Climate 411

5 Undeniable Truths about the Clean Power Plan

By Ben Schneider / Published: August 13, 2014

Do you get a sense of déjà vu when you hear the fossil fuel industry arguments against the Environmental Protection Agency’s new climate change plan? You’re not imagining things – we’ve heard these many, many times before.

The EPA recently held public hearings around the country to solicit comments on its new proposal to put reasonable, nationwide limits on climate pollution from power plants.

The plan is moderate, flexible, and paves the way for considerable economic gains, but the substance hardly mattered for some die-hard opponents: The fossil fuel industry allies trotted out the same talking points about the supposed costs of action and American indifference to clean air policies that they always do.

Tellingly, industry lobbyists and their friends in Congress couldn’t even be bothered to wait and see what the rule said before blasting it with wildly inaccurate claims about the cost of implementation.

Fossil fuel industry allies have clung to these false arguments for decades, so it’s little wonder misinformation continues to swirl around these rules and the clean energy debate at large.

Here are the real facts about five issues opponents raised about the Clean Power Plan:

1. Renewable energy is taking hold.

Opponents of clean air regulations are keen to convince the public that affordable, renewable energy is a pipe dream. But the truth is renewable energy has never been more efficient, it’s never been less expensive, and it’s taking root all over the country.

Take a look at solar power: According to the U.S. Solar Energy Industries Association, the cost of solar power plummeted 60 percent between the first quarter of 2011 and the second quarter of 2013. The long-term picture is just as impressive: In 2012, rooftop solar panels cost about 1 percent of what they did 35 years earlier.

And solar isn’t the only renewable that’s catching on. Wind energy accounted for one-third of new power capacity over the last five years, an amount that could double in the years to come.

Texas, the nation’s top wind producing state, saw wind energy generation grow a whopping 13 percent in 2013. Last year, 60 percent of wind projects in the entire United States were in Texas.

2. Americans support limits on greenhouse gas emissions. 

Industry lobbyists often suggest that Americans cringe at any and all attempts to curb the pollution that causes global warming, but that argument is flat-out false. Recent polling shows that’s clearly not the case.

A recent study by Yale found that 64 percent of Americanssupport strict carbon dioxide emission limits on existing power plants.

3. The power plant rules will be efficient and affordable. 

As I wrote earlier, the fossil fuel industry and their allies in Congress were eager to say the proposed rules will cost vast sums of money that will trickle down to consumers and destroy jobs in the process. The Washington Post Fact-Checker thoroughly debunked those claims, and it is not the first time industry has been caught red-handed.

Time and again, the cost of implementing any rules related to the Clean Air Act are five to 10 times less than the industry initially estimates they will be.

4. Power companies already have tools to implement pollution limits.

The Clean Power Plan is part of President Obama’s broader plan to reduce nationwide carbon dioxide emissions. He has set as a goal to reduce emissions by 17 percent by 2020 nationwide, using 2005 as the baseline. Industry opponents claim the emission reduction goal is unrealistic, but there’s evidence to the contrary.

Xcel Energy, one of the country’s largest electricity and natural gas providers, has already reduced emissions 20 percent since 2005. The company is on pace to decrease emissions by 31 percent in 2020.

5. States can handle implementation better than you may think. 

Yet another common complaint from industry is these meaningful clean air regulations are too big and unwieldy for states to implement. Don’t tell that to California, which last year implemented a world-class climate law that has led to substantive greenhouse gas reductions and economic growth.

And the nine states in the Regional Greenhouse Gas Initiativeare already reaching stellar results.

Industry allies are actually half-right about one thing, though: The Clean Power Plan is indeed a huge deal. It may very well serve as a turning point for the United States and the world in our effort to reduce greenhouse gasses, while pointing the economy toward revitalization through clean energy.

The sooner opponents stop circulating myths to the contrary, the sooner everyone can reap those benefits.

This post originally appeared on our EDF Voices blog.

Also posted in Clean Power Plan, Greenhouse Gas Emissions, Health, Jobs, Policy / Read 2 Responses

“Risky Business” stands out in growing sea of climate reports

By Gernot Wagner / Published: June 26, 2014
Receding beach on North Carolina’s Outer Banks. Source: FEMA/Tim Burkitt

(This blog originally appeared on EDF Voices)

This blog post was co-authored by Jonathan Camuzeaux.

Put Republican Hank Paulson, Independent Mike Bloomberg, and Democrat Tom Steyer together, and out comes one of the more unusual – and unusually impactful – climate reports.

This year alone has seen a couple of IPCC tomes, an entry by the American Association for the Advancement of Science and the most recent U.S. National Climate Assessment.

The latest, Risky Business, stands apart for a number of reasons, and it’s timely with the nation debating proposed, first-ever limits on greenhouse gas emissions from nearly 500 power plants.

Tri-partisan coalition tackles climate change

The report is significant, first, because we have a tri-partisan group spanning George W. Bush’s treasury secretary Paulson, former mayor of New York Bloomberg, and environmentalist investor Steyer – all joining forces to get a message through.

That list of names alone should make one sit up and listen.

Last time a similar coalition came together was in the dog days of 2009, when Senators Lindsay Graham, Joe Lieberman, and John Kerry were drafting the to-date last viable (and ultimately unsuccessful) Senate climate bill.

Global warming is hitting home

Next, Risky Business is important because it shows how climate change is hitting home. No real surprise there for anyone paying attention to globally rising temperatures, but the full report goes into much more granular details than most, focusing on impacts at county, state and regional levels.

Risky Business employs the latest econometric techniques to come up with numbers that should surprise even the most hardened climate hawks and wake up those still untouched by reality. Crop yield losses, for example, could go as high as 50 to 70 percent (!) in some Midwestern and Southern states, absent agricultural adaptation.

The report is also replete with references to heat strokes, sky-rocketing electricity demand for air conditioning, and major losses from damages to properties up and down our ever-receding coast lines.

Not precisely uplifting material, yet this report does a better job than most in laying it all out.

Financial markets can teach us a climate lesson

Finally, and perhaps most significantly, Risky Business gets the framing exactly right: Climate change is replete with deep-seated risks and uncertainties.

In spite of all that we know about the science, there’s lots more that we don’t. And none of that means that climate change isn’t bad. As the report makes clear, what we don’t know could potentially be much worse.

Climate change, in the end, is all about risk management.

Few are better equipped to face up to that reality than the trio spearheading the effort; Paulson, Bloomberg and Steyer have made their careers (and fortunes) in the financial sector. In fact, as United States Treasury secretary between 2006 and 2009, Paulson was perhaps closest of anyone to the latest, global example of what happens when risks get ignored.

We cannot – must not – ignore risk when it comes to something as global as global warming. After all, for climate, much like for financial markets, it’s not over ‘til the fat tail zings.

Also posted in Basic Science of Global Warming, Cars and Pollution, Extreme Weather, Greenhouse Gas Emissions, Health, Jobs, News, Policy / Read 1 Response

The Many Benefits of Reducing Carbon Pollution from Existing Power Plants

By Megan Ceronsky / Published: May 15, 2014

(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.

Also posted in Clean Power Plan, Greenhouse Gas Emissions, Jobs, Policy / Read 2 Responses

Trucks delivering six miles per gallon won’t work in the long haul

By Jason Mathers / Published: May 8, 2014

Here’s something to think about next time you are stuck in traffic next to an 18-wheeler: The average tractor-trailer can travel only six miles per gallon of diesel.

These heavy trucks travel a lot too; averaging more than 120,000 miles a year or 20 roundtrip drives between Boston and San Francisco. Freight trucks are on the road for one primary purpose: to get goods to all of us. In fact 70% of U.S. freight tonnage is moved by tractor-trailer trucks. Over the coming years, demand for freight services is expected to grow even more. And this is driving up fuel consumption and greenhouse gas emissions.

A call for strong fuel efficiency standards

But it is possible and affordable for tractor-trailer trucks to get nearly 11mpg by 2025. The Obama Administration can set new fuel efficiency and greenhouse gas standards for heavy trucks that cut fuel consumption by 40% compared to 2010 levels. These standards would also apply for heavy-duty work trucks, such as box delivery trucks, bucket trucks, beverage delivery trucks and refuse trucks.

Strong, new fuel efficiency and greenhouse gas standards for our nation’s heavy trucks are achievable, cost-effective and critical to cutting greenhouse emissions and fuel consumption – all while we continue to depend on trucks to deliver the goods we need and want. The slideshow below highlights some of the technology available to meet bold standards as well as the significant cost, oil and emissions savings from such standards.

Bold fuel efficiency standards are good for our economy, environment and energy security. One fact that just jumps out at me is this: These standards will cut our oil consumption by 1.4 million barrels a day. That sounds like a big number and it is. It’s a bit higher than the amount of oil we import daily from Saudi Arabia.

They will also be good for trucking fleets too. These trucks will cost $30,000 less to fuel a year.

Strong fuel efficiency and greenhouse gas standards for heavy trucks are an important part of the President’s Climate Action Plan, and EDF will continue to work towards strong standards through our unique combination of industry engagement, regulatory design expertise and technical know-how.

This post first appeared on our EDF Voices blog

Also posted in Cars and Pollution, Policy / Read 2 Responses

When it comes to carbon, pay now or pay more later

By Gernot Wagner / Published: April 17, 2014

(This post originally appeared on ensia.com) 

Economics is largely just organized common sense, and it doesn’t get much more common sense than benefit-cost analysis. Want to decide whether to buy that apple, make that investment or pass that clean air rule? Tally up the benefits. Tally up the costs. If benefits outweigh costs, do it.

Although in many ways climate change is a problem in its own league, the same principles apply. Secretary of State John Kerry recently said, “The costs of inaction are catastrophic,” and they most likely would be. While climate change ought to be a risk management problem — an existential risk management problem on a planetary scale — that realization alone may not always be good enough. Despite the inherent risks and uncertainties, sometimes we need a specific number that we can plug into a benefit-cost analysis.

The U.S. government makes lots of regulatory decisions that have important implications for the climate. Any benefit-cost analysis of these decisions ought to include their climate impact. If a particular decision will lead to more greenhouse gas emissions — building the Keystone XL pipeline, for example — that figure ought to go on the cost side of the ledger. If the decision will lead to fewer greenhouse gas emissions — such as carbon pollution standards for power plants — that figure adds to the benefits side.

Such benefit-cost analyses require a dollar figure for the social cost of carbon pollution. The best we currently have is around $40 for each ton of carbon dioxide emitted, calculated by averaging results from the three of the most prominent and well-established climate-economic models. Uncertainties around the $40 value notwithstanding, putting in $0 is not an option. That, sadly, is what some with clear stakes in the outcome are arguing, however weak the ground they stand on.

In fact, $40 is very likely on the low end of the true cost of CO2. By definition, it only includes what is known and currently quantifiable. It doesn’t include many things we know are linked to a changing climate that aren’t so easily quantified, such as respiratory illness from increased ozone pollution, the costs of oceans turning ever more acidic and impacts on labor productivity from extreme heat. If these were factored in, the $40 figure would certainly be higher.

And the list of what’s missing in the current calculation goes on, as a recent commentary in Nature points out. For example, the models used to calculate the $40 figure are based on costs associated with higher average temperatures rather than costs of increased weather extremes. Taking extreme events seriously in the social cost calculation would increase the $40 figure further still.

We know climate change is and will be costly. How costly exactly is up for discussion, but it’s clear that we should at the very least use the $40 per ton figure in any benefit-cost analysis that involves climate impacts. That’s common sense, too.

Also posted in Clean Power Plan, Greenhouse Gas Emissions, Policy / Read 1 Response

Energy Efficiency and Carbon Pollution Standards: Double Dividends for Climate and Consumers

By Tomas Carbonell / Published: March 27, 2014

The U.S. Environmental Protection Agency (EPA) has embarked on a vital effort — accompanied by extensive outreach to states, power companies, environmental organizations, and other stakeholders, including you — to establish the nation’s first limits on carbon pollution from fossil fuel-fired power plants.

EPA was directed to take this critical step for public health and the environment in the President’s Climate Action Plan that was released last summer. Protective and well-designed Carbon Pollution Standards will provide important benefits for all Americans.

Fossil fuel-fired power plants emit 40 percent of the nation’s carbon pollution, as well as significant amounts of mercury, acid gases, and pollutants that contribute to smog and particulates.

That’s why it is critical to get these rules right, and to mobilize common sense solutions proven in red and blue states alike in reducing carbon pollution from the power sector.

Of all the available ways to reduce carbon pollution, one of the most cost-effective and time-tested approaches is to reduce demand for fossil fuel electricity through end-use energy efficiency (EE).

EE measures encompass countless improvements, large and small, in the ways we use electricity in our offices, factories, and homes. All of those improvements can add up to big savings, not only in our monthly energy bills but in the total amount of fossil generation needed to power our society.

Dozens of states and power companies are already investing heavily in EE, and have built up decades of experience in measuring and verifying the many benefits it can yield for consumers and for the environment.

Incredible Potential to Cut Emissions and Save Money by Reducing Wasted Electricity

States and power companies around the country have been implementing EE programs for decades, and have increased their efforts in recent years as experience with the benefits of EE has grown.

26 states in diverse regions of the country, from Arizona and Colorado in the Southwest to industrial Midwest states like Ohio and Illinois, now have “energy efficiency resource standards” or similar policies that require utilities to achieve a certain amount of energy savings each year.

State spending on EE programs increased by 28 percent between 2010 and 2012.

As EE policies and investments have grown, so have energy savings.

In 2011, state EE programs saved a total of 22.9 million megawatt-hours — roughly equivalent to the entire annual output of seven 500 megawatt coal-fired power plants.

These savings increased 22 percent since 2010 and, importantly, count only those savings achieved in the first year these EE measures are in place.

Because most EE measures continue to yield energy savings years or even decades after they are installed, the cumulative savings from these state EE programs are much larger.

A recent study by the American Council for an Energy Efficient Economy found that EE programs and policies are a key reason why residential and commercial electricity demand has remained stable since 2007.

As impressive as these developments are, they only scratch the surface of what could be achieved if we were to fully unlock the potential for EE to save energy and reduce emissions.

An exhaustive 2009 analysis by McKinsey & Company, for example, found that rigorous investment in cost-effective EE could reduce the country’s total energy consumption by 23 percent in 2020.

Energy savings on this scale would yield massive emission reductions — about 700 million metric tons of carbon dioxidein 2020 alone (more than 30 percent of power sector emissions today) – and at a cost per kilowatt-hour saved that is about 85 percent less than the average retail price of electricity.

The report also estimated that realizing these energy savings would create about 600,000 to 900,000 jobs through 2020.

Other national and regional studies have similarly found that EE represents a tremendous “win-win” opportunity for our climate, for families and consumers, and for the economy as a whole.

In 2012, for example, the Southwest Energy Efficiency Project (SWEEP) issued a report focusing on the potential benefits of scaling-up EE programs in six Southwestern states (Arizona, Colorado, Nevada, New Mexico, Utah, and Wyoming).

Based on the track record of “best practice” EE programs around the country, SWEEP found that these six states could reduce their electricity demand in 2020 by more than 20 percent while achieving net benefits of about $20 billion – amounting to $2,650 for every household in the region (largely in the form of lower energy bills).

Investments in EE at this scale would also create about 30,000 additional jobs in the region by 2020, and increase wages and salaries by more than $1 billion.

At the same time, these EE measures would reduce carbon pollution by more than 30 million metric tons in 2020, (a 16% reduction relative to expected emissions in 2020), while also reducing thousands of tons of pollutants that contribute to smog, acid rain, and harmful particulate pollution.

EE and the Carbon Pollution Standards

If you’ve read my colleague Megan Ceronsky’s earlier blog, you’ve already heard about section 111(d) of the Clean Air Act.

That section provides bedrock authority for EPA to issue Carbon Pollution Standards for existing power plants.  It also provides a broad, flexible framework for states and companies to deploy EE and other flexible approaches to reducing carbon pollution from the power sector.

Under section 111(d), EPA and the states will work together to reduce emissions from existing power plants.  EPA will issue “emission guidelines” that identify the “best system of emission reduction” for carbon pollution from existing power plants and the emission reductions achievable using that system.  The states then have the responsibility to develop plans that implement standards consistent with those guidelines.

Just a few weeks ago, Kate Konschnik, Policy Director of the Environmental Law Program at Harvard Law School, released a report that makes a strong legal case for considering EE as part of the “best system of emission reduction” that underpins EPA’s emission guidelines.

As Konschnik argues, the Clean Air Act grants EPA broad authority to consider flexible measures such as EE as a part of the best system of emission reduction for carbon pollution:

[B]ecause it is adequately demonstrated and cost-effective, imposes minimal environmental costs, and reduces overall energy requirements.

Moreover, as Konschnik points out, methods for quantifying and verifying EE-related energy savings and emission reductions are well-developed.

Over the last two decades, at least 35 states and two regional transmission organizations have adopted protocols for measuring and verifying energy savings from EE projects. These savings are now widely used as the basis for critical regulatory proceedings and market functions, including establishing utility rates, compensating EE in regional capacity markets, and carrying out long-term regional resource planning.

In addition, EPA has already allowed several states to credit emission reductions resulting from EE and renewable energy towards compliance with national air quality standards. EPA has also issued detailed guidance to the states on analytical approaches and tools that could be used for future programs.

Ensuring Smooth Implementation of EE in the Carbon Pollution Standards

Under traditional emissions trading programs such as the Regional Greenhouse Gas Initiative (RGGI) or California’s cap-and-trade system, the emission reduction benefits of EE are readily observed as emissions from power plants drop.

Under these programs, no separate system for tracking emission reductions from EE is necessary.  As a recent report by RGGI confirms, these programs are also funding significant investments in EE programs that have already helped 815,000 families.

However, some states may choose to directly incentivize EE through policies that credit individual projects and programs for their impacts on energy savings and emissions.

For this reason, EDF has worked with experts in the field to study how measurement and verification for such EE crediting systems could work in a way that is environmentally rigorous and administratively streamlined, and that builds on extensive state and regional experience with existing EE programs.

We recently submitted a report to EPA, developed by the Analysis Group, that lays out one possible framework for ensuring both desirable outcomes:

  • Rigorous measurement and verification of EE projects, and
  • Consistent methods for determining emission reductions that are attributable to EE projects

This framework recognizes the diverse approaches to measurement and verification of EE that are in use around the country. But in developing this framework, we were also struck by the significant progress that a number of organizations have made in developing best practices and consensus protocols for evaluating EE projects.

One example is the Department of Energy’s Uniform Methods Project (UMP), which has organized a multi-stakeholder process to develop rigorous yet streamlined measurement and verification protocols for different types of EE projects.

To date, UMP has released protocols addressing seven major EE project types and five “cross-cutting” evaluation issues. Eight more protocols are expected to be finalized in the coming months.

Other notable efforts to develop and encourage best practices in the field include:

EE: Ready for Prime Time

EE represents a historic opportunity to achieve extensive reductions in emissions of carbon pollution and other power sector pollutants that directly harm public health and the environment.

In many cases, EE measures will actually save families and businesses money over time and help strengthen the economy.

Decades of state and utility experience in designing and implementing EE programs have demonstrated that the benefits of EE are real, and that the policies and tools needed to incentivize EE and measure its effects are available.

EPA should fully mobilize the potential of EE by exercising its authority to consider EE in the design of the Carbon Pollution Standards, and by providing guidance to the states to facilitate the inclusion of EE in state plans implementing those standards.

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