A group of athletes and companies has come together to create a group called Protect Our Winters to educate and advocate for policies that mitigate the effects of climate change.

The threat of human-induced climate change recognized by these leaders applies to more than just winter events. Summer sports, such as golf and baseball, are also feeling the strain of our warming world.

In the spirit of the Olympic Games, we must unite as global citizens to join in our most important race – the race to defend the future of our planet.

Also posted in Basic Science of Global Warming, Extreme Weather, Greenhouse Gas Emissions, Science / Comments are closed

Key takeaways from the court decision blocking suspension of BLM’s Waste Prevention Rule

(EDF Legal Fellow Samantha Caravello co-authored this post)

A U.S. District Court judge has halted Interior Secretary Ryan Zinke’s latest effort to suspend the Bureau of Land Management’s (BLM) Waste Prevention Rule.

The judge issued a preliminary injunction last night in response to legal challenges brought by the states of California and New Mexico, and by EDF and a coalition of conservation and tribal citizen groups.

The court decision ensures that the Waste Prevention Protections are in full force and effect, delivering important benefits to tribes, ranchers and families across the West. It also demonstrates that facts matter, and that public input matters — and, as the court recognized, Zinke ignored both when he suspended the Waste Prevention Rule.

Here are some key takeaways from the court’s decision.

Zinke’s suspension would have resulted in immediate and irreparable harms

The Waste Prevention Rule requires that oil and gas companies take common sense actions to prevent the waste of valuable natural gas on federal and tribal lands. These actions also reduce harmful air pollution including methane, and smog-forming and toxic pollutants.

Judge William Orrick, of the U.S. District Court for the Northern District of California, found that Zinke’s attempt to suspend the Waste Prevention Rule would have real, immediate, and irreversible effects on public health and the environment.

In reaching this conclusion, the judge highlighted the severe health threat that Zinke’s suspension would pose for people living near oil and gas operations.

He cited:

“[T]he waste of publicly owned natural gas, increased air pollution and associated health impacts, and exacerbated climate impacts.” (Order, page 2)

The judge referred to declarations from EDF experts and members that documented these health and climate harms, including:

  • “Environmental Defense Fund member Francis Don Schreiber, for example, resides on a ranch in Governador, New Mexico, where there are 122 oil and gas wells either on or immediately adjacent to his land, all managed by BLM and subject to the Suspension Rule…. He notices an ‘extremely strong’ ‘near-constant smell from leaking wells,’ which ‘make[s] breathing uncomfortable’ and causes concern that he and his wife ‘are breathing harmful hydrocarbons…’ As Schreiber suffers from a heart condition and has already had open heart surgery, he is ‘at a higher risk from breathing ozone,’ and is ‘constantly concerned about the impact of the air quality on [his] heart condition.’” (Order, page 26)
  • “Dr. Ilissa B. Ocko, climate scientist, states that the 175,000 additional tons of methane that will result during the one-year suspension is ‘equivalent to the 20-year climate impact of over 3,000,000 passenger vehicles driving for one year or over 16 billion pounds of coal burned.’” (Order, page 25)
  • “Dr. Renee McVay, whose research focuses on atmospheric chemistry, estimates that approximately 6,182 wells subject to the Waste Prevention Rule are located in counties already suffering from unhealthy air with elevated ozone levels… The Suspension Rule will result in additional emissions of 2,089 tons of VOCs in these already at-risk communities, where many of the conservation and tribal group plaintiffs’ members reside, leading to and exacerbating impaired lung functioning, serious cardiovascular and pulmonary problems, and cancer and neurological damage.” (Order, page 25)

The court concluded:

“Plaintiffs list several environmental injuries with effects statewide, to the general public, and on the personal level, any of which might be sufficient to establish likely irreparable harm.” (Order, page 27)

Facts and analysis matter

In addition to these irreparable harms, the court found that EDF and our allies were likely to succeed on the merits:

“Plaintiffs have provided several reasons that the Suspension Rule is arbitrary and capricious, both for substantive reasons, as a result of the lack of a reasoned analysis, and procedural ones, due to the lack of meaningful notice and comment.” (Order, page 29)

Under the law, when a federal agency seeks to change a prior policy – as Zinke did when he sought to suspend the common sense requirements in the Waste Prevention Rule – that agency must provide “good reasons and detailed justification.” (Order, page 12)

The court found that Zinke fell short of these important requirements because he repeatedly “fail[ed] to point to any factual support underlying [his alleged] concern[s]” over the Waste Prevention Rule. (Order, page 14)

The court carefully evaluated each alleged justification for the suspension put forth by Zinke, and found them all lacking.

For example, the court noted that with respect to Zinke’s “concerns” regarding production wells:

“[C]ounsel for the government essentially conceded that it was in possession of no new facts or data underlying this ‘newfound’ concern.’” (Order, page 14)

Ultimately, the court found:

“[I]t appears that BLM is simply casually ignoring all of its previous findings and arbitrarily changing course.” (Order, page 17, internal quotation omitted)

The court’s careful analysis underscores that these facts matter, and that Zinke cannot ignore the substantial record evidence supporting the common sense standards in the Waste Prevention Rule.

Public input matters

The court also found that Zinke attempted to ignore key input from the public on the suspension of the Waste Prevention Rule by deeming comments on the importance and effectiveness of the Waste Prevention Rule “outside of the scope” of his action. (Order, page 23)

The court found Zinke’s “refus[al] to consider” this important input on “integral” issues was inconsistent with bedrock requirements of administrative law.

The fight to protect these safeguards is not over

The court has now determined that EDF and our allies are “likely to succeed on [our] claim that BLM failed to consider the scope of commentary that it should have in promulgating the Suspension Rule and relied on opinions untethered to evidence.” (Order, page 24)

Next, the case will proceed to the merits stage, in which the court will issue a final decision on the legality of Zinke’s suspension of the Waste Prevention Rule. A schedule has not yet been set for this next phase of the litigation.

However, just as the court was blocking his suspension, Zinke was separately trying to rescind nearly all of the key provisions of the Waste Prevention Rule that he was also trying to suspend.

Zinke acknowledges that this rescission will cost taxpayers millions in lost royalties, and will result in additional emissions of climate-warming methane as well as smog-forming volatile organic compounds and hazardous air pollutants – but he nonetheless is proposing to eliminate the protections in the Waste Prevention Rule.

BLM is accepting public comment on the rescission proposal until April 23. It is important that Zinke continue to hear from the public about the harmful impacts that will result from his actions to remove these common sense protection. Comments on the proposal can be filed here.

Also posted in Clean Air Act, Greenhouse Gas Emissions, Health, News, Policy / Read 1 Response

Underhanded maneuvers to repeal the Clean Power Plan put Americans’ lives and health at risk

(EDF’s Ben Levitan co-authored this post)

Environmental Protection Agency (EPA) Administrator Scott Pruitt says he will sign a proposal tomorrow to repeal the Clean Power Plan – America’s only nationwide limits on carbon pollution from fossil fuel power plants.

If the proposal matches what we’ve already seen in a leaked draft, it would be one of the most deeply harmful and reckless actions an EPA Administrator has ever taken. It would cost thousands of American lives, harm public health in myriad other ways, and lead to years of costly delays in combating the urgent threat of climate change.

Administrator Pruitt would have to go to great lengths to obscure and ignore these harmful consequences. When EPA issued the Clean Power Plan in 2015, it estimated that the plan would create up to $54 billion in annual benefits, including:

  • The prevention of up to 3,600 premature deaths every year
  • The prevention of 90,000 childhood asthma attacks every year
  • The prevention of 300,000 missed school and work days every year.

By comparison, EPA concluded that the annual costs would be much lower. And in the two years since the Clean Power Plan was issued, new analyses – including this one from New York University’s Institute for Policy Integrity – have concluded that compliance with the Clean Power Plan has become dramatically cheaper as a result of the plummeting costs of clean energy.

Yet the draft proposal for repealing the Clean Power Plan seems to rely on a significantly higher costs estimate, and much lower benefits. How is that possible?

A careful look at the numbers shows that the Administrator Pruitt’s EPA cooked the books for this proposal. They used discredited methodologies to artificially inflate costs, and to mask the consequences for our climate and obscure the thousands of lives that could be lost as a result of their repeal of the Clean Power Plan.

Here are four tactics that Administrator Pruitt has employed in the leaked proposal to inflate the costs and hide the benefits of the Clean Power Plan:

1. Disregarding lives saved by the Clean Power Plan

EPA’s original analysis of the Clean Power Plan found that it would avoid thousands of premature deaths each year by reducing particulate matter pollution – yielding up to $34 billion in annual health benefits in 2030.

According to the American Lung Association, particulate matter pollution causes permanent damage to lung development in children, aggravates asthma and other respiratory problems, increases hospitalizations, and increases deaths from heart and lung diseases including lung cancer.

The Clean Power Plan would reduce exposure to this pollution across the country – avoiding these health harms and premature deaths.

Administrator Pruitt’s draft proposal assumes away those benefits by asserting – contrary to established medical research – that there is zero health impact from reducing particulate matter pollution below certain “threshold” levels. The proposal also suggests that EPA can count only the climate benefits associated with carbon pollution, with no consideration to any health benefits at all.

This claim that there is a “threshold” level of particulate pollution below which it does not harm human health is directly contradicted by the American Heart Association and was completely discredited many years ago by an expert panel convened by EPA under the George W. Bush Administration. It also runs contrary to EPA’s long-standing practice.

As EPA itself recently explained in a court brief:

The best scientific evidence, confirmed by independent, Congressionally-mandated expert panels, is that there is no threshold level of fine particulate pollution below which health reductions are not achieved by reducing exposure.

Ignoring the deaths and harm to Americans’ health that would result from repealing the Clean Power Plan is unconscionable. The plain truth is that undoing the Clean Power Plan would deprive Americans of billions of dollars in health benefits and put then at increased risk for premature death.

2. Artificially inflating the costs of the Clean Power Plan

EPA originally anticipated that parties would comply with the Clean Power Plan in part through investments in demand-side energy efficiency, “a highly cost-effective means” for reducing carbon pollution from the power sector.

Demand-side energy efficiency measures help consumers save electricity, resulting in lower electric bills for hard-working Americans, less pollution, and a more reliable electric grid. Investments in energy efficiency are largely offset by the electricity savings that result.

Yet the upside-down accounting in the draft proposal adds those energy efficiency investments to the costs of the Clean Power Plan without deducting the electricity savings those investments yield. This makes it look like the power sector is paying for both energy efficiency and the electricity that it no longer needs to produce. Therefore, this upside-down accounting includes billions of dollars of imaginary electricity costs – for electricity that will never be generated or purchased.

The draft proposal adds the cost of this imaginary electricity to its estimate of Clean Power Plan benefits — to represent the “benefit” of not having to purchase electricity that was never produced in the first place. When comparing costs and benefits, this imaginary electricity is a net wash ­– but it enables EPA to inflate its estimate of the plan’s costs by up to $19.3 billion in 2030.

The draft proposal also uses a higher discount rate of 7 percent for energy efficiency investments – providing no meaningful justification for a choice that further inflates costs by $6.2 billion.

The cumulative effects of adding the cost of imaginary electricity and using a higher discount rate increases costs by up to $25.5 billion in 2030.

3. Shortchanging the benefits of reducing carbon pollution

Administrator Pruitt’s proposal aggressively undercuts the social cost of carbon. That's the estimate of damages that climate pollution causes for our families and communities – from more intense hurricanes and heat waves, more wildfires, and the many other threats of climate change.

By using an unrealistically low figure, the proposal severely undervalues the benefits of the Clean Power Plan’s carbon reductions.

The original Clean Power Plan utilized an estimate of the social cost of carbon developed over many years by experts from a dozen federal agencies who used the best available science and repeatedly considered public input.

The draft proposal for repealing the Clean Power Plan has new, misleading values that use unsound methods rejected by independent experts to yield a lower estimate of the Plan’s benefits.

The draft proposal simply ignores important categories of carbon reduction benefits

The new proposal claims to count only the domestic U.S. impacts of carbon pollution, even though this pollution causes worldwide harm. A recent report by the National Academy of Sciences affirmed the importance of counting global benefits, explaining that the benefits of reducing carbon pollution would be dangerously undervalued if every country used a domestic-only social cost of carbon.

The draft proposal’s “domestic-only” cost estimate also ignores significant harms to the U.S. that arise from climate change impacts in other countries – including “global migration, economic destabilization, and political destabilization,” and “[l]ower economic growth in other regions [that] could reduce demand for U.S. exports, and lower productivity [that] could increase the prices of U.S. imports.”

For these reasons, the National Academy of Sciences concluded earlier this year that:

Climate damages to the United States cannot be accurately characterized without accounting for consequences outside U.S. borders.

Administrator Pruitt’s approach flies in the face of that expert advice.

The draft proposal short-changes our children by discounting pollution reduction benefits for future generations

The new proposal also uses a sharply lower value for the benefits that today’s carbon reductions provide to future generations.

The original Clean Power Plan “discounted” the future benefits of carbon reductions at a rate of three percent per year, based upon the findings of the inter-agency working group.

But the new proposal uses discount rates as high as seven percent, without any justification – a value that is much higher than recommended by the National Academy of Sciences or the economics literature.

The cumulative effects of ignoring global impacts and increasing the discount rate are dramatic. In the original Clean Power Plan, EPA estimated climate benefits of $20 billion in 2030 (using a three percent discount rate). The draft proposal to repeal the Clean Power Plan estimates climate benefits of just $0.5 billion in 2030.

Click to enlarge

 

4. Ignoring how low-cost clean energy means the Clean Power Plan will be even more affordable

In the two years since EPA finalized the Clean Power Plan, the plan’s goals have become even more achievable and low-cost than originally projected – thanks to electricity sector developments including the sharply declining costs of renewable energy.

But the new draft proposal has made no attempt to update its economic analysis, and does not appear to acknowledge that recent studies of the Clean Power Plan have found compliance costs are now much lower than EPA originally estimated.

Instead, Administrator Pruitt is proposing to repeal this life-saving, economically beneficial public health protection before even bothering to properly consider the latest data.

The recent report from the Institute for Policy Integrity highlights the falling costs of complying with the Clean Power Plan and points to several power sector developments that explain this trend.

The report presents several recent economic analyses conducted by independent, non-governmental entities that estimate substantially lower compliance costs than EPA projected in 2015. For instance, a June 2016 analysis by M.J. Bradley & Associates, using the same electric sector model as EPA but updating several inputs, finds that compliance would cost up to 84 percent less than EPA originally estimated.

EPA recognized and evaluated many of these precise studies as part of its Clean Power Plan deliberations. Yet for the sake of repealing the Clean Power Plan, Administrator Pruitt has decided to ignore these studies.

America deserves better

The Clean Power Plan is the most significant step the U.S. has ever taken to address the crisis of climate change. Once fully implemented, it will provide enormous public health benefits – making Americans safer, healthier, and more productive.

If Administrator Pruitt is intent on rolling back a life-saving protection for human health and the environment, the American people at least deserve an honest evaluation based on the best available data.

Unfortunately, it looks like he’s using underhanded maneuvers and deceptive accounting gimmicks to justify rescinding the Clean Power Plan instead – and the consequences for the health and safety of Americans will be all too real for decades to come.

Also posted in Clean Power Plan, Economics, Health, News / Comments are closed

Climate and clean energy progress continues in spite of Clean Power Plan repeal rumors

According to news reports, Environmental Protection Agency (EPA) Administrator Scott Pruitt is planning to start the process of repealing the Clean Power Plan very soon.

This seriously flawed and misguided effort would be a dangerous step backwards for public health and climate protections.

However, as the Trump Administration continues to unravel these protections, the transition to a clean energy future is accelerating. States, cities, and power companies are responding to the ongoing attacks by forging ahead with ambitious actions to slash carbon pollution in order to respond to the threat of climate change and accelerate the clean energy revolution.

Clean Power Plan repeal?

The Clean Power Plan is a common-sense rule to safeguard public health by reducing carbon pollution from power plants to 32 percent below 2005 levels by 2030.

The Clean Power Plan would prevent:

  • 3,600 premature deaths each year
  • 1,700 heart attacks each year
  • 90,000 asthma attacks each year

Administrator Pruitt reportedly intends to propose repealing the Clean Power Plan in the coming days.

If so, EPA will likely issue an “Advance Notice of Proposed Rulemaking” (ANPR) to solicit public input on a replacement rule – a protracted process that is likely to lead to a far weaker standard.

The ANPR process could lead to years of harmful and unjustified delay in implementing urgently needed limits on carbon pollution from fossil fuel power plants.

Forging ahead to a clean energy future

The U.S. power sector has already made enormous strides in deploying clean energy resources and slashing greenhouse gas emissions.

American Wind Energy Association

 

Solar Jobs Census 2016The Solar Foundation, interactive map

Globally, the International Energy Agency (IEA) reported yesterday that renewables accounted for almost two-thirds of new capacity installed.

  • Solar additions worldwide grew faster than any other fuel last year, including coal and natural gas.
  • Over the next five years, the IEA projects renewable capacity to grow by over 920 gigawatts – a 43 percent increase by 2022.

Meanwhile, by the end of 2016, carbon pollution from U.S. power plants had already declined to 25 percent below 2005 levels – meaning the power sector is already almost 80 percent of the way to achieving the Clean Power Plan’s 2030 targets.

A new report by the Institute for Policy Integrity highlights the falling costs of complying with the Clean Power Plan. The report points to several market and policy developments including low natural prices, declining renewable energy costs, the 2015 renewable energy tax credit extensions, and state programs supporting the adoption of clean energy technologies.

The Clean Power Plan targets have become a floor for forward-looking states and companies that acknowledge the Clean Power Plan was a first step towards realizing the promise of a low-carbon power sector.

Yet this shift towards clean energy – driven by market forces and accelerating subnational action – is no substitute for decisive federal action that will ensure continued and accelerated progress in achieving the emissions reductions required to stem the tide of climate change.

The U.S. Energy Information Administration projects that without the Clean Power Plan, carbon emissions from the power sector will increase by 2030 – reversing the current downward trajectory in the United States and leaving the country behind as the global clean energy revolution continues.

To keep us moving forward, state and local officials are stepping up their game by cutting carbon pollution and switching to clean energy in spite of — and in direct response to — President Trump’s rollbacks.

  • Fourteen states and Puerto Rico, accounting for more than 10 percent of U.S. carbon emissions from the power sector, pledged as part of the new U.S. Climate Alliance to reduce their greenhouse gas emissions consistent with the goals of the Paris Agreement, as well as meet or exceed their Clean Power Plan targets.
  • 381 mayors (and counting) representing more than 67 million Americans also pledged to honor the Paris Agreement goals and work to meet the 1.5° Celsius global temperature target. Dozens of cities have committed to move to 100 percent clean energy.
  • Colorado Governor John Hickenlooper signed an executive order in July 2017 committing the state to slash greenhouse gas emissions to 26 percent below 2005 levels by 2026, consistent with U.S. goals under the Paris Agreement. “The vast majority of our residents, and indeed the country, expect us to help lead the way toward a clean and affordable energy future,” Governor Hickenlooper said in a press release.
  • Nine states comprising the Regional Greenhouse Gas Initiative (RGGI) in August announced a proposal to cut carbon pollution from the power sector an additional 30 percent between 2020 and 2030 – a 65 percent reduction below the original 2009 pollution cap. The proposal demonstrates bipartisan commitment to combat climate change, with five Republican and four Democratic governors helming the RGGI states (Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont). Meanwhile, both New Jersey gubernatorial frontrunners have pledged to rejoin RGGI after this year’s election.
  • Virginia regulators are working to establish a “trading-ready” program to slash power plant carbon emissions in response to an executive order Governor Terry McAuliffe signed in May 2017. “Today, I am proud to take executive action to cut greenhouse gases and make Virginia a leader in the global clean energy economy,” Governor McAuliffe said when he signed the order.
  • California affirmed its position as a global leader on climate progress with a bevy of actions in the past year. In September 2016, legislators passed SB 32, which requires the state to slash greenhouse gas emissions to 40 percent below 1990 levels by 2030. In July 2017, the state secured a 10-year extension to its landmark cap-and-trade program and strengthened tools to improve local air quality in a bipartisan effort. “All over the world, momentum is building to deal seriously with climate change,” Governor Jerry Brown said in July. “Despite rejection in Washington, California is all in.”
  • At least 20 states and the District of Columbia have adopted ambitious greenhouse gas reduction targets, with most aiming for an 80 percent reduction by 2050 below baselines ranging from 1990 to 2006. Twenty-nine states and D.C. have binding renewable portfolio standards in place, while eight more have set renewable portfolio goals. Twenty states have set mandatory energy efficiency targets, while eight more have set energy efficiency goals.

The nation’s largest power companies are similarly pledging to slash carbon pollution and deploy renewable energy resources as they embrace the rapid transition to a clean energy economy.

  • The CEO of American Electric Power (AEP), the country’s largest generator of electricity from coal, had this to say in response to President Trump’s decision to withdraw the U.S. from the Paris Agreement: “I think it's really important for us to stay engaged from an international community standpoint, particularly addressing large issues. And not withstanding that, we're continuing on our path of moving to a clean energy economy.” AEP has cut carbon pollution by 44 percent since 2005, and has plans to add more than eight gigawatts of wind and solar in the coming years.
  • Duke Energy, the nation’s largest power producer, this year announced plans to reduce carbon emissions to 40 percent below 2005 levels by 2030. “Our next major investment platform focuses on generating cleaner energy,” said CEO Lynn Good. “Our retirement of more than 40 older, less efficient coal units, coupled with the addition of clean natural gas plants and renewables, is driving our emissions reduction.”
  • DTE Energy Co. announced plans in May 2017 to curb its carbon emissions more than 80 percent by 2050 by closing coal-fired power plants and adding new gas-fired generation and renewables. “Not only is the 80 percent reduction goal achievable – it is achievable in a way that keeps Michigan's power affordable and reliable,” DTE Chairman and CEO Gerry Anderson said. “There doesn't have to be a choice between the health of our environment or the health of our economy; we can achieve both.”
  • Xcel Energy committed in June 2017 to achieving a 60 percent reduction in carbon emissions by 2030, relative to 2005 levels. In August, the company announced plans to retire two coal-fired units in Colorado, continuing its progress towards a cleaner generating portfolio. In addition, Xcel’s massive new investments in renewable energy –including a proposal to add 3,380 megawatts of wind generation across seven states –will help the company generate 40 percent of its energy from renewables by 2021.
  • Berkshire Hathaway Energy subsidiary MidAmerican Energy has announced a goal to provide 100 percent renewable energy, including a $3.6 billion project to add 2,000 megawatts of wind, which will expand wind energy to 85 percent of the company’s sales. Said CEO Bill Fehrman: “Our customers want more renewable energy, and we couldn’t agree more.”
  • Minnesota Power, a division of ALLETE, plans to provide 44 percent of its electricity from renewable resources by 2025. Said one executive, “We look forward to working with our customers and regulators to continue down the path toward a safe, reliable, cleaner and affordable energy future.”

The imperative of addressing climate change, overwhelming public support for climate action, and clear market trends towards lower-carbon energy resources are driving states, cities, and power companies to lead the way to a low-carbon future.

If governors, mayors, and power sector CEOs continue to take steps to reduce carbon pollution, they will realize the tremendous benefits of a clean energy economy — thousands of new jobs, critical public health protections, and increasingly resilient communities and infrastructure.

The Trump Administration’s effort to repeal the common-sense Clean Power Plan – its latest attack on life-saving safeguards for our children’s health – will not change the reality of climate change or the accelerating transition to an economy powered by low-carbon energy.

However, without a quick return to meaningful federal progress, the U.S. will fall further behind in the global clean energy revolution – one that could lead to shared prosperity and enormous opportunities for millions of Americans.

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