The Center for Climate and Energy Solutions seeks to inform the design and implementation of federal policies that will significantly reduce greenhouse gas emissions. Drawing from its extensive peer-reviewed published works, in-house policy analyses, and tracking of current legislative proposals, the Center provides research, analysis, and recommendations to policymakers in Congress and the Executive Branch. Read More
Comments of the Center for Climate and Energy Solutions on Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units
Summary of C2ES December 2014 comments on EPA’s proposed Clean Power Plan “Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units”
On June 18, 2014, EPA proposed carbon dioxide emission standards for existing power plants, also known as the Clean Power Plan, implementing its authority under section 111(d) of the Clean Air Act. More information on the proposed rule can be found here. On December 1, 2014, C2ES submitted formal comments to EPA in response to the proposed rule. The comments are summarized below.
Market-based mechanisms should be used to reduce carbon emissions: A nationwide, comprehensive, market-based program to reduce carbon emissions would be more effective and less costly than a state-by-state, sector-by-sector approach. Given the urgency of the need for climate policy action, and since such a program would require legislation that is unlikely in the near-term, EPA is appropriately using its authority under the Clean Air Act to reduce emissions from the power sector.
The Clean Power Plan is a stepping-stone to a comprehensive, national program: In finalizing the Clean Power Plan, EPA should do what it can to move individual actions toward a broader, nationwide program. This would include provisions that enable carbon-cutting technology deployment and policy consistency and compatibility across state lines.
State flexibility in the Clean Power Plan is critical: Since each state faces unique challenges when addressing its power sector, EPA has appropriately included several important flexibility elements in the proposal. States all have customized targets based on potential, and are authorized to work together or comply alone, pursue a rate- or mass-based standard, and drive emission reductions using any number of established or novel policy tools.
EPA-defined model provisions could encourage interstate consistency: Model provisions for topics such as how to use a carbon fee for compliance or what measurement, recording, and verification (MR&V) protocols to use to track efficiency measures could help states meet the deadline for their plans and could promote consistency across states.
Renewable energy projections should be based on a state’s market potential: Basing renewable generation projections, used in building block two of the Best System of Emission Reduction (BSER) determination, on regional benchmarks of Renewable Portfolio Standards (RPS) leads to inconsistent and inequitable results. This projection should instead be based on the potential market penetration of renewable generation in each state.
Unaffected generators should be able to opt-in: Generators not covered in the proposal, such as those under 25 megawatts or not connected to the electricity grid, should be allowed to opt-in such that their emission reductions can be credited.
Assuming a phase-in from coal to natural gas could increase state flexibility: The interim compliance targets, generally driven by a projected sudden shift from coal to gas, are so stringent that they could force some states to invest in new natural gas capacity to replace retired coal. EPA should consider softening these interim targets, coupled with a strengthening of final targets, to ensure states have adequate time to invest in long-term solutions like renewable generation.
Support for nuclear generation should be strengthened: EPA should consider factoring 100 percent of existing nuclear generation in its target and compliance calculations to ensure states are strongly encouraged to maintain their existing fleets. EPA should also explore means to increase credit for nuclear units currently under construction to recognize the investment and foresight of the relevant states.
A single year should not be used as the hydropower generation baseline: States that rely heavily on hydropower can experience significant year-to-year variability in fossil generation to balance the variability in water resource availability. EPA should consider a multi-year baseline to more realistically account for each state’s current reliance on fossil generation.
States should be encouraged to improve energy efficiency regardless of when or where the emission cuts take place: EPA should ensure states are able to give equal credit to any efficiency or conservation measure that reduces electricity demand in the compliance period, regardless of when the measure was enacted and even if it leads to a reduction in electricity imports in addition to a reduction in domestic generation.
New load that cuts economy-wide emissions should not be discouraged: As proposed, the Clean Power Plan would discourage many states from adding new load that actually cuts carbon emissions on a system-wide basis. For example, electric vehicles add to power plant emissions but more than offset this increase with a decrease in gasoline emissions. EPA should adjust the proposal to ensure such loads are not discouraged.
All types of demand reduction should be recognized: Assuming appropriate MR&V protocols are used, states should be able to recognize and reward credit for all demand reduction driven by efficiency policies or investments. For example, if a water utility reduces its electricity demand by reducing the demand for water (thereby reducing demand for pumping and treatment), this reduction should be creditable as part of the state's implementation of the Plan.
The climate targets announced this month by the United States and China will require a significant effort beyond a business-as-usual scenario for both countries. More details will likely follow in the weeks and months ahead, but here is what we know so far for each country.
China announced a goal for its greenhouse gas emissions to peak by 2030 or sooner. This marks the first time that China has pledged a peak or absolute target for greenhouse gas emissions, rather than an intensity-based target. In business-as-usual scenarios, China’s emissions wouldn’t peak until 2040 or later.
China also announced it would boost its share of zero-carbon energy, which includes nuclear, hydropower and renewables, to 20 percent – up from about 13 percent today. Meeting that goal will require a substantial build-out of nuclear power stations, hydroelectric stations, wind turbines, and solar panels, as well as transmission and other infrastructure. In a separate announcement, China said it plans to cap its coal consumption by the year 2020.
China can’t, as critics claim, sit idly by for 15 years and reach these targets. It will need to significantly restructure its energy system. China will have to add more than 1 GW of zero-carbon power a week for the next 15 years – an amount roughly equal to the entire installed electricity capacity of the United States.
Anyone who needs to plan for future risks -- whether a city manager, a state official, or a business leader -- needs good information that’s easy to find and easy to use. The federal government took an important step to help managers plan for the impacts of climate change with the release this month of the Climate Resilience Toolkit.
This new online portal offers a wide range of resources and interactives that consolidate some of the “greatest hits” from federal climate data sets, guidance for resilience planning, and examples of resilience projects.
The toolkit is likely to be especially helpful for communities and businesses in the early stages of resilience planning, or for individuals who want to know more about managing climate risks. I took a spin through the toolkit’s resources and here’s my take on some of its components.
The toolkit promotes a five-step process for building resilience: Identify the Problem, Determine Vulnerabilities, Investigate Options, Evaluate Risks and Costs, and Take Action.
The Climate Resilience Toolkit’s five-step process for building resilience.
Statement from Bob Perciasepe
President, Center for Climate and Energy Solutions
On the U.S.-China Joint Announcement on Climate Change
November 11, 2014
The joint announcement by President Obama and President Xi is an extremely hopeful sign. Even if the targets aren’t as ambitious as many might hope, the world’s two largest carbon emitters are stepping up together with serious commitments. This will help get other countries on board and greatly improves the odds for a solid global deal next year in Paris.
These targets will require major undertakings by both countries. Clearly the leaders of the world’s two largest economies have decided the risks posed by climate change justify stronger action to cut carbon emissions. And they’re confident they can keep growing their economies at the same time.
In the case of the United States, the new target is pushing the limits of what can be done under existing law. We can get there if Congress doesn’t stand in the way, and if states roll up their sleeves and work with businesses and other stakeholders to craft smart, practical plans to cut emissions from power plants. But to go much further, we’ll ultimately need Congress to act.
For too long it’s been too easy for both the U.S. and China to hide behind one another. People on both sides pointed to weak action abroad to delay action at home. This announcement hopefully puts those excuses behind us. We’ll only avert the worst risks of climate change by acting together.
Contact: Laura Rehrmann, email@example.com or 703-516-0621
About C2ES: The Center for Climate and Energy Solutions (C2ES) is an independent, nonprofit, nonpartisan organization promoting strong policy and action to address the twin challenges of energy and climate change. Launched in 2011, C2ES is the successor to the Pew Center on Global Climate Change. Learn more at www.c2es.org.
Carbon Pollution Standards
The U.S. Environmental Protection Agency's (EPA) Clean Power Plan, proposed in June 2014, would limit carbon pollution from existing power plants.
Electric power generation is responsible for nearly 40 percent of U.S. carbon dioxide emissions – making it the largest single source. Reducing power sector emissions is a key part of President Obama’s Climate Action Plan, which aims to reduce overall U.S. greenhouse gas emissions 17 percent below 2005 levels by 2020. His June 2013 presidential memorandum directed EPA to set standards for both new and existing plants.
Under the Clean Power Plan for existing power plants, each state has its own target (due to regional variation in generation mix and electricity consumption). Overall, the rule is designed to cut emissions 30 percent from 2005 emissions by 2030, with an interim target of 25 percent on average between 2020 and 2029.
In September 2013, EPA released a “Carbon Pollution Standard for New Power Plants,” replacing a March 2012 proposal. EPA proposed standards for coal- and natural gas-fired plants (measured as tons of greenhouse gas emissions per megawatt-hour of electricity produced) that states would apply at each regulated plant.
EPA will issue the finalize rules for the Clean Power Plan for existing power plants and the Carbon Pollution Standard for New Power Plants in the summer of 2015.
Explore the issues and options involved in EPA regulation of carbon pollution from power plants through the following resources.
- Report: Canadian Hydropower and the Clean Power Plan (April 2015)
- Infographic: Canadian Hydropower and the Clean Power Plan (April 2015)
- Blog: 5 Ideas for EPA's Clean Power Plan (December 2014)
- C2ES Comments on Proposed EPA Rule for Existing Power Plants (December 2014)
- Brief: Cross-State Electricity Load Reductions Under EPA's Proposed Clean Power Plan (November 2014)
- Cornerstone Article: Carbon Pollution Standards for New and Existing Power Plants and Their Impact on Carbon Capture and Storage (September 2014)
- Map: Energy efficiency in the Clean Power Plan (August 2014)
- Map: Renewables in the Clean Power Plan (June 2014)
- Map: Proposed state emission rate targets (June 2014)
- Q&A on EPA Greenhouse Gas Standards for Existing Power Plants (Updated February 2015)
- Graphic: Policy options to reduce carbon emissions in the power sector (June 2014)
- Blog: EPA’s proposed carbon standard for power plants is stringent and flexible (June 2014)
- Event: Carbon Pricing: State and Federal Options (May 2014).
See video of the event, and relevant slides from Dallas Butraw, David Bookbinder, Brian Turner, and Jon Brekke
- C2ES Comments on Proposed EPA Rule for New Power Plants (May 2014)
- Brief: Carbon Pollution Standards for Existing Power Plants: Key Challenges (May 2014)
- Brief: Carbon Pollution Standards for Existing Power Plants: Issues and Options (March 2014)
- Q&A on EPA Greenhouse Gas Standards for New Power Plants (Updated February 2015)
- Blog: EPA’s Regulation of Greenhouse Gases: What are the Facts? (January 2011)
- Brief: Events Leading to Regulation of Greenhouse Gases under the Clean Air Act (March 2010)
- Jonas Monast et al., Enhancing Compliance Flexibility under the Clean Power Plan: A Common Elements Approach to Capturing Low-Cost Emissions Reductions (Durham, NC: Nicholas Institute for Environmental Policy Solutions, 2015).
- U.S. Environmental Protection Agency, Carbon Pollution Standards webpage.
- Presidential Memorandum – Power Sector Carbon Pollution Standards
- Megan Ceronsky and Tomas Carbonell, Section 111(d) of the Clean Air Act: The Legal Foundation for Strong, Flexible & Cost-Effective Carbon Pollution Standards for Existing Power Plants (Washington, DC: Environmental Defense Fund, 2013).
- Samuel D. Eisenberg, Michael Wara, Adele Morris, Marta R. Darby and Joel Minor, A State Tax Approach to Regulating Greenhouse Gases Under the Clean Air Act (Washington, DC: Climate and Clean Energy Economics Project at Brookings, 2014).
- Georgetown Climate Center, Carbon Pollution Standards for Existing Power Plants: State Opportunities and Potential Benefits (Washington, DC: Georgetown Climate Center, 2013).
- Daniel Lashof et al., Closing the Power Plant Carbon Pollution Loophole: Smart Ways the Clean Air Act Can Clean Up America’s Biggest Climate Polluters (Washington, DC: Natural Resource Defense Council, 2013).
- Daniel Lashof and Starla Yeh, Cleaner and Cheaper: Using the Clean Air Act to Sharply Reduce Carbon Pollution from Existing Power Plants, Delivering Health, Environmental, and Economic Benefits (Washington, DC: Natural Resource Defense Council, 2014).
- Jonas Monast et al., Regulating Greenhouse Gas Emissions From Existing Sources: Section 111(d) and State Equivalency, 42 Environmental Law Reporter 10206 (Washington, DC: Environmental Law Institute, 2012).
- James McCarthy, “EPA Standards for Greenhouse Gas Emissions from Power Plants: Many Questions, Some Answers.” Congressional Research Service (CRS). R43127. November 15, 2013.
- Stephen Munro, EPA's Clean Power Plan: 50 chefs stir the pot (Washington, DC: Bloomberg New Energy Finance, 2014).
- National Conference of State Legislatures, States Reactions to Proposed EPA Greenhouse Gas Emissions Standards webpage.
- Conrad Schneider, Power Switch: An Effective, Affordable Approach to Reducing Carbon Pollution from Existing Fossil-Fueled Power Plants (Boston, MA: Clean Air Task Force, 2014).
- Robert Sussman, Power Plant Regulation under the Clean Air Act: A Breakthrough Moment for US Climate Policy? (Charlottesville, VA: Virginia Environmental Law Journal, 2014).
- Jeremy M. Tarr, Jonas Monast, and Tim Profeta, Regulating Carbon Dioxide under Section 111(d) of the Clean Air Act: Options, Limits, and Impacts (Durham, NC: Nicholas Institute for Environmental Policy Solutions, 2013).
- Gregory E. Wannier et al., Prevailing Academic View on Compliance Flexibility under § 111 of the Clean Air Act, RFF Discussion Paper 11-29 (Washington, DC: Resources for the Future, 2011).
While the focus in New York this week has been on world leaders pledging to act on climate change, business leaders also stepped up to be part of the climate solution.
In recent years, many companies have acknowledged the risks of climate change and worked to improve their energy efficiency and sustainability. This week, companies announced new efforts to fund clean energy, reduce carbon emissions, and support a price on carbon.
For example, Bank of America announced an initiative to spur at least $10 billion of new investment in clean energy projects. Hewlett Packard announced plans to reduce emissions intensity of its product portfolio by 40 percent from 2010 levels by 2020.
Many companies joined together to take a stand:
One way to reduce power plant carbon emissions is to reduce the demand for electricity. Encouraging customer energy efficiency is one of the building blocks underpinning the Environmental Protection Agency’s (EPA) Clean Power Plan. But the plan does not distinguish among uses of electricity. That means, without further options, the Clean Power Plan could inadvertently discourage states from deploying electric vehicles (EVs), electric mass transit, and other technologies that use electricity instead of a dirtier fuel.
In all but very coal-heavy regions, using electricity as a transportation fuel, especially in mass transit applications, results in the emission of far less carbon dioxide than burning gasoline. In industry, carbon emissions can be cut by using electric conveyance systems instead of diesel- or propane-fueled forklifts and electric arc furnaces instead of coal boilers.
Under the proposed power plant rules, new uses of electricity would be discouraged regardless of whether a state pursues a rate-based target (pounds of emissions per unit of electricity produced) or a mass-based target (tons of emissions per year).
EPA has a few options to make sure regulations for power plants would not discourage uses of electricity that result in less carbon emissions overall.
The 113th Congress (2013-2014) is on track to be one of the least productive and most divided in history. No legislation explicitly mentioning climate change has been enacted into law, but more bills and resolutions related to climate change have been introduced in this Congress than in the previous one. (For brevity, we refer to all legislative proposals, including resolutions, and amendments, and draft bills, as “bills.”)
Only two bills loosely related to climate change (though not directly referencing it) have been passed and signed into law: the Disaster Relief Appropriations Act and the Hurricane Sandy Relief bill, which provided $17 billion and $9.7 billion, respectively, to cope with Sandy’s aftermath.
Of the 221 bills introduced that explicitly reference climate change or related terms, such as greenhouse gases or carbon dioxide, the majority support climate action. These focus primarily on building resilience to a changing climate, supporting the deployment of clean energy, and improving energy efficiency. A number would use some form of carbon pricing to reduce emissions.