Climate 411

A First Look at the Clean Power Plan: Protecting Public Health and Cutting Carbon Pollution

Source: Flickr/ Rupert Ganzer

Source: Flickr/Rupert Ganzer

Earlier this week, our nation took a ground-breaking step by proposing to finally establish carbon pollution limits on existing power plants — the single largest source of climate-destabilizing pollution in the U.S. and one of the largest in the world.

We have national limits on the other air pollutants emitted by these plants, including mercury and arsenic and smog-forming pollutants — and we urgently need to secure strong limits on carbon pollution.

Here’s a first look at the proposed Clean Power Plan and its “building blocks” — the opportunity for state leadership, the profound public health benefits for our communities and families, and the good news about cost savings for customers.

The Proposed Pollution Reductions

The Clean Power Plan would reduce carbon pollution from existing fossil fuel-fired power plants by approximately 30 percent by 2030, and could curb emissions by as much as 27 percent by 2020.

EPA looked at the existing power plants in each state, and evaluated four time-tested, cost-effective emission reduction pathways:

  1. The potential to improve power plant efficiency
  2. The potential to rely more on lower-emitting power plants such as combined cycle natural gas and less on higher-emitting power plants
  3. The potential to deploy zero emitting generation resources like wind and solar
  4. The potential to capture end-use energy efficiency opportunities.

EPA then added up these four “building blocks” to calculate the reduction that a State could achieve on average in its overall emission rate over 2020-2029 (the “interim” target), and what rate could be achieved in 2030:

 

State

2012 Emission Rate
(Fossil, Renewable, and 6% Nuclear) (lbs/MWh)

2020-2029 Interim Goal (lbs/MWh)

2030 State Goal (lbs/MWh)

Percent change from 2012 rate

Alabama

1,444

1,147

1,059

-27%

Alaska

1,351

1,097

1,003

-26%

Arizona

1,453

735

702

-52%

Arkansas

1,640

968

910

-45%

California

698

556

537

-23%

Colorado

1,714

1,159

1,108

-35%

Connecticut

765

597

540

-29%

Delaware

1,234

913

841

-32%

Florida

1,200

794

740

-38%

Georgia

1,500

891

834

-44%

Hawaii

1,540

1,378

1,306

-15%

Idaho

339

244

228

-33%

Illinois

1,895

1,366

1,271

-33%

Indiana

1,923

1,607

1,531

-20%

Iowa

1,552

1,341

1,301

-16%

Kansas

1,940

1,578

1,499

-23%

Kentucky

2,158

1,844

1,763

-18%

Louisiana

1,466

948

883

-40%

Maine

437

393

378

-14%

Maryland

1,870

1,347

1,187

-37%

Massachusetts

925

655

576

-38%

Michigan

1,696

1,227

1,161

-32%

Minnesota

1,470

911

873

-41%

Mississippi

1,130

732

692

-39%

Missouri

1,963

1,621

1,544

-21%

Montana

2,245

1,882

1,771

-21%

Nebraska

2,009

1,596

1,479

-26%

Nevada

988

697

647

-34%

New Hampshire

905

546

486

-46%

New Jersey

932

647

531

-43%

New Mexico

1,586

1,107

1,048

-34%

New York

983

635

549

-44%

North Carolina

1,646

1,077

992

-40%

North Dakota

1,994

1,817

1,783

-11%

Ohio

1,850

1,452

1,338

-28%

Oklahoma

1,387

931

895

-35%

Oregon

717

407

372

-48%

Pennsylvania

1,540

1,179

1,052

-32%

Rhode Island

907

822

782

-14%

South Carolina

1,587

840

772

-51%

South Dakota

1,135

800

741

-35%

Tennessee

1,903

1,254

1,163

-39%

Texas

1,298

853

791

-39%

Utah

1,813

1,378

1,322

-27%

Virginia

1,297

884

810

-38%

Washington

763

264

215

-72%

West Virginia

2,019

1,748

1,620

-20%

Wisconsin

1,827

1,281

1,203

-34%

Wyoming

2,115

1,808

1,714

-19%

State Flexibility & Innovation

Under the Clean Power Plan, states will control their own future.

States have the flexibility to deploy the emission reduction policies and pathways that make the most sense for them, maximizing cost-effectiveness and co-benefits for their citizens, so long as they achieved the required emission reductions.

Some states might choose to build their compliance plans around existing Renewable Energy Standards and energy efficiency programs. Others might choose to put in place an emission reduction trading program between power plants. Still others might choose to collaborate with other states to submit joint plans and capture the cost-effective emission reduction opportunities available across state boundaries.

Public Health Benefits

The public health benefits of the Clean Power Plan are extensive and will help ensure healthier and longer for our loved ones who suffer from heart and lung ailments, and for our children.

EPA’s analysis shows that the reductions in carbon pollution and the associated reductions in sulfur dioxide, oxides of nitrogen, and particulate matter that will happen as a result will generate health benefits of $55 to $93 billion per year in 2030.

The pollutants that contribute to the soot and smog that make people sick will be reduced by more than 25 percent in 2030 — avoiding 2,700 to 6,600 premature deaths and 140,000 to 150,000 asthma attacks per year.

From the soot and smog reductions alone — ignoring the important reductions in carbon pollution achieved — Americans will see 7 dollars in health benefits for every dollar invested through the Clean Power Plan.

Cleaner power will ensure healthier and longer lives for millions of Americans.

Electricity Rates & Reliability

EPA’s analysis also shows that there will be sufficient power generation capacity across the United States under this framework to meet demand.

The flexibility provided to States will allow them to design plans to secure reductions in carbon pollution without any risk to power reliability.  As has been true for the past 40 years, we will reduce air pollution and maintain reliable power.

Because the Clean Power Plan will spur investments in demand-side energy efficiency, in 2030 electricity bills are expected to be 8 percent lower than they would have been without the plan.

Under the Clean Power Plan we will have cleaner, safer power, lower electricity bills, cleaner air, and healthier lives.

Cleaner power for a stronger America.

Posted in Clean Air Act, Clean Power Plan, Energy, Greenhouse Gas Emissions| 2 Responses, comments now closed

Power plant rule a tipping point for clean energy economy

By Cheryl Roberto, Associate Vice President, Clean Energy Program

For those of us (and all of you) who’ve been urging the government to implement meaningful climate policy, the release yesterday of a plan to cut carbon emissions from power plants has been a long time coming. But it finally came.

The U.S. Environmental Protection Agency’s proposed carbon pollution rule for existing fossil-fueled power plants – also known as the Clean Power Plan – are a huge win for our climate.

We also think it could go down in history as the tipping point in our nation’s transition to a clean energy economy. Here’s why:

Old, dirty power plants will be retired

The nation’s fleet of coal-fired power plants is the single largest source of carbon pollution in the U.S. and one of the largest in the world. Placing carbon regulations on this source of electricity for the first time in history will transform our energy system.

Utilities have acknowledged that it doesn’t make economic sense to pour money into retrofitting and retaining older, less-reliable coal-fired power plants when they need to focus investments on newer and more reliable plants.

This means that many of the most highly-polluting coal-fired power plants that provide electricity to our homes and businesses today will be retired. It presents a unique opportunity for clean energy solutions to fill the gap in generating capacity.

It may be one of the largest market opportunities in history to drive…clean energy on a national level.

Increasing our use of homegrown, renewable power sources and investing in proven tools such as energy efficiency, smart grids and demand response (which compensates electricity customers for conserving energy) will help fill this gap while reducing our reliance on fossil fuels that pollute the environment and contribute to climate change.

States will lead the way

EPA’s approach provides clear guidance for what limits and metrics must be met, but leaves states the flexibility to design solutions to meet those requirements as they see fit. This will encourage all states (even those which do not embrace the climate challenge) to look at clean energy technology as an attractive option when they seek to comply with the law.

Federal limits on carbon pollution from existing power plants are exactly the clarity states need to lead us to clean, reliable and affordable energy for all Americans – now and in the future.

Entrepreneurs, investors ready to jump in

What’s more, the new EPA plan – once it's final – will give entrepreneurs, corporations and venture capitalists the market signal they need to go full steam ahead with low-carbon innovations. It may be one of the largest market opportunities in history to drive the development and implementation of clean energy on a national level.

At Environmental Defense Fund, we’re right in the middle of many of these promising solutions, working with state legislators and regulators to clear outdated rules that mire us in the past and discourages innovators.

Paving the way for a cleaner, healthier future

We’re working with financial institutions to develop new funding opportunities for clean energy investments that will help raise the estimated $10.5 trillion needed over the next two decades to transition our world to a clean energy economy.

We’re working with energy research pioneer Pecan Street Inc.in Austin, TX to test customer energy management solutions such as rooftop solar, home energy storage, learning thermostats and time-of-use energy pricing (which incentivizes people to use electricity during periods of low, or “off-peak” energy demand).

And we’re pushing to make energy efficiency a cornerstone of America’s energy policy.

It may not be as sexy as fuel cells and solar panels, butbuilding a more efficient energy system — from power plants to transmission lines to homes and buildings — is the most affordable and cleanest path forward.

The United States is expected to spend about $2 trillion over the next two decades to replace our outdated electric infrastructure. These new regulations are a step in the right direction toward ensuring that these investments are spent on our future and not entrenching us in our past.

EPA's proposed rule means good jobs, economic development and a healthier planet.

And as a pioneer at the forefront of this movement, EDF is determined to make sure we stay on track.

This blog first appeared on EDF Voices

Posted in Clean Air Act, Clean Power Plan, Energy, Green Jobs, Greenhouse Gas Emissions| 1 Response, comments now closed

Study: Climate change may push hurricanes farther north, south

A satellite image of Irene, a Category 1 hurricane, as it made landfall in North Carolina in August of 2011. Source: NASA/NOAA GOES project

The hurricane season of 2014 just kicked off, and with two devastating storms wreaking havoc along the northeastern United States coast over the last few years, it’s no wonder everyone’s on edge.

We’re concerned about hurricanes becoming more frequent and intense, and about the worsening storm surge caused by a rise in sea levels. But flying under the radar is a fourth link between hurricanes and climate change: how climate change affects the location of hurricanes.

new study led by researchers at the National Oceanic and Atmospheric Administration, the Massachusetts Institute of Technology and Princeton University found that hurricanes have been shifting pole-ward at a rate of 30 to 40 miles per decade over the last 30 years.

It means they are moving closer to major population centers such as Washington, New York and Boston.

The likely cause? Human-caused climate change.

The migration of hurricanes has “potentially profound consequences for life and property,” the authors of the study warn in an article published recently in the journal Nature.

Increasing hazard exposure and mortality risk from tropical cyclones may be compounded in coastal cities outside the tropics, while being offset at lower latitudes.”  

Linking climate change to hurricane location

This finding is an important advancement in scientists’ understanding of how climate change has already contributed to extreme weather events. Research shows that the rise in global temperatures already causes more warm days, heat waves, and heavy rainfall.

Detecting trends in hurricane activity has been difficult, however, due to inconsistent and often unreliable historical data.

To get around this data challenge, the scientists at NOAA, MIT and Princeton developed a new technique that relies on a dependable subset of the data, and which teases out natural events such as El Niño to detect a distinct relationship between hurricane activity and climate change.

Their conclusion: Hurricanes are drifting toward the poles most likely due to an expansion of the Hadley Cell, a permanent atmospheric circulation feature that carries heat from the tropics to the Earth’s temperate zones.

Scientific understanding is that the Hadley Cell expansion is a result of the increase in heat-trapping gases in the atmosphere from human activities. So as we continue to drive cars, generate electricity at fossil-fueled power plants, cut down trees, and farm – we are indirectly pushing hurricanes farther north and south.

The new study is groundbreaking not only because it uses a novel technique, but also because it links a hurricane trend to climate change.

What we know so far

So where are we today with hurricanes and climate change?

Scientists studying hurricanes:

  • Have found no observed trend in frequency
  • Have not been able to detect trends in intensity  and duration
  • Are confident that human-caused sea level rise is contributing to storm surge
  • Expect the frequency of intense storms to increase in the future
  • Have now detected a robust trend in location shifts that is likely due to human activity

This new research presented in Nature suggests that hurricanes are migrating toward the poles and may devastate densely populated coastal regions that had previously, for the most part, been spared such storms.

It’s yet another reason why we must act now to curb carbon pollution and limit climate change.

This post first appeared on EDF Voices

Posted in Basic Science of Global Warming, Clean Power Plan, Extreme Weather, Greenhouse Gas Emissions| 2 Responses, comments now closed

EPA Hands Over the Keys with Clean Power Plan, California Already on Cruise Control

EPA’s Clean Power Plan, proposed today, is a roadmap for cutting dangerous pollution from power plants, and as with any map, there are many roads to follow. For this journey, states are in the driver’s seat and can steer themselves in the direction most beneficial to their people and to the state’s economy, as long as they show EPA they are staying on the map and ultimately reaching the final destination.

As usual, California got off to a head start, explored the territory, blazed a lot of new trails, and left a number of clues on how states can transition to a lower carbon future, and California’s successes are one proven, potential model for other states to follow. The state’s legacy of clean energy and energy efficiency progress is a big reason the White House and EPA could roll out the most significant national climate change action in U.S. history.

Way back in the mid-1970s, when Governor Jerry Brown did his first tour of duty, California pioneered what remains one of the most effective tools for cutting pollution and saving money:  energy efficiency. The state’s efficiency standards, largely aimed at buildings and appliances, have saved Californians $74 billion and avoided the construction of more than 30 power plants. All those energy savings have translated into California residential electricity bills that are 25% lower than the national average.  What’s more, California produces twice as much economic output per kilowatt hour of electricity usage as the national average.

While energy efficiency has done yeoman’s work pulling costs down, reducing the need for dirty energy, and supercharging the state’s clean energy economy, California has also brought bold approaches to cleaning up its power supply. The California Renewable Portfolio Standard (RPS) requires 33% of all electricity sold in California to come from renewable sources by 2020, the most aggressive of the 29 states with RPS measures on the books.

In 2006, California enacted Senate Bill 1368, a groundbreaking law that set the nation’s first greenhouse gas emissions standard for power plants, a forerunner of EPA’s Clean Power Plan announced today. The same year, the Global Warming Solutions Act (AB 32) instituted a statewide limit on greenhouse gas emissions, requiring California to return to 1990 levels by 2020. Power plants are capped under AB 32’s successful cap-and-trade program, another precedent that set the table for EPA’s Clean Power Plan, which establishes a national limit on power plant pollution for the first time. This robust suite of policies resulted in California cutting carbon pollution from in-state and imported electricity by 16% between 2005 and 2010-2012.

Given this track record, it’s no surprise that Californians strongly support pollution limits on power plants. According to the Public Policy Institute of California (PPIC) 2013 survey, 76% of Californians support “stricter emissions limits on power plants,” and 65% of survey respondents say that California should act immediately to cut emissions and not wait for the economy to improve, a record-high level of support. The survey also shows that Californians believe the economy will improve because of strong environmental regulations, and that you don’t have to have one or the other. Data corroborating this view continues to pile up:  the state now has its lowest unemployment rate since 2008 even with increasingly stringent environmental policies.

California is proof positive that states can fashion creative policies that improve their environmental and economic bottom line, and that’s exactly what will be needed to make EPA’s Clean Power Plan a durable and resounding success. California’s roadmap includes a variety of alternative routes, giving other states a chance to adopt or adapt them to meet the needs of their own unique journeys toward a healthier future.

This post first appeared on our California Dream 2.0 blog.

Posted in Cars and Pollution, Clean Air Act, Clean Power Plan, Energy, Greenhouse Gas Emissions, News, Policy| 1 Response, comments now closed

New EPA rule for dirty power plants fuels strange debate

Coal-fired power plants are the single largest source of carbon pollution in the United States.

In the downside-up Alice in Wonderland world of Congress, we are about to begin a debate about whether unlimited pollution is a good thing.

It will be triggered by the Obama administration's historic announcement today that for the first time, America’s fossil-fueled power plants will not be allowed to release limitless amounts of carbon pollution – a policy that will improve the chances our children and grandchildren will have a safe and healthy future.

No one, of course, will stand up and say they love pollution.

But you're about to hear elected officials and industry lobbyists talk very loudly about the calamity that will occur if we impose any restriction at all on carbon pollution from power plants.

Learn how you can support carbon limits

Never mind that power plants are the largest source of this pollution, or that they cause major damage to our environment and our health. And don’t worry that up until now, there have been no national limits on them at all.

According to these folks, unless we allow companies to pollute as much as they want, we will face catastrophe.

Pollution is bad – period

The new rule from the U.S. Environmental Protection Agency would establish standards for carbon pollution from existing power plants, just as they have standards for soot and mercury and other pollutants. The rule is based on decades of science, and will be proposed under authority granted by Congress through the Clean Air Act.

More importantly, it’s based on two pieces of basic common sense:

  1. When there is no limit on pollution, you get a lot of pollution.
  2. Pollution is bad.

It doesn’t seem to reassure the unlimited pollution crowd that every past effort to reduce air pollution has resulted in a net benefit for our economy as well as for our health. In fact, the benefits of most EPA Clean Air Act rules outweigh the costs by 30 to 1.

But as reliably as a humid summer in Washington, critics of the law will wildly over-estimate the cost of complying with new pollution reduction rules.

The impacts of unlimited pollution are scary, as outlined in two recent scientific reports that outline the situation globallyand in the United States. Kids will have more asthma attacks, storms will be more destructive, drought more severe, and lots of other dangerous problems.

Compare that future to one in which we have reasonable limits on carbon pollution. They won’t solve all of our problems, but they are a significant step forward. The new EPA rule will kick-start a transition to a clean-energy and low-carbon future, which will lead to economic and health benefits for everyone.

So next time someone tells you that limits on carbon emissions are a bad idea, ask if he (or she) thinks unlimited pollution is a responsible policy – and watch the person change the subject in a hurry.

It’s how these conversations usually end.

This blog first appeared on EDF Voices

Posted in Cars and Pollution, Clean Air Act, Clean Power Plan, Energy, Greenhouse Gas Emissions| Comments closed

The Supreme Court Has Been Clear – EPA Has Authority to Address Carbon Pollution from Power Plants

(This post was written by EDF General Counsel Vickie Patton and EDF Senior Attorney Peter Zalzal)

This upcoming Monday, June 2nd, the Environmental Protection Agency (EPA) will announce proposed standards to reduce harmful, climate-destabilizing carbon pollution from our nation’s fleet of existing fossil fuel fired power plants.

EPA has clear authority to address this harmful pollution, authority that is manifest in our nation’s clean air laws, that has been confirmed time and again by the United States Supreme Court, and that has been recognized even by those who continue to obstruct climate progress in the courts.  And the agency has a responsibility to exercise that authority through science-based actions to address climate pollution in a way that protects public health and welfare.

In Massachusetts v. EPA, the U.S. Supreme Court held that EPA had clear authority under the Clean Air Act to address Greenhouse Gas emissions:

[b]ecause greenhouse gases fit well within the Act's capacious definition of ‘air pollutant.’

             549 U.S. 497, 532 (2007)

The Court continued:

The Clean Air Act's sweeping definition of “air pollutant” includes “any air pollution agent or combination of such agents, including any physical, chemical . . . substance or matter which is emitted into or otherwise enters the ambient air . . . . " § 7602(g) (emphasis added). On its face, the definition embraces all airborne compounds of whatever stripe, and underscores that intent through the repeated use of the word "any." Carbon dioxide, methane, nitrous oxide, and hydrofluorocarbons are without a doubt "physical [and] chemical  . . . substance[s] which [are] emitted into . . . the ambient air."  The statute is unambiguous.

             Id. at 528-29 

The Court emphasized that EPA’s responsibility to exercise this authority was grounded in science and the agency’s duty to protect public health and welfare.  In rejecting various policy reasons for inactions, the Court concluded that EPA must move forward with standards if it found climate pollution endangered human health and welfare, noting that:

[T]here is nothing counterintuitive to the notion that EPA can curtail the emission of substances that are putting the global climate out of kilter.

             Id. at 531

In 2011, the Supreme Court directly addressed EPA’s authority to establish carbon pollution standards for existing power plants under Section 111(d) of the Clean Air Act – the foundational provisions for Monday’s announcement.

In American Electric Power Co. v. Connecticut, the Court found:

And we think it equally plain that the Act “speaks directly” to emissions of carbon dioxide from the defendants’ plants.

Section 111 of the Act directs the EPA Administrator to list “categories of stationary sources” that “in [her] judgment . . . caus[e], or contribut[e] significantly to, air pollution which may reasonably be anticipated to endanger public health or welfare.” §7411(b)(1)(A). Once EPA lists a category, the agency must establish standards of performance for emission of pollutants from new or modified sources within that category. §7411(b)(1)(B); see also§7411(a)(2). And, most relevant here, §7411(d) then requires regulation of existing sources within the same category.7 For existing sources, EPA issues emissions guidelines, see 40 C. F. R. §60.22, .23 (2009); in compliance with those guidelines and subject to federal oversight, the States then issue performance standards for stationary sources within their jurisdiction, §7411(d)(1).

             131 S. Ct. 2527, 2537 (2011) 

Our nation’s highest court, then, has twice affirmed EPA’s authority to address climate destabilizing pollution from the power sector.  First, in Massachusetts, by confirming that greenhouse gases fall squarely within the Clean Air Act’s definition of “air pollutant,” and then again in American Electric Power, where the Court found that the Clean Air Act authorizes EPA to address carbon pollution from existing power plants using the precise provision that is basis for EPA’s action this Monday.

EPA’s authority in this area is so unequivocal that, in an oral argument before the Supreme Court in a recent case concerning a distinct, separate climate program, the attorney arguing for industry challengers conceded:

I think most critically, Your Honor, [EPA’s authority] includes the new source performance standards program of Section 111 that this Court discussed in Connecticut v. AEP. And this is a very important point, because this case is not about whether EPA can regulate greenhouse gases from stationary sources. This Court held that it could under this program in Section 11 [sic].

            (see Supreme Court transcript page 22).

EPA has determined that six greenhouse gases – carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride – endanger the health and welfare of current and future generations.  And this determination has been upheld by the U.S. Court of Appeals for the D.C. Circuit and the Supreme Court declined to review it – meaning it is firmly the law of the land.

This endangerment determination along with EPA’s manifest authority under the Clean Air Act to address greenhouse gas emissions – twice affirmed by the Supreme Court – form an unshakeable legal foundation for EPA’s action to cut carbon pollution from power plants,  the nation’s single largest source of carbon pollution and one of the largest in the world.

Moving forward swiftly to address climate pollution could not be more urgent to protect the health of our communities and families.

Posted in Clean Power Plan, News| 4 Responses, comments now closed

Why you only get 25% of the electricity you pay for

By Ronny Sandoval

What would you say if I told you that about three-quarters of what you spend on electricity every month is wasted? Considering that Americans spend about $350 billion on electricity annually, I hope you’ll find this as shocking as I do.

From generation to delivery to consumption, inefficiencies at every step of electricity’s journey add up to a lot of waste. Fortunately, these same conditions present us with opportunities to substantially reduce inefficiencies and their associated economic, social, and environmental impacts.

Generation: Energy is wasted at the source

Today, the majority of the electricity produced in the United States originates from fossil fuels, including coal and natural gas. According to the United States Environmental Protection Agency, these plants are only about 33 percent efficient, and “two-thirds of the energy in the fuel is lost — vented as heat — at most power plants in the United States.”

There are limits to what can be done to address this problem as this loss is largely due to the thermal process of large power plants, since heat is a by-product of this sort of generation and it has to be released somehow.

Some plants, however, achieve higher efficiencies by capturing wasted heat energy and putting it to meaningful work, raising the total efficiency to somewhere within the 60-80 percent (or greater) range.

One example of this kind of technology is combined heat and power, which burns a fossil-fuel like natural gas to make electricity, but reroutes the heat generated as a by-product (often vented out of the chimney stack) back to the customer’s premise and used to heat hot water or a space.

Today, this technology is mostly limited to large buildings or complexes, but it has proven to be very successful in places such as New York City, where these types of structures are prevalent.

Delivery: Energy is lost en route to homes and businesses

Adding to our energy loss, another seven percent of the electricity that’s ultimately generated is later lost in the delivery path to homes and businesses.

Available and emerging technologies show us it doesn’t have to be this way. “Voltage optimization’” technologies and strategies, for example, can lower the amount of energy lost in the delivery process while also reducing the associated environmental impacts.

Consumption: Old appliances, bad habits = a little more waste

Try to think of all the old and inefficient appliances and equipment that use more electricity than is necessary. For example, incandescent (traditional) light bulbs can use four times as much electricity as energy-efficient compact fluorescent bulbs. Most of the energy these traditional bulbs use generates heat, not light.

Similarly, inefficient refrigerators can use 15 percent more electricity (or much more depending on the age) than efficient alternatives.

Now, also think of all the things that are simply left on or running that don’t have to be (lights, computers, TVs, phone chargers, etc.) and you really start to get a picture of the amount of inefficiency based on our ingrained habits of consumption.

Smart solutions

But don’t be discouraged! Abundant and cost-effective energy efficiency opportunities mean we can reduce this waste – and ultimately pollution. By simply improving the way we use energy at home and at work we can realize big energy savings across the whole electricity supply chain.

When an unused appliance is powered off, the electric system doesn’t just save on the energy the appliance would have used, it also avoids all the extra energy (and greenhouse gas emissions) the system would have generated to compensate for its inefficiencies.

Fortunately, more and more solutions (such as “smart’ thermostats” and “smart” power strips) are providing consumers with the tools to automate and maximize energy savings at home.

Commercial buildings can also benefit from these intelligent energy control devices by implementing operating schedules, occupancy sensors, and other forms of building automation to ensure that lighting or heating and cooling systems aren’t running when not needed.

Abundant and cost-effective energy efficiency opportunities mean we can reduce this waste.

Collectively, we can improve this part of the supply chain through an increasing variety of actions – such as using more efficient appliances, energy conservation, and the automation of energy use.

A rare opportunity

I think it’s safe to say that most Americans would like to see more bang for their electricity buck, but the argument for efficiency is not just a financial one. Energy efficiency has the added benefit of protecting our finite natural resources and reducing harmful, greenhouse gas emissions that affect our health.

Much of the inefficiencies in the electric system are a product of decisions made along the supply chain and the policies and incentives that drive them.

The U.S. is expected to spend about $2 trillion over the next two decades to replace our aging, inefficient and polluting energy infrastructure. This presents a once-in-a-generation opportunity to revolutionize how we make, move, manage, and use electricity.

It's an opportunity we cannot afford to waste, the way we've been wasting so much electricity.

This blog originally appeared on EDF Voices

Posted in Clean Power Plan, Energy, Greenhouse Gas Emissions, Policy| 4 Responses, comments now closed

Section 111(d) of the Clean Air Act — Cooperative Federalism and Performance-Based Standards

dv067014One year ago this June, President Obama directed the Environmental Protection Agency (EPA) to develop Carbon Pollution Standards for existing power plants — a key component of his Climate Action Plan.

The President charged EPA with launching the effort "through direct engagement with States, as they will play a central role in establishing and implementing standards for existing power plants."

Congress laid the groundwork for this dynamic federal-state collaboration in 1970 when it provided for national environmental performance standards for sectors that are major sources of dangerous air pollution.

Under this program  (Section 111(d) of the Clean Air Act) EPA identifies the "best system of emission reduction" available to address dangerous air pollution from existing pollution sources through performance standards, adopted after public notice and comment, called "emission guidelines." 1

EPA quantifies the emission reductions that can be achieved using this "best system" — and that becomes the performance benchmark for state plans which implement and enforce standards of performance for the existing sources of pollution in each state. 2

Congress provided for state plans to be submitted to EPA to evaluate whether the plan provides for emission reductions that are equivalent to or greater than those under the "best system." 3 Congress made clear that states are not required to use the particular system identified by EPA — they have the flexibility to use other systems, tailored to their state, so long as they achieve an equivalent or greater level of pollution reduction.

Under the timeline set out by President Obama, EPA will propose guidelines for emissions from existing power plants at the beginning of June, and finalize them by June 2015.

Consistent with the long-standing implementation timetable under this Clean Air Act program, states will submit their plans to implement and enforce standards by the end of June 2016.

Section 111(d) standards have long been effective in addressing dangerous air pollution from a variety of source categories and can be designed to provide a flexible and cost-effective framework for reducing carbon pollution from power plants.

For decades, section 111(d) has provided the foundation for pollution cuts from major sources of air pollution. Toward the end of the 1970s, EPA and the states put section 111(d) to work, publishing and implementing emission guidelines for fluorides from phosphate fertilizer plants (1977),4 sulfuric acid mist from sulfuric acid plants (1977),5 sulfur from kraft pulp mills (1979),6 and fluoride from primary aluminum plants (1980).7

These emissions guidelines and the state-devised standards implementing them would achieve dramatic reductions of harmful air pollutants, eliminating 75 percent of overall nationwide fluoride emissions from phosphate fertilizer plants,8 almost 80 percent of sulfuric acid emissions from an uncontrolled sulfuric acid plant,9 82 percent of overall nationwide total reduced sulfur from kraft pulp mills,10 and up to 78 percent of fluoride emissions from the primary aluminum industry.11

The pollution from fossil fueled power plants, one of the single largest sources of dangerous air pollution in our nation, has been subject of clean air standards under section 111 since the advent of the modern Clean Air Act in 1970.12 National standards of performance under section 111 have applied to newly constructed power plants and existing plants that are revamped and reconstructed.

The flexibility that the Clean Air Act provides in establishing and implementing standards of performance for existing sources under section 111(d) is well suited for the regulation of carbon pollution from fossil fuel power plants.

Congress created a framework under section 111(d) to address pollution from existing power plants that can be flexible and expansive in scope where such a framework could be more effective in addressing emissions.

The statutory language — "best system of emission reduction" — is broad, and not defined in the statute. The ordinary meaning of the word is expansive — "a complex unity formed of many often diverse parts subject to a common plan or serving a common purpose."13 Throughout the Clean Air Act, Congress has used the word "system" to describe innovative, flexible regulatory approaches such as the acid rain emissions cap and allowance trading program, and marketable permits.14

Indeed, the legislative history of the section over the years is consonant with this broad reading of the term "system," especially for section 111(d).

When Congress amended the Clean Air Act in 1977, it altered the definition of "standard of performance" as applied to new sources in order to require new sources to deploy the "best technological system" of emission reduction. But, pointedly, it left the corresponding definition for existing sources intact15 and even explicitly confirmed that "systems" of emission reduction for existing sources were "not necessarily technological."16

In 1990, Congress abandoned this special limitation for new sources and reverted to the broad, unified definition of section 111 "standards of performance" for both new and existing sources.17

Thus, EPA can deploy a systemic approach to reducing carbon pollution from power plants, looking beyond each individual source in isolation to find the "best," most cost-effective system for reducing pollution.

It has done so several times before. In the 1995 emission guidelines for municipal waste combustors, EPA authorized states to create averaging and trading programs in reducing emissions of nitrogen oxides.18

In the context of greenhouse gas emissions, which do not have local effects, an averaging approach allows cost-effective emission reduction opportunities to be captured while rigorous overall emission reduction targets are achieved.

Not only may EPA allow averaging of emissions among existing sources as part of the "best system of emission reduction," but it can also consider pollution-reduction measures that are implemented beyond the source and secure reductions in emissions at the source.

For example, in the 1997 emission guidelines for hospital/medical/infectious waste incinerators, EPA required state plans to include waste management plans, where feasible, to eliminate part of the waste stream going to the incinerator that would produce harmful emissions.19 In that context, part of the "best system of emission reduction" involved measures taken well outside of the source’s boundaries that could reduce harmful emissions from the sources.

EPA could take a similar approach to address carbon pollution from existing power plants — as deploying demand side energy efficiency and renewable energy can be some of the most effective means of reducing harmful emissions from existing plants while capturing the greatest co-benefits in cutting utility bills, creating jobs, making state economies less dependent on price fluctuations in fossil fuels, and stimulating local economies.

States have extensive experience in implementing emission guidelines and other system-wide approaches under the Clean Air Act, and are well positioned for developing and implementing plans to address carbon pollution from existing power plants under Section 111(d).

The next two parts of this series will look at the impressive achievements of states and power companies across the country in in cutting carbon pollution through flexible, cost-effective, demonstrated policies that are reducing utilization of high-emitting plants, expanding renewable energy capacity, and improving the efficiency with which we use energy.

Through the dynamic state-federal collaboration provided by section 111(d), the Carbon Pollution Standards for existing power plants will build on this foundation and help us make further progress along the path toward a cleaner, safer energy future.

  1. 40 C.F.R. § 60.22(b)
  2. Id. § 60.24.
  3. Id.; 42 U.S.C. § 7411(a); id. § 7411(d)(2).
  4. Phosphate Fertilizer Plants, Final Guideline Document Availability, 42 Fed. Reg. 12,022 (Mar. 1, 1977).
  5. Emission Guideline for Sulfuric Acid Mist, 42 Fed. Reg. 55,796 (Oct. 18, 1977).
  6. Kraft Pulp Mills; Final Guideline Document; Availability, 44 Fed. Reg. 29,828 (May 22, 1979).
  7. Primary Aluminum Plants; Availability of Final Guideline Document, 45 Fed. Reg. 26,294 (Apr. 17, 1980).
  8. Final Guideline Document: Control of Fluoride Emissions from Existing Phosphate Fertilizer Plants, Doc. No. EPA-450/2-77-005, at 1-7 (Mar. 1977).
  9. Final Guideline Document: Control of Sulfuric Acid Mist Emissions from Existing Sulfuric Acid Production Units, Doc. No. EPA-450/2-77-019, at 8-2 (Sept. 1977).
  10. Kraft Pulping, "Control of TRS Emissions from Existing Mills," Doc. No. EPA-450/2-78-003b, at 1-6 (Mar. 1979).
  11. Primary Aluminum: Guidelines for Control of Fluoride Emissions from Existing Primary Aluminum Plants, Doc. No. EPA-450/2-78-049b, at 125 tbl. 1-7 (Dec. 1979).
  12. Standards of Performance for New Stationary Sources, 36 Fed. Reg. 24,876 (Dec. 23, 1971).
  13. Webster’s Third New International Dictionary 2322 (1967).
  14. 42 U.S.C. § 7511a(g)(4)(A); id. § 7651b; id. § 7651c.
  15. Clean Air Act Amendments of 1977, Pub. L. No. 95-95, § 109(c)(1)(A), 91 Stat. 685, 699-700.
  16. H.R. Rep. No. 95-564, at 129 (1977) (Conf. Rep.).
  17. Clean Air Act Amendments of 1990, Pub. L. No. 101-549, § 403(a), 104 Stat. 2399, 2631.
  18. 40 C.F.R § 60.33b(d)(2).
  19. Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Hospital/Medical/Infectious Waste Incinerators, 62 Fed. Reg. 48,348, 48,359 (Sept. 15, 1997) (codified at 40 C.F.R. §§ 60.35e, 60.55c).

Posted in Clean Power Plan, Greenhouse Gas Emissions, Policy| 1 Response, comments now closed

Soot Pollution Limits Unanimously Upheld in Court, Continuing Clean Air Victory Streak

Last week, the U.S. Court of Appeals for the D.C. Circuit unanimously upheld the Environmental Protection Agency’s (EPA’s) particulate matter (soot) pollution standard, ruling that EPA’s decision to strengthen the standard in 2012 was firmly grounded in science and the law. The ruling also upheld EPA’s new requirement that states install air quality monitors near heavy traffic roads, where soot pollution levels can spike. The court’s decision is the latest in a string of legal victories for critical health protections on air pollution.

When fossil fuels are burned in an automobile or power plant, they release soot pollution, very fine, ashy particles less than one tenth the width of a human hair. These particles are so small that the air can carry them for long distances. When inhaled, soot particles penetrate deep into the lungs, where they can cross into the bloodstream via the path normally taken by inhaled oxygen. Exposure to soot pollution can inflame and alter our blood vessels, cutting off the oxygen supply to our heart and brain, leading to a heart attack, stroke, or other serious cardiac event.

The Clean Air Act mandates that EPA revisit its standards on criteria air pollutants – like soot – every five years, so that clean air standards can keep pace with the latest understanding of health science. Since EPA established its 2006 soot standard, hundreds of scientific studies have shown that particle pollution could cause adverse health effects—even in cities that met EPA’s established limits. Based on this information, in 2012, EPA strengthened its soot pollution standard to protect public health. Furthermore, EPA called for states to implement roadside air quality monitors to ensure the standards would likewise protect individuals exposed to significant near-road emissions.

The National Association of Manufacturers and the Utility Air Resources group, a coalition of large power companies and coal companies, filed legal challenges to EPA’s new soot standards, arguing that the 2006 standard was sufficient to protect public health. But the science doesn’t lie. In the D.C. Circuit Court’s unanimous decision, Judge Brett Kavanaugh wrote:

Here, we can be brief: Petitioners have not identified any way in which EPA jumped the rails of reasonableness in examining the science. EPA offered reasoned explanations for how it approached and weighed the evidence, and why the scientific evidence supported revision of the National Ambient Air Quality Standards.

EPA was reasonable in their interpretation of the science—the polluting companies, on the other hand, could not present a credible argument against the updated soot pollution standards, or the need for roadside air quality monitors.

This important victory is critical to protect our families and communities from harmful soot pollution, and it is clear that EPA’s implementation of the Clean Air Act stands up to both legal and scientific scrutiny.

This post was adapted from EDF’s Texas Clean Air Matters Blog

Posted in Cars and Pollution, Clean Air Act, Health| 3 Responses, comments now closed

The Many Benefits of Reducing Carbon Pollution from Existing Power Plants

(This post was written by EDF attorney Megan Ceronsky and legal fellow Peter Heisler)

The newly-released Third National Climate Assessment has some eye-opening news about climate change.

The report confirms that if greenhouse gas emissions are not reduced it is likely that American communities will experience:

  • increased severity of dangerous smog and particulate pollution in many regions[1]
  • intensified precipitation events, hurricanes, and storm surges[2]
  • reduced precipitation and runoff in the arid West[3]
  • reduced crop yields and livestock productivity[4]
  • increases in fires, insect pests, and the prevalence of diseases transmitted by food, water, and insects[5]
  • increased risk of illness and death due to extreme heat[6]

Source: Flickr/Eric Schmuttenmaer

Extreme weather imposes a high cost on our communities, our livelihoods, and our lives.  The National Climatic Data Center reports that the United States experienced seven climate disasters that each caused more than a billion dollars of damage in 2013, including the devastating floods in Colorado and extreme droughts in western states.[7]

These are precisely the type of impacts projected to affect American communities with increasing frequency and severity as climate-destabilizing emissions continue to accumulate in the atmosphere.

Fossil fuel-fired power plants are far and away the largest source of greenhouse gas emissions in the United States, emitting more than two billion metric tons of carbon dioxide in 2012 — equivalent to 40 percent of U.S. carbon pollution and nearly one-third of total U.S. greenhouse gas emissions.[8]

Yet there are currently no legal limits on the amount of carbon dioxide power plants can release into the atmosphere.

This June, the Environmental Protection Agency (EPA) will, at long last, propose Carbon Pollution Standards for existing power plants.

The solutions we need to achieve significant reductions of carbon pollution from our nation’s largest source are at hand — including changes at existing power plants to reduce emissions, shifting utilization towards lower-polluting generation and away from higher-polluting generation, and deploying renewable energy and energy efficiency.

The health-improving, cost-saving, job-creating benefits of these proven techniques should be shouted from the rooftops.

States and power companies are already capitalizing on opportunities to reduce carbon pollution and other health-harming air pollutants by switching to lower-emitting generation.

Look, for example, at Colorado.

The Clean Air-Clean Jobs Act, which passed with bipartisan support and was signed by Governor Bill Ritter in 2010,[9] will significantly improve air quality while ensuring a reliable supply of electricity.

Under the Act, Xcel Energy plans to replace aging, high-emitting coal-fired units in the Denver metro area with lower-emitting resources, including state-of-the-art efficient combined-cycle natural gas plants that can quickly cycle to complement plentiful wind power and energy efficiency.[10] These changes will help Xcel reduce carbon dioxide emissions from its Colorado fleet by 28 percent by 2020 as well as[11] nitrogen oxide emissions by 86 percent, sulfur dioxide emissions by 83 percent, and mercury emissions by 82 percent.

Reducing emissions of these dangerous pollutants will save lives, reduce the number of nonfatal heart attacks, reduce cases of chronic bronchitis and asthma attacks, and avoid hospital admissions and emergency room visits.[12]

Xcel Energy expects that the projects will inject $590 million into the state’s economy and support 1,500 jobs.[13]

Colorado is also leading the way in renewable energy and energy efficiency.  The state’s renewable energy standard (RES) — which was put in place by a ballot initiative in 2004 — now requires investor-owned utilities to supply 30 percent, and municipal utilities and cooperatives to supply 10 percent, of their retail sales with renewable energy by 2020.[14]  Colorado’s energy efficiency resource standard (EERS) sets a goal for investor-owned utilities of 5 percent savings of 2006 peak demand by 2018 through demand-side management programs for their customers.[15]

The RES is expected to avoid 30 million tons of carbon dioxide emissions, create more than 30,000 jobs, and generate $4.3 billion in economic output.[16]

As for energy efficiency, in 2013 Xcel's demand-side management plan saved 384.2 gigawatt hours of electricity (exceeding the goal approved by the Public Utilities Commission)[17] and avoided more than 280,000 tons of carbon dioxide and close to 230,000 pounds of sulfur dioxide from electricity generation.[18]

Renewable energy has taken off in recent months and years, replacing higher-emitting sources of energy and creating jobs.  Between 2011 and 2013, wind generation in the United States increased by 40 percent,[19] and in January 2014, the United States had a record month for wind power with generation of nearly 18,000 gigawatt hours.[20]

Xcel Energy recently announced 700 megawatts of new wind energy in New Mexico, Oklahoma, and Texas, which it estimates will save customers up to $590 million in fuel costs.[21]  Xcel says it is adding wind capacity “purely on economics and the savings we can deliver to our customers,” as the price of energy from the new facilities will be less than that from the company’s natural gas-fired plants.[22]

Solar power is on the rise as well.  In 2012, rooftop solar panels cost approximately one percent of what they did 35 years ago,[23] and the cost of solar panels fell by 60 percent from 2011 to 2013.[24]  Since 2008, as the cost of a solar module dropped from $3.40 per watt to 80 cents per watt, solar deployment has jumped by about 10 times.[25]  In 2013 alone, solar photovoltaic installations increased by 41 percent, to a record 4.75 gigawatts, outpacing the industry’s own projections.[26]

Utilities and their customers are also seeing the advantages of solar energy. In March 2014, Austin Energy bought 150 megawatts of solar power at a price just below five cents per kilowatt hour — one of the lowest prices for solar yet which will likely lower rates.[27]  And solar produces high-quality jobs, too, with the industry employing about 143,000 Americans at the end of 2013 and surpassing growth expectations for that year.[28]

Along with renewables, energy efficiency will play a key role in reducing carbon pollution while at the same time saving businesses and families money on their energy bills and creating high-paying jobs.

A recent report by the American Council for an Energy-Efficient Economy lays out several policies that states could use to meet their carbon-reduction goals, including energy-efficiency targets, building codes, appliance standards, and new combined heat and power systems.[29]  If adopted, in the year 2030 these policies could:

  • reduce emissions of carbon dioxide by about 600 million tons, of sulfure dioxide by about 980,000 tons, and of nitrogen oxides by about 527,000 tons[30]
  • save 925 million megawatt hours of electricity in 2030,[31] avoiding about $48 billion in energy costs[32]
  • and support 611,000 jobs, creating 6.2 million job-years from 2016 to 2030.[33]

Energy efficiency not only offers a cost-effective way to reduce pollution and positively impact the economy, but also improves comfort and health, increases productivity, and cuts utility bills for homes and businesses, savings that can be spent on other goods and services.[34]

Several organizations have outlined approaches to reducing carbon pollution under the Clean Air Act, and their analysis shows that the Carbon Pollution Standards can protect the climate while at the same time reducing emissions of other dangerous air pollutants.  For example, NRDC estimates that its proposal would reduce harmful sulfur dioxide and nitrogen oxide emissions, saving thousands of lives, preventing 17,000 asthma attacks per year, and avoiding more than 1,000 emergency room visits and hospital admissions per year.[35]

Similar health benefits would be provided by Clean Air Task Force’s proposed framework, which would avoid 446,000 tons (31 percent) of sulfur dioxide and 402,000 tons of nitrogen oxide (24 percent) emissions relative to the base case by 2020.[36]

And Resources for the Future projects co-benefits from sulfur dioxide reductions ranging from $17 billion to $22 billion in 2010 dollars by 2020.[37]

Moving forward under the President’s Climate Action Plan to address carbon pollution from power plants couldn’t be more urgent.  In addition to the reductions in harmful air pollution discussed above, the National Climate Assessment explains that without abating climate change:

“Summers are longer and hotter, and extended periods of unusual heat last longer than any living American has ever experienced. Winters are generally shorter and warmer. Rain comes in heavier downpours. People are seeing changes in the length and severity of seasonal allergies, the plant varieties that thrive in their gardens, and the kinds of birds they see in any particular month in their neighborhoods.

“Other changes are even more dramatic. Residents of some coastal cities see their streets flood more regularly during storms and high tides. Inland cities near large rivers also experience more flooding, especially in the Midwest and Northeast. . . . Hotter and drier weather and earlier snowmelt mean that wildfires in the West start earlier in the spring, last later into the fall, and burn more acreage. . . .”

An upcoming blog will take a closer look at climate change and its impacts on public health in the U.S.  First, though, we will highlight some of the many successes states and power companies have had in deploying clean energy and energy efficiency, and explain the legal foundations for Carbon Pollution Standards that build on this experience and support the expansion of clean energy and energy efficiency programs.

These investments will not only cut emissions of carbon and other pollutants, but also provide homegrown energy, create jobs, and cut utility bills for American homes and businesses.  This is the right path forward for our communities, our kids, and our economy.


[1]  U.S. Global Change Research Program, Climate Change Impacts in the United States, at 222 (2014), available at http://nca2014.globalchange.gov/downloads.

[2]  Id. at 37, 42, 45.

[3]  Id. at 465.

[4]  Id. at 152, 157.

[5]  Id. at 223, 225-26.

[6]  Id. at 224.

[7]  National Climatic Data Center, Billion-Dollar U.S. Weather/Climate Disasters 1980-2013 (2014), available at www.ncdc.noaa.gov/billions/events.pdf.

[8] EPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012, at 2-4 tbl. 2-1 (Apr. 2014), available at http://www.epa.gov/climatechange/ghgemissions/usinventoryreport.html.

[9] Press Release, Bill Ritter: Colorado’s Governor, Gov. Ritter Signs Historic Clean Air-Clean Jobs Act (Apr. 19, 2010), http://www.colorado.gov/cs/Satellite%3Fc%3DPage&cid%3D1251573927379&p%3D1251573927379&pagename%3DGovRitter%252FGOVRLayout).

[10] Colorado Clean Air – Clean Jobs Plan, Xcel Energy, http://www.xcelenergy.com/Environment/Doing_Our_Part/Clean_Air_Projects/Colorado_Clean_Air_-_Clean_Jobs_Plan (last visited Apr. 11, 2014).

[11] Id.

[12] Answer Testimony of Leland B. Deck, Before the Pub. Utilities Comm’n of Colo., Docket No. 10M-245E (Sept. 17, 2010), available at https://www.dora.state.co.us/pls/efi/EFI_Search_UI.search.

[13] Id.

[14] Renewable Energy Standard, Database of State Incentives for Renewables & Efficiency, http://www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=CO24R&re=0&ee=0 (last visited May 3, 2014).

[15] Energy Efficiency Resource Standard,  Database of State Incentives for Renewables & Efficiency, http://www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=CO46R&re=0&ee=0 (last visited May 3, 2014).

[16] Jeff Lyng & Tom Plant, Governor’s Energy Office, Colorado’s 30% Renewable Energy Standard:

Policy Design and New Markets, at 10 (Aug. 2010), available at http://cnee.colostate.edu/graphics/uploads/HB10-1001-Colorados-30-percent-Renewable-Energy-Standard.pdf.

[17] Xcel Energy, Demand-Side Management Annual Status Report:

Electric and Natural Gas:

Public Service Company of Colorado, at 2 (Apr. 2014), available at  https://www.xcelenergy.com/staticfiles/xe/Regulatory/Regulatory%20PDFs/CO-DSM/2013-CO-DSM-Annual-Status-Report.pdf.

[18] Id. at 15, tbl. 6.

[19] Energy Info. Admin., Electric Power Monthly, Table 1.1.A (Feb. 2014), available at http://www.eia.gov/electricity/monthly/epm_table_grapher.cfm?t=epmt_1_01_a.

[20] Id.

[21] Xcel Energy, New Mexico and Texas Wind Power: We Are Leveraging the Wind, http://www.xcelenergy.com/Environment/Renewable_Energy/Wind/New_Mexico_and_Texas_Wind_Power (last visited May 1, 2014).

[22] Tom Gray, Citing Low Costs, Xcel Energy Plans ‘Significant Increase’ in Wind Purchases, Into the Wind: The AWEA Blog (July 11, 2013), http://aweablog.org/blog/post/citing-low-costs-xcel-energy-plans-significant-increase-in-wind-purchases.

[23] Dep’t of Energy, Revolution Now: The Future Arrives for Four Clean Energy Technologies, at 4 (Sept. 2013), available at http://energy.gov/sites/prod/files/2013/09/f2/Revolution%20Now%20–%20The%20Future%20Arrives%20for%20Four%20Clean%20Energy%20Technologies.pdf.

[24] Ian Clover, US Solar Power Costs Fall 60% in Just 18 Months, pv magazine (Sept. 20, 2013), http://www.pv-magazine.com/news/details/beitrag/us-solar-power-costs-fall-60-in-just-18-months_100012797/#axzz2qg0NDEBG.

[25] Dep’t of Energy, Revolution Now: The Future Arrives for Four Clean Energy Technologies, at 4-5 (Sept. 2013), available at http://energy.gov/sites/prod/files/2013/09/f2/Revolution%20Now%20–%20The%20Future%20Arrives%20for%20Four%20Clean%20Energy%20Technologies.pdf.

[26] Lucy Woods, GTM and SEIA: 41% Growth in US Solar Market for 2013, PVTECH (Mar. 5, 2014), http://www.pv-tech.org/news/gtm_and_seia_41_growth_in_us_solar_market_for_2013.

[27] Eric Wesoff, Cheapest Solar Ever? Austin Energy Buys PV From SunEdison at 5 Cents per Kilowatt-Hour (Mar. 10, 2014), https://www.greentechmedia.com/articles/read/Cheapest-Solar-Ever-Austin-Energy-Buys-PV-From-SunEdison-at-5-Cents-Per-Ki.

[28] The Solar Foundation, National Solar Jobs Census 2013, http://www.thesolarfoundation.org/research/national-solar-jobs-census-2013 (last visited May 1, 2014).

[29] American Council for an Energy-Efficient Economy, Change Is in the Air: How States Can Harness Energy Efficiency to Strengthen the Economy and Reduce Pollution, at iv (Apr. 2014), available at http://aceee.org/research-report/e1401.

[30] Id. at 21 tbl. 7.

[31] Id. at 18 tbl. 3.

[32] Id. at 22.

[33] Id.

[34] McKinsey & Company, Unlocking Energy Efficiency in the U.S. Economy, at 13-14 (2009), available at http://www.mckinsey.com/client_service/electric_power_and_natural_gas/latest_thinking/unlocking_energy_efficiency_in_the_us_economy.

[35] NRDC, Issue Brief Update: Cleaner and Cheaper: Using the Clean Air Act to Sharply Reduce Carbon Pollution from Existing Power Plants, Delivering Health, Environmental, and Economic Benefits, at 10 (Mar. 2014), available at http://www.nrdc.org/air/pollution-standards/files/pollution-standards-IB-update.pdf.

[36] Bruce Phillips, The NorthBridge Group, Alternative Approaches for Regulating Greenhouse Gas Emissions from Existing Power Plants under the Clean Air Act: Practical Pathways to Meaningful Reductions, at 22 (Feb. 2014), available at http://www.catf.us/resources/publications/files/NorthBridge_111d_Options.pdf.

[37] Dallas Burtraw et al., The Costs and Consequences of Clean Air Act Regulation of CO2 from Power Plants, at 10 tbl. 1 (Jan. 2014), available at http://www.rff.org/RFF/Documents/RFF-DP-14-01.pdf.

Posted in Clean Power Plan, Economics, Greenhouse Gas Emissions, Jobs, Policy| 2 Responses, comments now closed
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