Climate 411

There’s been a lot of talk recently about the Trump administration undermining our protections against dangerous air pollution during the new coronavirus crisis. But they didn’t just start now.

Possible increase in total air toxic emissions from a subset of facilities eligible to reclassify under the air toxics loophole, aggregated at state and city level. In many areas, this loophole could lead to a quadrupling of air toxics from these facilities. Graphic by EDF.

Air pollution is linked to many of the underlying conditions that make some people especially vulnerable to the virus. For years, the administration has taken actions that would put more of that unhealthy pollution in our air – including through a proposed loophole to our safeguards against air pollution from large industrial sources. Data released by EPA itself shows how this loophole – which the Administration could finalize in the coming months – might expose millions of Americans to a huge increase in toxic air pollution.

Last July, EPA Administrator Andrew Wheeler proposed to create an air toxics loophole allowing large industrial facilities to increase their emissions of dangerous pollutants. When this proposed rule first emerged, EDF pointed out that EPA’s own data shows more than 3,900 large industrial facilities across the country are potentially eligible to take advantage of this loophole.

But additional data on just a subset of these facilities, released by EPA after the proposal came out, indicates that the proposal could lead to millions of pounds of additional toxic air pollution across 48 states – with many of these facilities located in areas where millions of Americans live and work.

The proposed air toxics loophole would undermine clean air safeguards for large industrial facilities across the country that are currently subject to stringent standards for the emission of mercury, benzene, and other hazardous air pollutants that may cause cancer and have other harmful health impacts. Under the proposal, many of these facilities would be eligible to “reclassify” themselves as smaller sources subject to weaker standards or no standards at all – and therefore could operate with weaker, or no, air pollution controls.

(The proposal would codify a four-page memo that Trump’s EPA issued in January 2018 – with no analysis of air pollution or health impacts. EDF, a coalition of environmental groups, and the State of California challenged that memo in court.  Although the D.C. Circuit rejected these challenges on procedural grounds, the court also found that the memo has no legal force or effect and cannot be relied upon by state permitting authorities or sources.)

In September, EDF and 34 public health, environmental justice, labor and environmental organizations submitted comments strongly opposing the proposed rule. EDF and four other environmental organizations also submitted detailed technical and legal comments emphasizing the danger the rule poses to public health.

Near the close of the comment period, EPA released additional data, including identifying information for specific facilities that could be eligible to reclassify under the proposed rule. EDF analyzed this additional data for clues about the devastating health and environmental impacts the air toxics loophole could have. In response to this additional data, EDF submitted supplemental comments to EPA.

Among other things, our analysis found:

• EPA’s data covers more than 2,500 facilities that would be eligible to reclassify and increase their emission of dangerous pollutants. EPA identified more than 2,500 facilities that are currently subject to stringent Maximum Achievable Control Technology standards but under the loophole could avoid complying with those standards. This large number of facilities still represents only a subset of the nearly 4,000 facilities nationwide that EPA estimated would be potentially eligible to reclassify under the proposal.
• A potential 480% increase in nationwide emissions of air toxics from these facilities. While it’s difficult to know if and by how much facilities would increase emissions if they were to take advantage of the proposed loophole, EDF estimates that total air toxics emissions could increase by about 49.2 million pounds per year if all the eligible facilities were to increase their emissions to the maximum extent permitted under the loophole. (The value was estimated by looking at the difference between current total air toxics emissions at these facilities and emissions if facilities increased total air toxics emissions to 75% of 25 tons per year – the threshold that would make these facilities major again – consistent with EPA’s approach.) Due to missing data for some of the facilities on the EPA list, however, this estimate is based on only 60% of the 2,500 facilities identified by EPA – so it could well underestimate the potential increase in emissions that would result from this proposal.

• The proposed rule could expose millions of Americans in communities across the country to increases in toxic air pollution. Our analysis found facilities potentially eligible to use the loophole to increase their emissions of dangerous pollutants in 48 states. The greatest increases are concentrated in Texas, California, Michigan, and Louisiana. More than 3.7 million people live in the ten cities with the greatest possible increase in air toxics from this loophole.

After EPA issued the January 2018 memo that first opened the air toxics loophole, EDF issued a white paper finding that it could affect as many as 26 facilities in the Houston-Galveston region alone – and lead to hundreds of thousands of pounds of additional toxic pollution. Now, EPA’s own data reinforces the devastating impact of this loophole, from California to Michigan. EDF will continue to oppose this dangerous failure of EPA to uphold its responsibility to safeguard human health and the environment.

After many years of inaction, 2019 marked a significant turning point in the global fight for climate action. Today’s youth captured our global attention and brought a renewed sense of urgency to the climate crisis, while businesses, local governments, and elected officials took major steps forward and set the tone for meaningful action in the future.

Businesses Take a Strong Stand Against Climate Change

Across the country, more than 10 major utility companies set goals to steeply reduce their carbon emissions—including Duke Energy, Xcel Energy, and DTE Energy who announced targets to achieve net-zero climate pollution by 2050. Joining these major utilities in a push for net-zero are other global business leaders like Danone, Mars, Unilever, and Nestle.

In the transportation sector, electric vehicles are increasing their market share and Ford Motor Company unveiled its plan to produce an electric battery powered SUV—called the Mustang Mach-E.

As the jobs in the coal industry shrunk again,  jobs in wind, solar, and  related clean energy industries grew strongly  in 2019. In fact, a recent study showed that the global race for clean job creation is off and running.

Congress Prioritizes Climate

After years of climate inaction on Capitol Hill, 2019 delivered fresh momentum for change.

Representative Donald McEachin (D-VA) sponsored the 100% Clean Economy Act, a bill that puts the U.S. on a path to achieving net-zero climate pollution by 2050. More than 160 members of the U.S. House of Representatives are co-sponsoring the legislation, marking the first time in a decade where nearly the entire House democratic caucus rallied behind an ambitious climate pollution target.

Congressional committees in both chambers of the Capitol held collectively more than 50 climate related hearings—led by the landmark Select Committee on the Climate Crisis in the House of Representatives. In the House, 2019 marked the year when climate hearings were back on the docket after a six year drought.

In the Senate, there was a much needed sign of bipartisanship. This fall Senators Mike Braun (R-IN) and Chris Coons (D-DE) launched the first-ever bipartisan Senate Climate Solutions Caucus, which at the close of 2019 has 10 Senators.

Local and State Governments Lead the Charge to Action

While climate action received renewed attention in the nation’s Capital, the real action in 2019 was in city halls and statehouses across the country.

In response to the Trump Administration’s withdrawal from the Paris Climate Agreement, a coalition of states and local governments representing nearly 70% of U.S. GDP continued to sign on to “America’s Pledge” on climate.

At the city level, over 200 mayors from across the United States pledged their support to transition their municipalities to 100% clean

After Colorado and Washington signed major climate bills into law, Nevada, Oregon, and other states across the country also took major steps towards climate action in 2019.

Today, according to a November 2019 report, one-third of Americans (about 111 million and 34% of the population) lives in a community or state that has committed to or has already achieved 100% clean electricity.

A Renewed Priority for Change

Lawmakers’ renewed focus on climate action closely correlates with another major 2019 climate milestone: climate change (and action to address the problem) is now a top-tier issue for Americans.

Polling across the country shows that Americans across the political spectrum are rapidly acknowledging climate change is a crisis. In September, CNN became the first major news outlet to hold a Presidential forum specific to the issue.

Millions of people took to the streets this fall to participate in the world’s largest global climate change demonstration in history, and many youth have exclaimed that these protests are just the start.

Just how much has this grassroots action moved the needle? The Oxford Dictionary named “climate emergency” as the 2019 word of the year and Swedish climate activist Greta Thunberg was named Time Magazine Person of the Year.

The Stage is Set for Climate Action

But with more extreme weather events, health risks, and economic hardships caused by climate change on the horizon, it is critically important that we hold public and private sector leaders accountable for more progress and measurable action in 2020.

In a matter of weeks the House Select Committee on the Climate Crisis is poised to release policy priorities recommendations and House Speaker Nancy Pelosi has committed to bringing a major, bipartisan climate bill to the floor in 2020.

There’s no doubt 2019 marked a critical turning point in the climate change fight, but the stakes are raised as we head into 2020. For our children’s future, we must capitalize on this historic momentum for climate action, and push for binding commitments for a 100% clean economy by 2050.

For the U.S. to do its part to help avoid the worst impacts of climate change, we must achieve a 100% clean economy by 2050 at the latest – removing at least as much climate pollution from the atmosphere as we put into it each year. (Read this for more on what we mean by “100% clean” or why this should be the goal.)  But what does a 100% clean economy actually look like and how do we get there?

Several studies have examined how the U.S. can cut emissions 80% from 2005 levels by 2050, such as the Obama Administration’s Mid-Century Strategy for Deep Decarbonization. More recently, Evolved Energy’s 350 ppm Pathways for the United States became the first major report to identify pathways for the U.S. to achieve even deeper reductions: net-zero carbon dioxide (CO­₂) emissions by 2050.

A 100% clean economy by 2050 is ambitious but necessary. To achieve it, we’ll need policies that drive down  climate pollution and substantial acceleration of clean energy innovation. Deep decarbonization studies suggest that with comprehensive climate policy and technology progress as a foundation, a 100% clean economy will most likely rely on:

• Rapidly transitioning to a clean electricity system. We already have a good idea of how to clean up the electricity sector. Several zero-carbon sources (wind, solar, hydro, nuclear) have been widely deployed and are already among the most cost-effective options for new generation. As a result, the electricity sector is likely to transition quicker and more cost effectively than any other part of the economy.
• Electrifying as much as possible. Electrifying major sectors like transportation and buildings cuts fossil fuel use and reduces emissions even with today’s electricity mix. It will lead to even greater reductions as electricity gets cleaner.
• Deploying low carbon fuels where electrification isn’t practical. Cleaner alternatives to fossil fuels, including hydrogen, synthetic gas, and biofuels can fill in where electrification is tricky, such as for high temperature heat needed for manufacturing processes and in aviation.
• Advancing energy efficiency. Energy efficiency lowers the amount of energy required—and therefore the emissions produced. Today, there are cost-effective energy efficiency opportunities in every sector of the economy, from vehicles to appliances to industrial equipment. As technology improves, even more opportunities to save energy while saving money will become available.
• Removing carbon dioxide from the atmosphere. Protecting and increasing natural carbon “sinks” like forests or by deploying technologies that suck CO₂ directly out of the air can help lower concentrations of carbon dioxide in the atmosphere, helping us reach 100% clean as quickly as possible. Also, because it will be very challenging to completely eliminate emissions from all parts of the economy, especially industry and transportation, carbon dioxide removal (CDR) can help ensure we’re taking as much carbon out of the atmosphere as we’re putting into it. There is disagreement over how big the potential carbon sink is from natural sources (the Evolved study, for instance, assumes the potential for natural CDR is large relative to other estimates). To the extent less natural CDR is available, we will need more technological CDR or more carbon mitigation.
• Reducing non-CO₂ CO₂ is the dominant climate pollutant responsible for climate change, but there are other major greenhouse gases that trap more heat on a per ton basis, such as methane, nitrous oxide and hydrofluorocarbons (HFCs). These gases are emitted not only through energy consumption but as byproducts of a wide variety of activities such as agriculture, oil and gas industries, landfills, and refrigeration and air conditioning. There are various strategies available to reduce these greenhouse gas emissions, but some sources are easier to reduce than others. For example, cutting edge techniques to limit methane emissions from livestock can only reduce emissions by 30%, even as livestock-related emissions are likely to grow as the population grows. More RD&D, incentives, regulations and technical assistance across the economy will be needed to reduce these emissions and deploy available technologies.

This suite of strategies, some of which are already cost-competitive with more polluting alternatives, could take off with a pollution limit in place. The chart below, based on Evolved Energy’s data, shows how these strategies might intersect to help the U.S. reach a 100% clean economy (although it’s important to note that the Evolved analysis only considered energy-related CO­₂ emissions).

(Click to Enlarge) *With electrification, there will be less direct use of fossil fuel, but the fuels that remain will tend to be more energy and carbon intensive **Includes negative emissions from biomass, increased sequestration in natural sinks, and negative emissions technologies +Some of the savings attributed to EE could also be attributed to electrification, as many electric technologies use less energy to provide the same service compared to fossil fuel burning alternatives

The contributions of each of the strategies in the figure should be considered rough orders of magnitude rather than precise estimates. There are many different ways to project the potential emissions reductions from each strategy, and each strategy also interacts and influences the others. For example, the extent to which expanded electrification leads to emissions reductions depends heavily on how clean the electricity sector becomes. The important thing to note is that we will have to make dramatic progress in each of these areas in order to achieve a 100% clean economy.

We can also see that even as overall emissions decline, there are forces pushing some sources of emissions up: Historically, as economic growth increased, so did energy consumption and emissions. While there’s recent evidence this relationship may be growing weaker, in general, higher GDP is associated with more energy demand. And while we expect to electrify a lot of the economy, not all equipment can be easily electrified, especially those that require the most energy, like airplanes and some industrial processes that require extremely high temperatures. As a result, the remaining fuels that are not replaced with electricity are more carbon intensive than the average of all of the fuels used today. So while there’s less direct use of fossil fuels, what’s left may be more carbon intensive.

At the big picture level, a 100% clean economy will be vastly more efficient, more reliant on clean electricity, and will deploy technologies and practices that capture and store at least as many emissions as we produce. Let’s go deeper and explore how a 100% clean economy might transform specific sectors:

• In commercial and residential buildings, much of the energy needed for space and water heating and cooking will come from electricity. This will require next-generation appliance standards, more ambitious building codes, and incentives to adopt efficient electric technologies like electric heat pumps. Maximizing energy efficiency in new buildings will be essential: many of the buildings built today will still be standing in 2050.
• Increased electrification will also be necessary in the industrial sector, although many industrial processes will be hard to electrify. Fuel switching to alternative low- or no-carbon sources like hydrogen or sustainable biofuels, as well as energy and material efficiency – making less resource-intensive products – can also significantly reduce industrial sector emissions. Finally, many industrial processes are good candidates for carbon capture and storage technologies that capture carbon emissions to be stored underground or put to productive use.
• Electrification and efficiency will drive a lot of the transportation sector emission reductions. The Evolved analysis assumes that electric vehicles and other zero carbon alternatives like fuel cells make up nearly 100% of new vehicle sales by the end of the 2030s, up from only a few percent today. This will require expanded incentives for electric vehicles coupled with stronger climate pollution standards for cars and trucks (like the ones the Trump Administration is trying to roll back).

Deep decarbonization studies also often rely on biofuels as a large source of transportation emissions reductions, although measuring the full emissions footprint of biofuels is challenging and controversial.  What we do know is that, for applications such as jet fuel, electrification is unlikely, and therefore deployment of verifiably sustainable biofuels could play an important role in getting to 100% clean.

Taken together, transitioning to a 100% clean economy by midcentury will require an unprecedented transformation of our economy. Understanding the core elements of a 100% clean economy can help us design policies to accelerate the needed transition to a more efficient economy that relies more heavily on clean electricity and low carbon fuels, and which reduces as much climate pollution as it produces.

The good news is there are signs of progress. Several pieces of federal climate legislation have been introduced by members of both parties that would begin to put us on the right path. While a 100% clean economy ultimately requires that Congress enact legislation to drive down climate pollution, innovation is also an important piece of the climate puzzle, and it currently enjoys bipartisan support in Congress. And states across the country are already taking action.

100% clean is 100% achievable: now we need to build the political will to make it a reality.