Climate 411

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

By / Published: June 16, 2020

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 »

Also posted in Clean Air Act, Clean Power Plan, EPA litgation, News, Partners for Change, Policy / Comments are closed

This isn’t your parents’ Earth Day: Talking unlikely paths to environmentalism with EDF’s Diverse Partners team    

By / Bio / Published: April 22, 2020

This year we have reached Earth Day not only as the country continues to face unimaginable death tolls, but especially as there is an increasing understanding of the ways the coronavirus is compounding existing injustices in our country. 

EDF and EDF Action are very fortunate to have recently hired two amazing women, Elise Nelson Leary and Esther Sosa, to lead our engagement work with Latino, African American and other diverse community partners. We recently had a remote conversation with them to reflect on their current work and past experiences with Earth Day and the environmental movement.

“I would never have categorized my family as environmentalists…but that doesn’t mean they don’t care about the earth and its resources”

Question: What were your first memories of Earth Day? Are your families environmentalists?  Read More »

Also posted in Latino partnerships / Comments are closed

Momentum for climate action on Capitol Hill launches bipartisan Senate innovation package

By / Published: March 9, 2020

Local officials, lawmakers, and business leaders across the country are coalescing around initiatives to put the United States on a path to a 100% clean economy by 2050.

To achieve this ambitious objective and avoid the worst impacts of climate change, we must ensure that no more climate pollution is produced than can be removed from the atmosphere across our economy.

While there are different paths to achieve a 100% clean economy, we know we can’t be successful on the timeline science demands without a comprehensive limit and price on carbon emissions, accelerated deployment of existing clean energy technologies and rapid advancement in technology innovation. Together, this will spur a transition from a fossil fuel based economy to one driven by clean, affordable, reliable energy sources.

This transformation will affect every sector of our economy. But it can’t happen on its own, and it certainly won’t take place overnight, which is why we need lawmakers in Washington, D.C. to make progress whenever the opportunity arises.

Fortunately, U.S. Senators Lisa Murkowski (R-AK) and Joe Manchin (D-WV), leaders of the Senate’s Energy and Natural Resources Committee, recognize the important role innovation will play in a 100% clean future and have developed a major legislative package that includes dozens of provisions supporting new and expanded investment in research, development and demonstration for a wide range of low-carbon energy technologies. 

While this bipartisan package provides much-needed resources for an array of emerging low-carbon technologies, it could be improved by more balance in its funding levels. The current bill greatly increases funding to research and develop advanced nuclear and carbon capture, two technologies with potentially long timelines and limits to where they can be deployed to achieve significant emissions reductions, while keeping funding for renewables relatively flat.

Notable clean energy bills in this package include:

  • The BEST Act, which will authorize critical resources and require demonstration projects to advance energy storage technology.
  • The Clean Industrial Technology Act, which will reorient the U.S. Department of Energy research, design, and development towards decarbonization through the creation of competitive grants, cooperative agreements, technical assistance, and demonstration projects. This bill has already passed the Senate Energy and Natural Resources Committee on a bipartisan basis.
  • The Grid Modernization Act, which will establish a research, design and development program to increase energy storage and ensure the energy grid can meet the demands of a 100% clean future. This bipartisan bill has also already passed the Senate Energy and Natural Resources Committee.

While no bill is perfect, this package takes some valuable steps forward to help drive down the costs, and accelerate the deployment of clean energy technologies — and importantly, it has the bipartisan support needed to pass both the House and Senate.

By demonstrating the strength of cooperation across the ideological spectrum, this package can help spur more bipartisan momentum towards a durable solution to the climate crisis. It is encouraging to see lawmakers from both parties roll up their sleeves and work together to unlock innovation and accelerate key solutions that are needed to address climate change.

Authorizing new resources to fight climate change is an important first step towards a comprehensive federal strategy that puts the United States on the path to a 100% clean economy, but support for innovation alone is not sufficient to address the climate crisis. 

We need a comprehensive climate solution to solve this crisis. Until then, we shouldn’t ignore important progress along the way. This package of bills that will spur innovation is a welcome step forward and an important component of a 100% clean future.

The Senate is expected to vote on this Energy Innovation package in the coming days.

Also posted in Policy / Comments are closed

Two new analyses: significant benefits for Pennsylvania from historic move to limit carbon pollution

By / Bio / Published: November 21, 2019

(This post was co-written by Mandy Warner)

Two new analyses show significant opportunities for Pennsylvania under environmental protections that are compatible with the Regional Greenhouse Gas Initiative – commonly known as RGGI.

RGGI is a collaboration of nine northeast states that is designed to lower carbon pollution from the power sector. Pennsylvania Governor Tom Wolf signed an historic executive order last month directing the state’s Department of Environmental Protection to develop a regulation that is compatible with RGGI. That order followed Wolf’s commitment to reducing Pennsylvania’s climate pollution by 26 percent by 2025 and 80 percent by mid-century, compared to 2005 levels.

Pennsylvania has the fifth dirtiest power sector in the nation, and the power plants operating in Pennsylvania emit more carbon pollution than all the other power plants in the nine northeastern states in RGGI combined. A binding, declining limit on carbon pollution is a necessary element of any strategy to address this problem.

Two studies underscore the value of Pennsylvania’s actions:

  • EDF and M. J. Bradley & Associates released a new analysis that found there could be significant economic and emissions reduction benefits for Pennsylvania from setting a binding, declining limit on power sector carbon pollution, and creating a flexible, market-based mechanism to achieve that limit. The analysis was based on policy specifications, inputs, and assumptions developed by M.J. Bradley & Associates at the direction and on behalf of EDF, with feedback from participating stakeholder companies.
  • A recent report by Resources for the Future had similar findings.

Here are five key takeaways from both of these analyses.

  1. Pennsylvania has a significant opportunity for cost-effective pollution abatement by limiting carbon pollution and linking with RGGI

While carbon pollution from Pennsylvania’s power sector has declined in recent years, driven primarily by market trends including cheap natural gas prices, it is projected to start increasing again. By mid-2020, under business-as-usual forecasts with no carbon limits, both analyses found Pennsylvania’s power sector carbon pollution would be more than 30 percent higher than current levels.

By setting a binding, declining limit on power sector carbon pollution and creating a flexible, market-based mechanism to achieve that limit, Pennsylvania can significantly reduce its carbon pollution at low cost.

The EDF and M.J. Bradley & Associates analysis found that linking with RGGI and designing the program in a way that ensures all electric power used in Pennsylvania is covered under the cap could lower carbon pollution by more than 35 percent and produce roughly $200 million in net savings for Pennsylvania in 2030. That’s compared to business-as-usual scenarios with no carbon limit.

The lower costs are due to reduced need for capital expenditures like building new power plants, and to declining fossil fuel costs – both driven by more of the existing nuclear fleet remaining in operation.

Resources for the Future’s analysis similarly found that linking with RGGI could lead to significant carbon pollution reductions in Pennsylvania with no observable increases in electricity prices.

Earlier studies have also demonstrated the benefits of RGGI. By driving investments in energy efficiency, RGGI has already reduced consumer energy bills, generated net economic benefits for participating states, and has  produced enormous public health benefits. RGGI has helped save hundreds of lives, prevented thousands of asthma attacks, and saved billions of dollars in health-related economic costs.

According to electricity bill modeling by the Analysis Group, the average residential electricity bill in RGGI states will be 35 percent lower in 2031 than it is today, due to investments in energy efficiency.

Linking Pennsylvania with RGGI could offer further benefits – including allowing for emissions trading, which can lower total costs and make Pennsylvania’s program resilient to unexpected changes in weather or other events that could affect electricity markets while still preserving state autonomy and programs.

  1. Limiting carbon pollution and linking with RGGI provides support for existing and new zero-emission generation

Placing a binding, declining limit on carbon pollution – and then letting the carbon pollution limit drive a price in the energy market – provides Pennsylvania with a technology-neutral approach that ensures the most cost-effective deployment of zero-emission resources to meet the state’s climate goals.

The EDF and M.J. Bradley & Associates analysis found that under business-as-usual scenarios using EDF’s reference natural gas price assumptions, all nuclear capacity in Pennsylvania retires by 2030.

According to the analysis, linking with RGGI and designing the program in a way that ensures all electric power used in Pennsylvania is covered under the cap can help support the state’s existing nuclear fleet – retaining roughly 50 percent of the fleet in 2030.

Resources for the Future similarly found that limiting carbon pollution and linking with RGGI would forestall expected nuclear retirements, increasing Pennsylvania’s nuclear generation by up to 280 percent in 2026 relative to business-as-usual scenarios.

The natural gas prices used by Resources for the Future for their analysis are higher than currently observed, which would allow nuclear capacity to remain profitable with greater ease than may be possible with lower natural gas prices. But the preservation of existing nuclear capacity is a robust result under all scenarios that limit carbon pollution across both analyses, providing valuable insight into the role a limit on carbon pollution can play in preserving assets that are zero-emitting.

The EDF and M.J. Bradley & Associates analysis also found that linking with RGGI can increase wind and solar generation in Pennsylvania by almost 75 percent in 2030 compared to current levels. Resources for the Future found that limiting carbon pollution and linking with RGGI could generate up to 25 percent more wind and solar generation in Pennsylvania by 2026 compared to business-as-usual scenarios.

  1. Pennsylvania can reduce carbon pollution while increasing net exports from the state

The EDF and M.J. Bradley & Associates analysis shows that limiting carbon pollution and linking with RGGI would enable Pennsylvania to achieve its environmental objectives at low cost while at the same time increasing net exports from the state at least nine percent in 2030 compared to current levels.

Pennsylvania can also design its program to shift allowance value to producers with updating output-based allocation, which can increase gas and nuclear generation and energy exports in the state. According to Resources for the Future, the production incentive from output-based allowance allocation can increase exports from Pennsylvania above business-as-usual levels by 2026. Most of these exports are to other RGGI states so the overall pollution in the region is unaffected.

Resources for the Future also finds that using an output-based allowance allocation to non-emitting producers can provide incentives to shift generation in Pennsylvania from fossil fuel to zero-emitting sources, further decreasing carbon pollution in Pennsylvania and nationally.

  1. Smart policy design can amplify these benefits and further lower overall pollution

When a state or group of states puts a limit on carbon pollution, particularly in states that are served by a multi-state wholesale electricity market, emissions leakage to emitting sources that are not covered under the program is always a concern.

While both analyses demonstrate clearly that such leakage will not even come close to dwarfing the significant climate benefits of Pennsylvania’s program, it may partially erode the potential for greater pollution reductions. Linking programs can help reduce leakage but is not sufficient to fully mitigate it.

The EDF and M.J. Bradley & Associates analysis finds that an effective leakage mitigation mechanism, such as putting emissions associated with imported power under the cap, can lower overall carbon pollution – driving 75 percent more reduction in pollution in the Eastern Interconnect in 2030. The analysis also shows that leakage mitigation can help provide more support for Pennsylvania’s existing nuclear fleet and lower overall system costs, more than doubling nuclear generation in the state and lowering system costs by roughly $330 million in 2030 compared to no leakage mitigation.

Pennsylvania has options available today to mitigate leakage concerns and ensure that the state is not disadvantaged in the broader marketplace relative to other states that choose not to control carbon pollution. Resources for the Future has shown that an output-based allowance allocation to producers has the potential to result in negative leakage.

Regional transmission organization PJM Interconnection is also looking into ways to enhance technical capabilities to support state policy choices such as carbon limits. As part of its Carbon Pricing Senior Task Force, PJM is actively exploring with its stakeholders what data needs and frameworks can best support state carbon outcomes in the context of a regional market. They are also considering ways to ensure that states that are controlling carbon are seeing those policy choices accurately reflected.

This PJM stakeholder process provides an important opportunity for Pennsylvania to engage to ensure the state has the information it needs to deploy the policy frameworks that can effectively mitigate leakage.

  1. More ambitious carbon pollution limits can provide even further benefits

The EDF and M.J. Bradley & Associates analysis also finds that more ambitious carbon pollution limits (in line with deep decarbonization trajectories) with leakage mitigation can accelerate pollution reductions, retain all of the state’s existing nuclear fleet, and incent new clean energy resource builds – all at lower system costs compared to business as usual scenarios with no carbon limit.

According to the analysis, more ambitious carbon pollution limits can increase solar capacity in Pennsylvania by more than 10 times, leading to an increase in renewable generation of more than 130 percent in 2030 compared to business-as-usual scenarios.

Public support for concrete climate policy is sky-high in Pennsylvania

There is strong support in Pennsylvania for moving forward to reduce carbon pollution.

A poll conducted by EDF Action earlier this year found that 79 percent of Pennsylvania voters support regulations to reduce carbon pollution. That includes 66 percent of state Republicans polled.

Major Pennsylvania power companies, including Exelon and FirstEnergy, applauded Governor Wolf’s executive order. The Pennsylvania Chamber of Commerce noted that “climate change is real” and that the business community needs to be “at the table to discuss solutions.”

The time for action is now

It is becoming increasingly urgent to address climate change. That means it is critical for Pennsylvania to move forward without delay, and put in place an ambitious program to secure carbon pollution reductions and lock in public health benefits at the lowest cost.

The good news is that Pennsylvania can build on planning it has already completed as part of previous compliance work. Governor Wolf’s executive order sets a deadline of July 31, 2020 for a proposed rule to cut carbon emissions to be presented to the Environmental Quality Board. But there’s no reason not to move forward more quickly.

We urge Governor Wolf to develop a proposed rule to submit to the Air Quality Technical Advisory Committee at its February meeting. That would help create certainty about the state’s emissions trajectory on a short-term time horizon, including creating regulatory certainty for affected industries.

Also posted in Cities and states, Energy, Policy / Comments are closed

Public records confirm EPA’s “censored science” proposal was an end-run around Congress

By / Published: November 12, 2019

Earth as seen from a NOAA weather satellite. Photo: NASA

The Trump administration is reportedly expanding its dangerous plan — originally proposed by former Administrator Scott Pruitt — to limit the scientific evidence that the agency can consider when establishing public health protections.

According to a story in the New York Times today, the new proposal will be even more damaging than Pruitt’s version – which was flatly illegal and would have left Americans more exposed to dangerous contaminants in the air we breathe, the water we drink, and the products we use.

The original proposal was based on failed congressional legislation whose sponsor “pitch[ed]” the idea to former EPA Administrator Scott Pruitt. But newly released public documents show that the origins of the “censored science” proposal are more cynical than we knew.

EDF sued to obtain the public records after EPA violated the Freedom of Information Act (FOIA) by not releasing them, with Earthjustice representing us in the litigation.

The new public records reveal just how explicitly Trump’s EPA is attempting to defy Congress by implementing its “censored science” policy through administrative rulemaking. It turns out that – from the beginning – EPA’s overt goal was to implement the same damaging ideas that the Senate refused to pass. Read More »

Also posted in Health, News, Policy, Pruitt, Science, Setting the Facts Straight / Comments are closed

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

By / Published: October 30, 2019

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.

Also posted in Clean Air Act, Clean Power Plan, EPA litgation, Policy / Comments are closed