On November 1, the North Carolina Utilities Commission issued an order in the Carbon Plan docket, almost two months ahead of schedule. It largely ratifies an agreement reached by Duke Energy and the state’s Public Staff, who are charged with protecting the state’s ratepayers. While the Commission drops the requirement for Duke Energy to model hitting the 70% carbon emission reduction by 2030 in state law, largely due to a boom in electricity demand, the utility is still required to take “all reasonable steps” to hit the target by the “earliest possible date.” Which begs the question, what is the earliest possible date? A new white paper from EDF comes to the conclusion that North Carolina can still hit the target by 2032, even with the new carbon-emitting resources moving forward under this order.
Climate 411
North Carolina can still avoid huge amounts of emissions (and stranded carbon emitting assets) under the state’s Carbon Plan Law. Here’s how.
New modeling shows the power and potential of cap-and-invest in Washington state
Washington state’s cap-and-invest program, created in the 2021 Climate Commitment Act (CCA), is nearing the end of its second year and has already raised over $2 billion for communities by putting a price on pollution.
The program is a win-win for climate action and for communities: It creates a powerful economic incentive for companies across the state to lower their emissions, while generating investments for Washington communities in the process. There are already many projects underway across all 39 counties in the state, putting that auction revenue to use. Some of the benefits that people in Washington are seeing include:
- More access to cleaner public transit including free ferry, bus, and other transit rides for youth.
- Cleaner air for children in and around schools with upgrades to zero-emissions school buses and new, efficient HVAC systems.
- Lower energy bills for low-income households and small businesses who receive support for replacing old gas furnaces with modern and efficient electric alternatives.
But the scale of this program enables it to deliver much more for Washington’s communities and economy in the long run. Just how much more? Thanks to new, in-depth modeling from Greenline Insights, supported by EDF, we now have a clearer picture of the transformative impact this program could have.
Why EDF is exploring marine carbon dioxide removal
The oceans are a massive carbon sink. Researchers, companies and governments are exploring whether we can engineer coastal and ocean systems to store even more carbon. But while the ocean presents us with great possibilities, it’s also a complex system where human interventions can impact everything from the ecological (species’ interactions or the habitats they depend on) to the socio-economic (food systems or economic livelihoods).
EDF has a track record of coordinating collaborative research on natural carbon storage systems in the ocean to understand both their role in carbon sequestration and their potential to generate ecological and socio-economic benefits, as well as any associated risks.
We’re now taking a similarly holistic approach to exploring the potential of technical approaches to marine carbon dioxide removal (or, mCDR). Our aim: to identify the areas with the greatest potential to accelerate innovation with minimal risks to people and nature.
mCDR: different methods to increase carbon sinks
Marine CDR is a manmade intervention in the marine environment that changes the biology, chemistry or physics of the surface ocean resulting in the net removal of carbon dioxide from the atmosphere. A few ideas have been suggested based on existing knowledge of ocean science. For example:
- Using fertilizers like iron sprinkled in the water in large quantities could encourage the growth of phytoplankton, microscopic marine plants, that, by sinking or being consumed, could facilitate the movement of carbon to the deep sea.
- Releasing minerals into surface waters that amplifies the slow natural weathering of rocks like limestone or basalt could help boost ocean’s alkalinity and increase carbon sequestration rates in the ocean.
- Pumping surface water to deeper depths could take carbon dioxide the ocean has absorbed from the atmosphere and mimic the natural process of phytoplankton sinking when they die.
While these innovations seem promising, changing natural processes can result in a host of hard-to-determine impacts. For example, scientists don’t yet know whether artificial fertilization and growth could result in carbon export to the deep ocean. Therefore, we need to be cautious and examine not only the efficacy of carbon removal, but also impacts on marine life and human health. There are also complex ethical considerations associated with undertaking many of these approaches, from economic costs to impacts on livelihoods and food security across both short and long timescales. It’s critical to understand the risks as well as who will benefit, and who will bear the costs as decisions to continue research or deployment are being made.
Why it’s time to examine mCDR’s efficacy and impacts
It’s clear that holding warming below 2 degrees Celsius through emissions reductions and the energy transition alone will be difficult. We see a potential role for mCDR in contributing to stabilizing the climate and reaching net zero goals in the long term, which requires gaining a better understanding of benefits and risks in the short term. More and more organizations are working on mCDR, in large part driven by significant interest in the voluntary carbon market. And while funding is currently focused on evaluating the efficacy of carbon removal, we lack a solid scientific basis upon which to make reasonable decisions.
A strong scientific foundation is critical to speeding and scaling CDR solutions. But speeding and scaling down the wrong path can ultimately reduce confidence in entire solution pathways, as well as lead to environmental harms. EDF wants to help to establish, guardrails, governance and policies to help develop a responsible research program that would allow thoughtful consideration of the full scope of both climate and ecological and socio-economic implications of mCDR development.
EDF applies a systems perspective in examining climate solutions, with mCDR fitting within our existing and complementary efforts related to natural climate solutions, emissions reductions, carbon markets and solar geoengineering methods. We also have a long track record of working with academe, industry, governments, other NGOs, community groups and other civil society organizations to provide society with the understandings required to make science-based decisions.
While EDF is not supporting widespread deployment of mCDR methods at this time, we are engaging in the following ways:
- Assessing research needs, contributing to research, advocating for research code of conduct, and supporting the development of rigorous standards for assessing the safety of any research in this space.
- Examining permitting and regulatory needs to help inform recommendations and policies.
- Developing effective engagement strategies with communities and interested parties around mCDR research.
- Creating a holistic framework to evaluate different benefits, risks and tradeoffs of different types of mCDR.
- Advocating for the developing of a robust federal research initiative on marine CDR
Emissions reduction remains EDF’s number one priority and primary focus. However, as we work to address near term warming and with it limit some of the most worrisome impacts of climate change that we’re already experiencing, we need to research new technologies that show promise. Instead of jumping into mCDR with a Gold Rush mentality, it’s critical to develop an evaluative framework for looking at the impacts of these new technologies across the multiple dimensions that affect the environment and people’s wellbeing and engage civil society in the process.
Washington state’s landmark climate law continues to build a greener future for Washingtonians
Results were released today for Washington’s third quarterly auction of 2024, administered last Wednesday by the Department of Ecology (Ecology). During the auction, participating entities submitted their bids for allowances. Under the Climate Commitment Act — Washington’s landmark climate law which sets a binding, declining limit on pollution — Washington’s major emitters are required to hold one allowance for every ton of greenhouse gas that they emit, with the total number of allowances declining each year. With fewer allowances available each year, this system requires polluters in Washington to reduce their emissions in line with the state’s climate targets. Distributing allowances through quarterly auctions allows Ecology to both regulate harmful emissions and raise critical revenue to invest in frontline communities, ramp up clean job creation, bolster climate resilience, and accelerate further emissions reductions.
Here are the results, released today:
Locking in the U.S. NDC: New report finds policy combined with IRA can ensure significant power sector reductions and major benefits
As we race to decarbonize the economy this decade, the Inflation Reduction Act (IRA) has provided an enormous economic opportunity for the clean energy industry. With costs of deploying clean energy solutions becoming so low, we are in a critical window of time to adopt new carbon policies and lock in “cost-optimal” model projections and go beyond them to realize a pathway for the U.S. that’s consistent with a 1.5°C warming trajectory.
However, according to a recent report by the Rhodium Group (RHG), the United States is not on track to meet its nationally-determined contribution (NDC) goal of 50-52% economy-wide emissions reduction in 2030 from 2005 levels, with RHG projecting a reduction of only 32-43%.
With this carbon policy imperative in mind, a new peer-reviewed journal article, building on a report by Resources For the Future (RFF), demonstrates how policies that constrain carbon emissions in the power sector could unlock the full potential of IRA incentives in order to achieve the economy-wide goal of 50-52% emission reductions from 2005 under the U.S. NDC, with 80% emission reductions in the power sector.
The article finds that combining a carbon cap with the IRA significantly drives down the cost of achieving reductions to meet the cap. Modeling showed a marginal abatement price of $27/ton to achieve 369 million tons of additional abatement and reach 80% power sector emission reductions by 2030, compared to 2005 levels, which is nearly 60% cheaper when compared with model scenarios that only have a carbon cap, without the IRA. The combination of a carbon cap with the IRA would also lower consumer costs this decade to roughly $114/megawatt hour (MWh), compared to $117/MWh without either policy in place, and create significant net climate and health benefits due to deeper reductions in fossil fuel pollution.
Background
The U.S. NDC is ambitious and aligned with recent COP28 decisions consistent with keeping a 1.5°C warming trajectory within reach. Achieving the NDC would demonstrate global climate leadership and be significant, given that the U.S. contributes about 11% of global emissions. The power sector is the core component for achieving the NDC, with numerous studies continuing to show that the majority (about two-thirds) of near-term abatement is projected to have to come from the power sector. Moreover, the power sector plays a key role in decarbonizing the economy through electrification of other sectors such as buildings, transportation and heavy industry.
To reach the 2030 target, U.S. power sector emissions need to drop by roughly 80% by 2030, compared to 2005 levels, or “80×30”. This goal will require rapid acceleration of electric power sector decarbonization, striving to triple the annual deployment of new clean energy projects and phase out fossil fuel pollution — consistent with the COP28 pledges.
Recent federal and state-level policy actions are accelerating progress towards 80×30. The IRA and the Infrastructure Investment and Jobs Act (IIJA) have changed the economics of decarbonizing the power sector and paving the way for a cost-optimal pathway to clean energy. If realized, this pathway, in tandem with state policies and company-level actions, could contribute to a significant portion of the emission reductions needed in the power sector and across the economy to meet the NDC target. However, there are both risks to locking in the cost-optimal trajectory under the IRA projected by models and opportunities to go beyond the IRA in order to fully unlock the potential of the power sector to drive progress to the NDC target.
We are already seeing a powerful effect from the incentives in the IRA, which are projected to unlock around $390 billion of spending on energy and climate through 2022-2031. Of this amount, around $160 billion (41%) is expected to be spent on tax credits for clean electricity, underlining the significant investment the IRA makes in the power sector transition and the importance of maximizing its implementation. The tax credits are also uncapped, in that there is no limit in the legislation that restricts government spending on them.
The problem
Despite this promise, a wide range of model projections reflect uncertainty in the degree and magnitude of IRA implementation as well as other pressures such as increased demands and risks to faster clean deployment. Model projections assume “cost-optimal” conditions whereby decisions to build, maintain, and/or retire power generation are optimized for system costs, which may differ from real-world investment decisions.
According to a study examining multiple models, power sector emissions are projected to fall by 47-83% below 2005 levels in 2030. RFF’s power sector modeling is consistent with this range, projecting a decrease of 44-63%, falling short of 80×30. And across the economy, reductions from the IRA are projected to be 33-40% below 2005 levels in 2030 with a 37% average, below the 50-52% the NDC target.
The solution
The challenge ahead of us for the power sector is to lock in these cost-optimal trajectories and maximize the potential benefits of the IRA — AND close the gap to reach 80×30. The RFF report offers a potential policy solution by combining the IRA incentives with a carbon emissions cap that constrains the total amount of carbon dioxide emissions in the power sector over time, and ensures that electric demand must be increasingly met by zero-emissions electricity generation. While the RFF analysis looked at the interaction of the IRA and emissions cap policies at the federal level, the same dynamics exist with state or regional caps as well.
Model methodology and scenarios
RFF used the Haiku model — a national capacity expansion model that reflects supply and demand at the State level and optimizes for system cost with a given set of inputs and policy conditions.
RFF’s model tests several scenarios, which include:
- Baseline: A “pre-IRA baseline” scenario that does not include the IRA;
- IRA: An IRA “Business-as-Usual” scenario that includes current policies;
- Cap mimic IRA:
- IRA + 80×30 cap: A scenario that combines the IRA with a carbon emissions cap to ensure 80×30 is reached; and
- 80×30 cap: A “Cap Only” scenario, for comparative purposes, that uses a carbon emissions cap to reach 80×30 without the IRA in place.
Key Findings
1. A nationwide Carbon Emissions Cap can lock in the IRA at no additional cost: Including a carbon emissions cap with a carbon price on fossil fuel pollution will further incentivize uptake of IRA incentives to lock in the upper range of projected emission reductions and a shift to clean energy generation, and spur a faster transition away from coal generation in particular.
2. A Carbon Cap is needed to achieve 80×30: The RFF model scenarios finds a carbon emissions cap combined with the IRA will both
- lock in IRA abatement projections to maximum effect and provide certainty over the emissions outcome; and
- close the gap on the 80×30 target at much lower incremental cost. The average resource cost of achieving 80×30 is $31/ton under the “IRA+CAP” scenario.
3. The IRA dramatically reduces the cost of getting to 80×30 — slashing the cost per ton of emissions by nearly 60%: Reaching 80×30 in the “Cap only” scenario has a marginal abatement cost of $67/ton, while for the “IRA + CAP” scenario the marginal abatement cost is $28/ton — or about 58% lower with the IRA in place. This finding demonstrates how powerful the combination of the IRA with an emissions cap could be for reaching 80×30, and, therefore, the NDC target.
4. A Carbon Cap combined with the IRA drives overall reduction in consumer costs: Energy prices are lower in the “IRA + CAP” scenario compared to the pre-IRA baseline ($112/MWh compared to $117/MWh for averaged across 2023-2032), which particularly benefits low- and mid-income consumers who pay a larger fraction of their income on utility bills. This outcome is due to the IRA incentives placing a downward shift in retail prices as the costs of clean generation that would have been paid by electricity ratepayers are shifted to taxpayers. While the carbon cap accounts for the cost of fossil fuel pollution and accelerates phase out of coal and uptake of renewables — while still extracting revenue from polluters — this is balanced by shift away from ratepayers under IRA incentives that does not impact consumer prices.
5. A Carbon Cap combined with the IRA leads to major net health climate benefits: The “IRA + CAP” scenario shows climate and air quality health benefits that substantially outweigh resource costs, with a net benefit of $226 billion. This outcome is driven by an improvement of roughly 80% in additional air quality benefits, reflecting lower SOx and NOx emissions from coal generation. This finding further emphasizes that a limit and/or price associated with ongoing CO2 emissions is critical to driving down coal capacity and consumption and avoiding harmful pollution — with coal generation falling from 562 tera-watt hours (TWh) under the IRA, to only 110 TWh for the “IRA + CAP” scenario.
Recommendations
RFF’s journal article clearly illustrates how an additional carbon policy could work at the federal level, but there’s also a critical role for State- and company-level actions. For example, efforts such as the Regional Greenhouse Gas Initiative (RGGI), North Carolina’s Carbon plan and regulator efforts across 25-member U.S. Climate Alliance that concretely create an obligation to reduce emissions are necessary to close the emissions gap to 80×30. Power companies and utilities also have a major role in realizing the “cost optimal” model outcomes and developing and executing plans that maximize IRA incentives, reduce customer costs and realize social and environmental benefits.
With clean energy deployment costs plummeting, it is essential to act fast and build on the impacts of the IRA by putting in place additional policies to reduce carbon emissions — at all levels — that lock in cost-optimal model projections and go beyond them to reach the U.S. NDC target.
Investors, bipartisan former officials, others defend SEC climate risk disclosure rule
Extreme weather caused by climate change is a threat to human health and safety, but it is also increasingly the cause of serious economic disruptions. And in the transition to a lower carbon economy, companies are navigating both opportunities and challenges.
The Securities and Exchange Commission (SEC) recently adopted a rule to better equip investors to manage these risks. The rule will standardize public companies’ disclosures of climate-related financial risk information. (You can read more details about the rule here).
The SEC’s rule has received widespread support from a diverse array of stakeholders. However, certain state attorneys general, oil and gas interests, the U.S. Chamber of Commerce, and others have challenged the rule in court.
EDF joined Americans for Financial Reform, Sierra Club, and Sierra Club Foundation (represented by Earthjustice) and Natural Resources Defense Council (NRDC) to support the SEC’s climate risk disclosure rule by filing an amicus curiae – or “friend of the court” – brief in the U.S. Court of Appeals for the Eighth Circuit.
Our brief shows that:
- The rule is rooted in decades of the SEC requiring financially relevant environmental disclosures and updating disclosure requirements to reflect evolving market dynamics and investor concerns.
- The rule is reasonable and firmly supported by rigorous evidence of the importance of climate risk information to investors.
- The rule furthers the SEC’s core missions of investor protection, market efficiency, competition, and capital formation.
Our brief is in good company. More than a dozen others from investors, experts, and a broad range of stakeholders have also been filed in support of the rule, underscoring the SEC’s manifest authority to require commonsense climate-related financial risk disclosure and the importance and benefits of doing so.
Here are a few highlights from filings supporting the SEC’s action: