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”

Read the full comments here (PDF).

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.

General Comments

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.

Energy Generation

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.

Energy Efficiency

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.


US-China climate goals go well beyond business as usual

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.

Climate Resilience Toolkit is important resource

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.

Bob Perciasepe's statement on US-China climate announcement

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, rehrmannl@c2es.org 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.

Companies are part of the equation to address climate change

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:

Don't toss out the good electricity with the bad

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.

Climate Interest, But No Action in the 113th Congress

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.

President Obama's Climate Action Plan: One Year Later

President Obama's Climate Action Plan: One Year Later

June 2014

Download the full brief (PDF)

One year after President Obama announced his Climate Action Plan, the administration has made marked progress in its initial implementation. The plan, announced June 25, 2013, outlines 75 goals in three areas: cutting carbon pollution in the United States, preparing the United States for the impacts of climate change, and leading international efforts to address climate change. The administration has made at least some progress on most of the plan’s 75 goals; many of the specific tasks outlined have been completed. In several key areas, the administration has taken important first steps, but it is too early to gauge their success or ultimate impact.



Risky Business report shows need to act on climate change

You expect a business leader to keep a close eye on the bottom line and to act when a threat is clear. As C2ES and others have noted, it is increasingly clear to many business leaders that climate change is a here-and-now threat that we all -- businesses, government and individuals -- must address.

Today’s “Risky Business” report lays out in stark numerical terms the likely economic impact of climate change on U.S. businesses and the U.S. economy. The initiative – co-chaired by former New York City Mayor Michael Bloomberg, former Treasury Secretary Henry Paulson, and former hedge fund manager Tom Steyer – brings high-profile attention to this issue in the hopes that highlighting the risks and potential costs will help spur action to manage the impacts and curb climate-altering emissions.

The report’s outline of the many costs of climate impacts is likely an underestimate. For example, the impacts of diminishing groundwater are difficult to calculate and are not included.

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