Selected category: Setting the Facts Straight

Electric Reliability and the Clean Power Plan: Perspectives of a Former Regulator

1024px-Wind_Turbines_and_Power_Lines,_East_Sussex,_England_-_April_2009

Source: Wikimedia Commons

There is no great disagreement that the U.S. energy system is transforming. With or without additional environmental regulations, like the U.S. Environmental Protection Agency’s (EPA) proposed Clean Power Plan, this transition is occurring. Our history and experience have demonstrated that we can weather it without threatening our uniform and non-negotiable commitment to reliability.

But to do that, we need to tap all of the tools at our disposal to ensure a robust, reliable, and integrated energy system that is no longer dependent exclusively upon centralized, fossil fuel generation. Done right, the resulting change can deliver benefits to customers, the economy, the environment, electric companies, innovators, and workers alike.

EPA’s proposed Clean Power Plan would place national limits on carbon pollution from existing fossil fuel power plants for the first time ever. In doing so, it would create long-term market signals that will help drive investments in energy efficiency, demand response, and renewable energy for years to come – not only reducing carbon pollution from the power sector to 30 percent below 2005 levels by 2030, but also by putting us on a path to a more reliable and resilient energy system.

As a former Commissioner of the Ohio Public Utilities Commission and electric system operator, I understand preserving the reliability of electric service is a paramount public responsibility for energy and environmental regulators, and for the power companies they oversee. As a Commissioner, I served as vice chair of the Critical Infrastructure Committee, a member of the Electricity Committee, and on the Task Force for Environmental Regulation and Generation within the National Association of Regulatory Utility Commissioners (NARUC). I co-chaired the National Electricity Forum 2012 to modernize the nation’s electricity infrastructure. At the request of the Federal Energy Regulatory Commission (FERC) and the U.S. Senate Committee on Energy and Natural Resources, I have provided testimony on reliability of the bulk power system before both of those bodies.

Prior to my appointment to the Commission, I served for six years as the Deputy Director and then Director of the City of Columbus, Ohio Department of Public Utilities. My duties there included running the City’s electric distribution utility. This hands-on experience meeting the daily needs of electricity customers as both a regulator and a system operator – while protecting the financial integrity of the system – gives me a keen appreciation for the real-world demands and importance of system reliability.

From that perspective, perhaps the most critical feature of the proposed Clean Power Plan is the flexibility it provides to states and power companies to craft individualized compliance plans that reduce pollution while preserving and strengthening electric reliability. EPA’s approach gives clear guidance on what limits and metrics must be met, but leaves states the flexibility to design solutions that will boost the economy and meet those requirements as they see fit.

That flexibility acts as a built-in “safety valve,” affording each state multiple pathways for compliance and providing leeway for states to make plans that are appropriate to their unique circumstances. Moreover, this flexibility complements the robust framework of operating practices, market instruments, and planning processes that already exist to address short-term and long-term reliability issues.

Leading experts on energy policy and electric reliability have recently weighed in to confirm reducing carbon pollution goes hand in hand with electric reliability, thanks to the flexible structure of the Clean Power Plan and our existing reliability tools and processes. According to a recent report by The Brattle Group, the combination of the ongoing transformation of the power sector, the steps already taken by system operators, the large and expanding set of technological and operational tools available, and the flexibility under the Clean Power Plan are likely sufficient to ensure compliance will not come at the cost of reliability.

And, just last week, Dr. Susan Tierney – a former Assistant Secretary for Policy at the U.S. Department of Energy and former Commissioner of the Massachusetts Department of Public Utilities— joined two other energy policy experts in sending a letter and report to the Chairman of the Federal Energy Regulatory Commission (FERC) concluding:

Evidence does not support the argument that the proposed CPP will result in a general and unavoidable decline in reliability.

The report provides examples of recent instances in which grid operators, FERC, and other entities have effectively used existing processes and tools to deftly address other kinds of reliability challenges in recent years, some of which were significant and unanticipated.

In 45 years of implementing the Clean Air Act, clean air standards have never caused the lights to go out. And nothing about the proposed Clean Power Plan – with all of its tremendous flexibility – will alter that record.

That’s a remarkable testament to the institutions and processes that exist to protect reliability, as well as the careful process EPA uses in developing clean air standards – and it is great news for families and communities who want and deserve clean air in addition to reliable, affordable electricity. The Clean Power Plan, like our other vital clean air standards, will help deliver both.

Also posted in Clean Air Act, Clean Power Plan, Energy, Policy| 1 Response

On El Niño, snowballs and real climate science

Source: NASA

Just as we thought science was finally taking root, here comes another article claiming that the rise in global temperatures has nearly stopped over the last 15 years. We heard it most recently from the Wall Street Journal.

Never mind that it’s been 30 years since a month was below the 20th century global average surface temperature. Or that climate change is evidenced by clearly visible sea ice and glacial melt. Skeptics support their argument by pointing out, time and time again, how little the Earth has warmed since 1998.

Indeed, the “nearly-stopped warming” may at face value appear to be supported by convincing scientific data. But don’t be fooled: 1998 was an exceptionally warm year thanks to a very intense El Niño, a naturally-occurring phenomenon involving unusually warm water in the Eastern Pacific Ocean.

The change in temperature from 1998 to today, therefore, is not at all a good representation of the long-term trend. It makes the nearly-stopped warming argument no more scientific than a snowball would be in Washington in February.

Selective statistics don't make a trend

Think of it as if you were to use the holiday season as a benchmark for measuring body weight.

If I looked at the weight change I had between Thanksgiving and December 31, a time of year when I usually enjoy lots of good food, the picture would look very different than if my weight monitoring began the week before Thanksgiving. That's because a Thanksgiving start date would be a higher-than-normal weight day, an anomaly.

And, yet, this is exactly what proponents of the nearly-stopped-warming theory are doing.

While it's true that the rate of temperature change has decreased since 2001, they cherry-pick a recent 15-year period, 1998 to 2012, starting with an initial year that is already way above average to prove their point. Of course, these quasi-scientists aren’t transparent about their strategy, so a non-expert would have to dig into the data to realize they are being tricked.

El Niño always a wild card

El Niño, meanwhile, was just doing what niños tend to do: It threw us for a loop.

The one occurring for 10 consecutive months 1997-98 was the most intense ever recorded, making 1998 the hottest year up until that point. (Three years have since broken that record: 2005, 2010 and 2014.)

Scientists have a number of technical and statistical methods for delineating natural from human influences on the temperature record, and apply these tools depending on the research questions they're trying to answer.

But the overall global record is not touched, so if you don't know which years were affected by natural events such volcanic eruptions, it can look noisy and confusing.

This is why we need to look at long-term trends to get the real answers.

This post originally appeared on our EDF Voices blog.

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

See no climate, hear no climate, speak no climate…Here we go again?

Source: Flickr/Alison Curtis

When news broke this week alleging that officials working for Gov. Rick Scott of Florida – a state that faces devastating impacts from climate change, such as being partially submerged – had unofficially banned use of the terms "climate change" and "global warming" from state documents, I had to check my calendar to see what year this is.

It felt as if we were back in 2003, when the George W. Bush administration was up to the same tricks. A former American Petroleum Institute lobbyist named Philip Cooney, who was then chief of staff in the White House Council on Environmental Quality, made hundreds of edits and deletions to EPA documents.

This country is drowning

Bush's White House tried to muzzle the EPA

Cooney's goal, according to a House committee investigation, was to “exaggerate or emphasize scientific uncertainties or to deemphasize or diminish the importance of the human role in global warming.” Cooney insisted on such extreme edits that that EPA decided to eliminate the climate change section from one report entirely.

After New York Times reporter Andrew Revkin broke the news about what was going on, Cooney resigned from the White House – and went to work for Exxon Mobil.

It's not yet clear exactly what happened in Florida. After four former staffers with the Florida Department of Environmental Protection said they'd been told not to use the terms "climate change," "global warming" or "sustainability," and that this ban was widely known, Gov. Scott told reporters this week "it's not true."

The DEP website does include references to climate change, though most are several years old. Meanwhile, at least one group has asked the agency's inspector general to investigate.

Other states tried to censor, too

With an overwhelming majority of the American public favoring climate action, skeptical politicians are starting to crab-walk in the direction of climate reality. “I’m not a scientist” is the current favorite dodge and also with Gov. Scott – an attempt to avoid both outright denial and the responsibility to act that comes with recognizing the problem.

But as Emily Atkin reported in Climate Progress, other states where the governors still don’t accept the scientific validity of human-caused climate change have also been pulling out the muzzle.

Pennsylvania’s Department of Conservation and Natural Resources was accused of pulling references to climate change from its website under orders from aides to Governor Tom Corbett. Corbett has since been voted out of office in favor of Gov. Tom Wolf, who understands that climate change is real.

North Carolina’s Department of Environment and Natural Resources was caught doing the same thing. This is the state where the General Assembly in 2012 passed a four-yearmoratorium on policies that rely on scientific models for sea level rise.

Maybe these states should require environmental officials to scrunch their eyes shut, stick their fingers in their ears and chant "nya-nya-nya." That would surely solve the problem.

Enough already

Here’s a prediction: Attempts to expunge the climate problem by executive fiat – to air-brush state websites and muzzle scientists – are on their last legs. So are evasions like “I’m not a scientist.”

Americans are raising the bar on how politicians from both parties talk about this issue. Voters will increasingly reward climate honesty and climate action.

Politicians who don't deliver will find themselves punished at the polls.

This post first appeared on our EDF Voices Blog.

Also posted in Extreme Weather, Policy| Read 1 Response

Defenders of dirty power plants use doublespeak to shape debate

Under the proposed Clean Power Plan, plants must cut carbon dioxide emissions by 30 percent below 2005 levels by 2030.

(This blog originally appeared on EDF Voices)

As we’ve noted before, few opponents of the federal Clean Power Plan want to stand up and say they favor unlimited carbon pollution. So they’re apt to frame their arguments in more clever ways.

Under the proposed Clean Power Plan, plants must cut carbon dioxide emissions by 30 percent below 2005 levels by 2030.

Sometimes their approach is to use misleading statistics – like when they talk about the cost of moving to clean energy without mentioning the much larger benefits of doing so.

Or they’ll use an appealing bit of logic, which sounds right until it’s exposed to the way the world really works.

It takes more than one EPA rule

One of those seemingly-logical attacks is the complaint that the plan the U.S. Environmental Protection Agency rolled out June 2 won’t solve climate change.

A CATO Institute blog says, “EPA’s Regulations Will Not Mitigate Climate Change.” At first glance, that seems like a step forward from the crazier objections – for instance, that climate change doesn’t exist.

But it’s really just a new strategy aimed at the same goal, like a lawyer who failed to impress the jury with an insanity defense and is now piecing together a fake alibi.

Your suspicions should be raised immediately when coal conglomerates complain that an EPA rule does “little” to solve an environmental problem, which on the surface sounds like a worthy objection. Why should the United States take this step to end unlimited pollution from power plants, they ask, when it won’t resolve the problem we are facing?

The complaint rests on the idea that the pollution reductions from U.S. power plants will not cut enough emissions to stop global warming. And that’s true.

It’s like telling Ike to call off D-Day because the landing alone wouldn’t defeat the Germans.

Even though power plant emissions are the largest source of carbon pollution in the United States – as of 2011, our utilities put out more of this pollution than the entire economies of every foreign country but China – they’re only a portion of total global output. So this plan does not, on its own, solve climate change.

But this argument is sort of like telling Ike to call off D-Day because the landing alone wouldn’t defeat the Germans.

Or it’s like telling a person with multiple risk factors for heart disease to keep smoking, because quitting won’t prevent an attack on its own. The reality is that in solving big problems, a major first step is always necessary and it's always insufficient.

The most important truth – in fact, the very reason some in industry are scrambling for arguments to oppose this new rule – is that the Clean Power Plan is a turning point in our environmental and economic history.

A historic step

For the first time, we’ll cut carbon emissions from their largest source, and begin to drive greater investment in abundant, affordable clean energy.

It will also have a big impact around the world. Addressing a major global problem in the 21st Century requires America to lead by example.

By making a substantial cut in our largest source of carbon emissions, we will not only cut billions of tons of pollution, we will enable a much bigger step forward internationally.

Let’s face it: Most of those in the fossil fuel industry who argue that the Clean Power Plan doesn’t cut enough pollution are really just trying to make sure we don't cut any pollution at all.

They know that if they’re able to intimidate the Congress into blocking these rules, it would make it substantially less likely that the U.S. and the rest of the world will move forward to a cleaner future.

But there’s an easy test to tell if someone offering this complaint is sincere: If they’re making suggestions to further strengthen the final rule, then they’re actually interested in a solution.

If not, they’re just trying to keep America living in the past.

Also posted in Clean Power Plan, Energy, Greenhouse Gas Emissions, News| Comments are closed

Reality check: Society pays for carbon pollution and that's no benefit

This open letter, co-authored by Jeremy Proville and first published on EDF Voices, was written in response to a New York Times article citing Dr. Roger Bezdek’s report on “The Social Costs of Carbon? No, The Social Benefits of Carbon.”

Dear Dr. Bezdek,

After seeing so many peer-reviewed studies documenting the costs of carbon pollution, it’s refreshing to encounter some out-of-the-box thinking to the contrary. You had us with your assertion that: “Even the most conservative estimates peg the social benefit of carbon-based fuels as 50 times greater than its supposed social cost.” We almost quit our jobs and joined the coal lobby. Who wouldn’t want to work so selflessly for the greater good?

Then we looked at the rest of your report. Your central argument seems to be: Cheap fuels emit carbon; cheap fuels are good; so, by the transitive property of Huh?!, carbon is good. Pithy arguments are fine, but circular ones aren’t.

First off, cheap fuels are good. Or more precisely, cheap and efficient energy services are good. (Energy efficiency, of course, is good, too. Inefficiency clearly isn’t.) Cheap energy services have done wonders for the United States and the world, and they are still doing so. No one here is anti-energy; we are against ruining our planet while we are at it.

The high cost of cheap energy

Yes, the sadly still dominant fuels—by far not all—emit carbon pollution. Coal emits the most. Which is why the cost to society is so staggering. Forget carbon for a moment. Mercury poisoning from U.S. power plants alone causes everything from heart attacks to asthma to inhibiting cognitive development in children. The latter alone is responsible for estimated costs of $1.3 billion per year by knocking off IQ points in kids. All told, coal costs America $330 to 500 billion per year.

Put differently, every ton of coal—like every barrel of oil—causes more in external damages than it adds value to GDP. The costs faced by those deciding how much fossil fuel to burn are much lower than the costs faced by society.

None of that means we shouldn’t burn any coal or oil. It simply means those who profit from producing these fuels shouldn’t get a free ride on the taxpayer. Conservative estimates indicate that carbon pollution costs society about $40 per ton. And yes, that’s a cost.

Socializing the costs is not an option

As someone with a Ph.D. in economics, Dr. Bezdek, you surely understand the difference between private benefits and social costs. No one would be burning any coal if there weren’t benefits to doing so. However, the “social benefits” you ascribe to coal are anything but; in reality they are private, in the best sense of the word.

If you are the one burning coal, you benefit. If you are the one using electricity produced by burning coal, you benefit, too. To be clear, these are benefits. No one disputes that. It’s how markets work.

But markets also fail in a very important way. The bystanders who are breathing the polluted air are paying dearly. The costs, if you will, are socialized. Society—all of us—pays for them. That includes those who seemingly benefit from burning coal in the first place.

Your claim that what you call “social benefits” of coal dwarf the costs is wrong in theory and practice. In theory, because they are private benefits. As a matter of practice because these (private) benefits are very much included in the calculations that give us the social costs of coal. What you call out as the social benefits of coal use are already captured by these calculations. They are part of economic output.

Our indicators for GDP do a pretty good job capturing all these private benefits of economic activity. Where they fail is with the social costs. Hence the need to calculate the social cost of carbon pollution in the first place.

So far so bad. Then there’s this:

Plants need carbon dioxide to grow, just not too much of it

In your report, you also discuss what you call the benefits of increases in agricultural yields from the well-known carbon dioxide fertilization effect. It may surprise you to hear that the models used to calculate the cost of carbon include that effect. It turns out, they, too, in part base it on outdated science that ought to be updated.

But their science still isn’t as old as yours. For some reason, you only chose to include papers on the fertilization effect published between 1902 and 1997 (save one that is tangentially related).

For an updated perspective, try one of the most comprehensive economic analysis to date, pointing to large aggregate losses. Or try this Science article, casting serious doubt on any claims that carbon dioxide fertilization could offset the impacts on agricultural yields from climate change.

Farmers and ranchers already have a lot to endure from the effects of climate change. There’s no need to make it worse with false, outdated promises.

Coal lobby speaks, industry no longer listens

It’s for all these reasons that, to borrow the apt title to the otherwise excellent New York Times story that ran your quote: “Industry Awakens to Threat of Climate Change”. And it’s precisely why the U.S. government calculates the social cost of carbon pollution. Yes, sadly, it’s a cost, not a benefit.

To our readers: Want to get involved? The White House has issued a formal call for public comments on the way the cost of carbon figure is calculated, open throughFebruary 26. You can help by reminding our leaders in Washington that we need strong, science-based climate policies.

Also posted in Economics, Greenhouse Gas Emissions, Science| Read 1 Response

Why the cost of carbon pollution is both too high and too low

(This post originally appeared on EDF Voices)

Tell someone you are a “climate economist,” and the first thing you hear after the slightly puzzled looks subside is, “How much?” Show me the money: “How much is climate change really costing us?”

Here it is: at least $40.

That, of course, isn’t the total cost, which is in the trillions of dollars. $40 is the cost per ton of carbon dioxide pollution emitted today, and represents the financial impacts of everything climate change wreaks: higher medical bills, lost productivity at work, rising seas, and more. Every American, all 300 million of us, emit around twenty of these $40-tons per year.

The number comes from none other than the U.S. government in an effort to uncover the true cost of carbon pollution. This exercise was first conducted in 2010. It involved a dozen government agencies and departments, several dozen experts, and a fifty-page, densely crafted “technical support document,” replete with some seventy, peer-reviewed references and an even more technical appendix.

Cass Sunstein, the Harvard legal scholar of Nudge fame, who was co-leading the process for the White House at the time, recently declared himself positively surprised how the usual interest-group politics were all-but absent from the discussions throughout that process. This is how science should be done to help guide public policy.

The cost of carbon pollution is too low

The number originally reached in 2010 wasn’t $40. It was a bit more than half as much. What happened? In short, the scientific understanding of the impacts of rising seas had advanced by so much, and the peer-reviewed, economic models had finally caught up to the scientific understanding circa 2007, that a routine update of the cost of carbon number resulted in the rather dramatic increase to near $40 per ton. (There are twenty pages of additional scientific prose, if you want to know the details.)

In other words, we had been seriously underestimating the cost of climate change all along. That’s the exact opposite of what you hear from those who want to ignore the problem, and the $40 itself is still woefully conservative. Some large companies, including the likes of Exxon, are voluntarily using a higher price internally for their capital investment decisions.

And everything we know about the science points to the fact that the $40 figure has nowhere to go but up. The more we know, the higher the costs. And even what we don’t knowpushes the costs higher still.

Howard Shelanski, Sunstein’s successor as the administrator of the Office of Information and Regulatory Affairs (OIRA, pronounced “oh-eye-ruh”), has since presided over a further update of the official number. In fact, this one didn’t incorporate any of the latest science. It was simply a minor technical correction of the prior update, resulting in a $1 revision downward. (The precise number is now $37, though I still say $40 at cocktail parties, to avoid a false sense of precision. Yes, that’s what a climate economist talks about at cocktail parties.)

And once again, it all demonstrated just how science ought to be done: Sometimes it advances because newer and better, peer-reviewed publications become available. Sometimes it advances because someone discovers and fixes a small mathematical error.

Your input is needed

While announcing the correction, Shelanski added another layer of transparency and an opportunity for further refinements of the numbers: a formal call for public comments on the way the cost of carbon figure is calculated, open through January 27 February 26th.

We are taking this opportunity seriously. EDF, together with our partners at the Natural Resource Defense Council, New York University School of Law’s Institute for Policy Integrity, and the Union of Concerned Scientists, is submitting formal, technical comments in support of the administration’s use of the cost of carbon pollution number as well as recommending further revisions to reflect the latest science.

The bottom line, as economists like to put it, is that carbon pollution costs society a lot of money. So as the technical experts trade scientific papers, you can help by reminding our leaders in Washington that we need strong, science-based climate policies.

Update (on January 24th): The official comment period just was extended for another month, through February 26th. More time to show your support.

Also posted in Economics, Greenhouse Gas Emissions, Science| Read 1 Response
  • About this blog

    Expert to expert commentary on the science, law and economics of climate change.

  • Categories

  • Get blog posts by email

    Subscribe via RSS

  • Meet The Bloggers

    Tomás CarbonellTomás Carbonell
    Attorney

    Nat KeohaneNat Keohane
    Vice President for International Climate

    Ilissa Ocko
    High Meadows Fellow, Office of Chief Scientist

    Peter Zalzal
    Staff Attorney

    Gernot Wagner
    Senior Economist

    Graham McCahan
    Attorney

    Mandy Warner
    Climate & Air Policy Specialist

    Pamela Campos
    Attorney

    Kritee
    High Meadows Scientist