Climate 411

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Read More »

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

Wheeler expected to weaken the Clean Power Plan even as pollution reduction costs are dropping

EPA Acting Administrator Andrew Wheeler is reportedly taking steps to nix the Clean Power Plan– America’s only national limits on carbon pollution from existing power plants – in favor of a weak substitute that does almost nothing to protect us from climate change and would increase harmful pollution that contributes to soot and smog.

There are many reasons why rolling back these life-saving protections makes no sense, but chief among them is that the opportunities to reduce carbon pollution are even greater – and cheaper – now than when the Clean Power Plan was finalized in 2015.

EPA is required to determine the “best system of emission reduction” when regulating pollution under the Clean Air Act, and select an approach that reflects the maximum feasible level of control. A look at the evidence overwhelmingly shows that a legitimate Clean Power Plan replacement would adopt emission reduction targets more ambitious than those in the Clean Power Plan, not less.

Here’s why:

1. Power sector trends have made the Clean Power Plan even more achievable and cost-effective than originally estimated

Read More »

Posted in Clean Air Act, Clean Power Plan, Economics, Policy / Comments are closed

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

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

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

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

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

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

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

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

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

Of these responses:

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

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

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

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

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

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

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

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

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

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

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

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

Posted in Economics, Energy, Policy / Comments are closed

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

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

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

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

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

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

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

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

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

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

1. Disregarding lives saved by the Clean Power Plan

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

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

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

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

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

As EPA itself recently explained in a court brief:

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

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

2. Artificially inflating the costs of the Clean Power Plan

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

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

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

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

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

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

3. Shortchanging the benefits of reducing carbon pollution

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

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

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

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

The draft proposal simply ignores important categories of carbon reduction benefits

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

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

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

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

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

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

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

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

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

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

Click to enlarge

 

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

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

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

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

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

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

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

America deserves better

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

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

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

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