Should EPA’s proposed carbon pollution rule be tougher?


While we are studying the new EPA proposed rule on cutting CO2 emissions from power plants, and the immediate and inevitable controversies surrounding it, we can also look ahead and identify some next steps in promoting science-based policy action on global warming. Here’s one that we support, for starters.

In the sixth year of Obama’s presidency and the fifth year after issuing its Endangerment Finding on greenhouse gases, the Environmental Protection Agency has finally proposed a rule aimed at reducing carbon dioxide emissions from existing U.S. power plants.

Core documents:

EPA Clean Power Plan Proposed Rule home page (links to the proposed rule, regulatory impacts analysis, EPA fact sheets, press release, technical documents, and procedure for public comment and participation)

Proposed rule: Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units

Regulatory Impact Analysis for the Proposed Carbon Pollution Guidelines for Existing Power Plants and Emission Standards for Modified and Reconstructed Power Plants

Credit to the agency for getting this done. I believe the seeming slow-walking of this regulatory process (even a proposed rule on future power plants has yet to be finalized) has been due to White House politics, not to EPA’s lack of diligence in doing its job. For several years the White House was enveloped in a kind of silence on climate change, which didn’t even figure in the 2012 presidential campaign. Finally, one year ago, Obama directed EPA to develop a rule on existing power plants, to be proposed by June 2014 and finalized by June 2015.

Obama’s announcement of a Climate Action Plan and EPA’s regulatory movement can be seen as an indicator that public support for action on global warming is building, and that the administration believes that this presents a political opportunity. It’s a sign that, after years of delay, setbacks, and attacks on climate science and scientists, the pendulum may be swinging in the direction of science-based policymaking on climate.

It seems to me there are several arenas for action that could add to the movement in that direction. My formulation of this is not in terms of “what Obama should do” (Joe Romm at Climate Progress has a good post that’s expressed in terms of assessing Obama’s next steps and climate ‘”legacy”) – rather, it’s about what we as citizens can do to hold government accountable for strengthening the connection between climate science and policymaking.

First: During the public comment and review period, make the case for strengthening the rule

Under EPA’s proposed rule, by 2020 states will have to cut their carbon emissions from existing power plants by 25 percent relative to 2005 levels. By 2030, emissions will have to be 30 percent below the 2005 baseline.

States would be allowed to develop implementation plans, which could include a flexible array of emissions-cutting options, including fuel-switching from coal to natural gas, adding renewable energy sources, investing in energy efficiency gains, or even initiating or joining an existing cap-and-trade system. Because these options include actions beyond the limits of the particular power plants, it can be assumed that the question of whether EPA has the authority to establish such a mandate will be the basis of some of the legal challenges that will be leveled the rule by its opponents once it is finalized. It is important that the full range of flexible options be included, and upheld, both in order to get the necessary quantity of emissions reductions and to achieve them in the most economical manner.

Using 2005 as a baseline year for the emissions reduction requirement is advantageous both for the regulated utilities and for states that have already taken steps to reduce emissions. U.S. power plant emissions in 2005 were at a pre-Great Recession high level. In 2005, U.S. power plants emitted more than 2.4 billion tons of carbon. By 2012, after the Great Recession, and after several years of the current move toward switching from coal to natural gas, and including some gains in energy efficiency and renewable energy deployment, carbon emissions were down to about 2 billion tons. EPA says carbon from power plants is down 16 percent.

Under the proposed rule, carbon emissions would have to drop to about 1.8 billion tons by 2020, and to 1.68 billion by 2030. Thus, since 2005 emissions have already come down enough to get about half-way to the 30 percent goal. States will get to factor in those gains to their 2030 targets. (Had the current year been used as the baseline, the required reductions by 2030 would be on the order of 20 percent.)

The E.P.A. projects that, under the proposed rule, about 32 percent of the U.S. electricity mix will still come from coal in 2030, down from about 39 percent in 2012. Coal would remain the single largest energy source for power plants. The projected decline in coal’s share would be counterbalanced by an increase in natural gas, from 29 percent in 2012 to 31 percent in 2030, and in non-hydro renewables (wind, solar, biomass, geothermal), from 5 percent in 2012 to 9 percent in 2030. Fossil fuels (coal plus natural gas) would continue to supply 63 percent of the energy for electricity, compared to 68 percent currently. (The figures come from the EPA Regulatory Impact Analysis, as noted by Roger Pielke Jr.)

Viewed in these terms, this does not appear to be a particularly radical change in the mix, especially given the daunting reality of global climatic disruption, the necessary major cuts in emissions worldwide over the next several decades that would be needed in order to forestall catastrophic impacts, and the radical transformation that must be expedited in order to accomplish that goal.

The new rule can be viewed, in practical terms, as a great opportunity to create a political and regulatory game-changer for the U.S. It can be viewed as a potential energy supply trajectory-changer. It can potentially serve as a signal that the U.S. is getting serious about climate change, and thus facilitate reaching a better international agreement on climate policy in 2015. In its final form, will it live up to this potential?

During the next phase of the action, a one-year public comment and review period before the rule becomes final, and with another year after that for states to submit their implementation plans, we can ask: can this rule, must it, be made tougher?

States vary widely in their current mix of fuel sources for power plants. Some are far more dependent on coal than others, for one thing. The proposed rule takes this into account, setting individual goals for each state. The goals for each state are set based on an estimate of what EPA believes that state can reasonably be expected to achieve, starting from the current technology mix. So, we can ask: how did EPA arrive at the proposed state-by-state goals, and should the states be expected to make deeper cuts more quickly?

Ben Adler at Grist has this:

“The key will be how they solicit comments on more ambitious targets,” says David Hawkins, NRDC’s director of climate programs. “We need an open mind on their part to consider evidence we can do better.”

Environmental experts generally agree that more ambitious targets are possible, especially if the EPA is going to make the rules extend all the way to 2030. Since technologies to produce energy more cleanly keep getting better and cheaper, the targets should grow significantly more ambitious over the course of the next decade.

“We’ll be pushing for 2020 reductions of at least 35 percent below 2005 levels, ramping up to more ambitious targets later in the decade,” says Hawkins.

Of course, the anti-regulatory, fossil-funded attack machine is already in full swing, claiming the rule will wreak havoc with the economy and with jobs. Countering this line of attack will be one essential component of supporting the rule, while calling for more ambitious targets. Putting down a couple of early markers on that score:

Peter Gleick President, Pacific Institute: Will New Climate Regulations Destroy the Economy? (Hint: No.)

There is a long history of claims that new rules to protect the environment or human health will seriously harm the United States economy. These claims are political fodder, they are provocative, and they are always wrong. In fact, the evidence shows the opposite: environmental regulations consistently produce enormous net benefits to the economy and to human health. In 2008, for example, the United States’ environmental technologies and services industry supported 1.7 million jobs. The industry at that time generated approximately $300 billion in revenues and exported goods and services worth $44 billion.

A Siegel at Get Energy Smart Now!: Reasons to apply a skeptical mindset to claims of disaster due to @EPA regulation …

Much will (and should be said) about the EPA rules released this morning. (Questions such as … Whether the 2005 starting point is gamesmanship to make the targets look bigger? (Well, yes …) Whether the rules go far enough? (Well, no …) Whether the coal industry is bearing enough of the financial burdens for the damages burning coal causes? (Hmm, absolutely not.) Etc …) But most simply … That the EPA is moving forward with guidance on coal fired plants  is — seriously — good.  That President Obama and the Administration are demonstrating a willingness to take — in wide public view and in the face of serious political interest pushback — Administration action in the face of a do-nothing Congress is good. That this is a step in the right direction is — without question — good.

What is not good is that, inevitably, the entire discussion will exaggerate the costs of action and understate the benefits of action.

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2 Responses to Should EPA’s proposed carbon pollution rule be tougher?

  1. cosmicomics says:

    “The projected decline in coal’s share would be counterbalanced by an increase in natural gas, from 29 percent in 2012 to 31 percent in 2030…”

    Much of the U.S. emissions reduction strategy has been based on replacing coal with natural gas, and the widely accepted assumption has been that the reserves made available by fracking justified this. A number of critics have argued that the industry reserve estimates are exaggerated and that steep decline rates, the constant need for new wells, and the peaking of sweet spots mean that the fracking revolution is better seen as a short-lived Ponzi scheme. Now, the world’s most influential energy organization, the IEA, seems to have approached this point of view. In its recent report, World Energy Investment Outlook, it has drastically lowered its evaluation of U.S. energy potential and writes that it expects shale investment and then production to fall from the mid 2020s (pp 59-60). Others expect the fall to occur earlier. In either case, this is not the basis for a mid to long-term emissions reducing energy strategy. What would happen if the U.S. expands gas infrastructure and then finds that gas is not an economically viable solution? In the absence of sufficient renewable generating capacity, would there then be a hasty reversion to coal?

  2. jeff cobb says:

    From Dr. Howarth:

    Statement on EPA Draft Plan Released June 2, 2014 on “Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units” RIN 2060-AR33
    Robert W. Howarth, Ph.D. The David R. Atkinson Professor of Ecology & Environmental Biology Cornell University, Ithaca, NY 14853 USA June 7, 2014

    I have carefully read the 645-page Draft Plan. There is much to commend in the Plan’s goals to reduce carbon dioxide emissions and to promote more production of electricity by renewable sources and more efficient end use of electricity. However, the Plan has a fundamental flaw: it addresses only carbon dioxide emissions, and not emissions of methane, another critically important greenhouse gas. This failure to consider methane causes the Plan to promote a very poor policy – replacing coal-burning power plants with plants run on natural gas (see pages 33-34) – as one of the major four building blocks of the Plan. Recent research indicates that the greenhouse gas footprint of generating electricity from natural gas can exceed that of coal-fired plants (Alvarez et al. 2012; Howarth et al. 2014 and references therein). The Plan should be revised to reflect the importance of methane and the extent of methane emissions from using natural gas. While phasing out coal is a desirable goal, replacing coal with natural gas trades one problem for another, reducing carbon dioxide emissions but increasing methane emissions to such an extent as to cause even greater global warming.

    “Methane” is mentioned only five times in the 645 pages. The first time is on page 59, where it is stated that EPA could not monetize the consequences of nitrous oxide and methane emissions, and that the Plan therefore focuses only on carbon dioxide emissions. The second time is footnote #13 on page 59, where it is stated that “although CO2 is the predominant greenhouse gas released by the power sector, electricity generating units also emit small amounts of nitrous oxide and methane….” Note that in both the first and second mention of methane in the Plan, nitrous oxide comes before methane, even though methane is far more important in global warming (IPCC 2013). Further note that the Plan seems to limit the focus to emissions at electric-power generating plants rather than include full life-cycle emissions. The third time is on page 174, where the Plan states “we have also analyzed potential upstream net methane emissions impact from natural gas and coal for the impacts analysis. This analysis indicated that any net impacts from methane emissions are likely to be small compared to the CO2 emissions reduction impacts of shifting power generation from coal-fired steam EGUs to NGCC units.” And the fourth and fifth times are late in the Plan, where it is mentioned that methane is emitted from landfills and where natural gas is defined.

    Early in the Plan (page 19), the focus on carbon dioxide is justified by stating “CO2 is the primary GHG pollutant, accounting for nearly three-quarters of global GHG emissions (see footnote 1) and 82 percent of U.S. GHG emissions. (see footnote 2).” These statements do not accurately reflect the most recent and best science on this topic. Footnote #1 refers to the IPCC (2007) report and is based only on comparing methane emissions and carbon dioxide emissions on a 100-year time scale. In the more recent IPCC (2013) synthesis, the IPCC explicitly states that “There is no scientific argument for selecting 100 years compared with other choices,” and that “The choice of time horizon…depends on the relative weight assigned to the effects at different times.” Because the short-term dynamics of the climate system are far more responsive to methane than to carbon dioxide (UNEP/WMO 2011; Shindell et al. 2012), comparing methane and carbon dioxide on shorter time scales is essential if we are to avoid warming the Earth to temperatures that greatly increase the risk of tipping points in the climate over the coming 15 to 35 years (see Howarth et al. 2014 and references therein). At these shorter time scales, the IPCC (2013) states that the global emissions of methane are actually greater than (slightly, for the 10-year time frame) or 80% of (for the 20-year time frame) those of carbon dioxide in terms of their influence on global warming; at both of these shorter time scales, carbon dioxide is responsible for less than half of global GHG emissions, not three-quarters.

    Similarly, the statement that 82% of US greenhouse gas emissions are due to carbon dioxide (referencing footnote #2, which is the EPA greenhouse gas inventory) is highly misleading. This also is based solely on comparing methane and carbon dioxide on a 100-year time scale, and further uses outdated global warming potentials (from earlier versions of the IPCC, not from IPCC 2013, where the global warming potential for methane has been substantially increased). Also, the best available evidence indicates that the EPA estimates for methane emissions in the US are much too low (Miller et al. 2013; Brandt et al. 2014; Howarth et al. 2014). EPA aggravated this by reducing their methane emissions for the natural gas industry by a factor of two in 2013, despite increasing evidence that their estimates were already too low (Miller et al. 2013; Brandt et al. 2014; Howarth et al. 2014). The Inspector General for the EPA has called for an improved approach by EPA for estimating methane emissions from the oil and gas industry (U.S. Environmental Protection Agency Office of Inspector General 2013).

    In addition to ignoring the global-warming consequences of methane and natural gas, the Plan does not adequately consider the public health consequences. The Plan states that “actions taken to comply with the proposed guidelines will reduce emissions of CO2 and other air pollutants, including SO2, NOx and directly emitted PM 2.5, from the electric power industry” (page 51). Reducing these pollutants – which largely come from combusting coal – is desirable. However, the use of natural gas is leading to highly elevated levels of ground-level ozone in many areas as well as elevated concentrations of benzene and other toxic and carcinogenic hydrocarbons. The Plan completely ignores these other pollution issues.

    A sound government policy on climate simply cannot focus solely on carbon dioxide and ignore methane. The number one source of methane pollution in the US is the natural gas industry (Howarth et al. 2012), and the US should take urgent steps to reduce this methane pollution. The Plan will require substantial revision using better quality and more recent science to consider both carbon dioxide and methane emissions.

    References cited:

    Alvarez RA, Pacala SW, Winebrake JJ, Chameides WL, and Hamburg SP. 2012. Greater focus needed on methane leakage from natural gas infrastructure. Proceedings of the National Academy of Sciences, doi 10.1073/pnas.1202407109.

    Brandt AF, Heath GA, Kort EA, O’Sullivan FO, Pétron G, Jordaan SM, Tans P, Wilcox J., Gopstein AM, Arent D, Wofsy S, Brown NJ, Bradley R, Stucky GD, Eardley D, and Harriss R. 2014. Methane leaks from North American natural gas systems. Science 343: 733-735.

    Howarth RW. 2014. A bridge to nowhere: Methane emissions and the greenhouse gas footprint of natural gas. Energy Science & Engineering, doi 10.1002/ese3.35 ttp://

    Howarth, R. W., D. Shindell, R. Santoro, A. Ingraffea, N. Phillips, and A. Townsend-Small. 2012. Methane emissions from natural gas systems. Background paper prepared for the National Climate Assessment, Reference # 2011-003, Office of Science & Technology Policy Assessment, Washington, DC.…/Howarth%20et%20al.%20…

    IPCC. 2007. IPCC Fourth Assessment Report (AR4), Working Group 1, The Physical Science Basis. Intergovernmental Panel on Climate Change.…/ar4/wg1/en/contents.html

    IPCC. 2013: Climate Change 2013: The Phsical Science Basis. Intergovernmental Panel on Climate Change.

    Miller SM, Wofsy SC, Michalak AM, Kort EA, Andrews AE, Biraud SC, Dlugokencky EJ, Eluszkiewicz J, Fischer ML, Janssens-Maenhout G, Miller BR, Miller JB, Montzka SA, Nehrkorn T, and Sweeney C. 2013. Anthropogenic emissions of methane in the United States. Proceedings of the National Academy of Sciences, doi 10.1073/pnas.1314392110

    Shindell D, and others. 2012. Simultaneously mitigating near-term climate change and improving human health and food security. Science 335: 183-189.

    UNEP/WMO. 2011. Integrated Assessment of Black Carbon and Tropospheric Ozone: Summary for Decision Makers. United Nations Environment Programme and the World Meteorological Organization. Nairobi, Kenya.

    U.S. Environmental Protection Agency Office of Inspector General. 2013. EPA needs to improve air e missions data for the oil and natural gas production sector, EPA OIG, Washington, D. C.

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