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.
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)
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.