The Surprising Facts About the Clean Power Plan: Most States Are Already On Track to Meet 2020 Benchmarks for Reducing Carbon Emissions

, senior energy analyst | June 3, 2015, 8:48 am EDT
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A new analysis released today by UCS shows that most states are already making progress toward cutting carbon emissions from power plants by shifting from coal-fired power to cleaner generation sources like renewable energy, energy efficiency, and natural gas. As a result of recent decisions and state laws that predate the proposed Clean Power Plan, 31 states have already made commitments that would put them more than halfway toward meeting the 2020 benchmarks set out by the EPA, and 14 of those states are already on track to meet or exceed them, including some unlikely suspects.

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Key findings

Our analysis shows that, through decisions already made such as the retirement of uneconomic coal plants, and compliance with existing renewable electricity standards and energy efficiency resource standards, many states all across the country are well positioned to reliably and affordably achieve the 2020 emissions reduction benchmarks set forth in the EPA’s proposed Clean Power Plan. Additional actions, especially further ramping up of cost-effective renewable energy and energy efficiency, can get them all the way toward compliance at modest costs or net savings to consumers.

Links to a slide deck and tables summarizing our findings are at the bottom of this post.

Key Finding #1: All but 4 states have already made decisions that will help cut their power plant emission rates before 2020.

States have already made legal and regulatory decisions that when fully implemented will collectively take the country approximately two-thirds of the way toward the combined state 2020 emissions benchmarks.

Key Finding #2: Current carbon-cutting decisions and actions are sufficient to put 14 states ahead of the emission rate reduction trajectory that the Clean Power Plan sets for them beginning in 2020 (see Figure 1). Collectively, these 14 states represent 34 percent of the U.S. population and 36 percent of U.S. Gross Domestic Product (GDP). Notably, the list includes

  • States that have become national leaders in their commitments to renewable energy and energy efficiency, such as Hawaii, California, Massachusetts, and Maryland;
  • Three of the nation’s most coal power dependent states—Kentucky, Ohio, and New Mexico—primarily due to their recent decisions to retire uneconomic coal plants and replace them with cleaner, cheaper alternatives;
  • States like Delaware, New York, and New Hampshire that are able to meet their benchmarks through collective action with the nine states that are part of the Regional Greenhouse Gas Initiative (RGGI)—a multi-state effort to collectively cap carbon emissions from power plants.
The 14 states that will have met EPA's 2020 benchmarks for emissions reductions based solely on prior actions and decisions.

The 14 states that will have met the EPA’s 2020 benchmarks for emissions reductions based solely on prior actions and decisions.

Key Finding #3: Fully 31 states will be at least halfway towards the 2020 benchmark in the EPA’s emission rate reduction trajectory, 23 of which will be 75 percent of the way there (Figure 2). Combined, these 31 states account for 71 percent of the U.S. population and 73 percent of U.S. GDP. Strikingly, nine of these states rank in the top third of coal generating states nationwide, illustrating that even the most coal-dependent states are already initiating the transition to lower carbon power sources.

Fully 31 states will be more than halfway toward meeting EPA's 2020 benchmarks for emissions reductions, representing 73 percent of U.S. GDP.

Fully 31 states will be more than halfway toward meeting the EPA’s 2020 benchmarks for emissions reductions, representing 73 percent of U.S. GDP.

What does it mean to meet a 2020 benchmark, anyway?

Once the Clean Power Plan is finalized this summer, states will have 1-2 years to develop compliance plans and up to 3 years for multi-state plans. Those plans must show how the state will meet an average annual carbon emission rate between 2020 and 2029 (called an interim target) and a final 2030 emission rate goal.

To help meet the interim target, the EPA suggested an emission rate reduction trajectory (or glide path) for each state starting in 2020 and continuing through 2029. Efforts to reduce power plant carbon emissions between 2012 and 2020 are eligible to help put states on their proposed emissions reduction pathway. In other words, states don’t need to wait to take action. And a vast majority of them are moving ahead.

Our analysis examines specific types of actions states have taken or will take between 2012 and 2020 that can help them cut emissions by 2020: retiring coal plants; deploying additional renewable energy to meet mandatory state renewable electricity standards (RES); and ramping up energy efficiency to meet mandatory state energy efficiency resource standards (EERS).

We analyze how far these planned actions will take states toward achieving the 2020 emission rate proposed in the EPA’s 2020-2029 glide path. While the rule does not require states to meet this 2020 emission rate, it is a helpful benchmark against which to measure a state’s progress toward meeting the interim and final targets of the CPP.

What exactly is considered a planned action?

In our analysis, we looked at specific actions that states have already taken or will take between 2012 and 2020 that reduce carbon emissions. Our aim was to construct a conservative estimate of states’ progress toward their benchmark emission rates in 2020.

  • Coal Retirements: For coal plant retirements, we conservatively assume that all of that retired generation will be made up by natural gas combined cycle (NGCC) power plants, which could come from ramping up existing NGCC plants, building new NGCC plants, or converting existing coal plants to natural gas. We used data, primarily from SNL Energy, on all announced coal plant retirements scheduled to take place between 2012 and 2020. The dataset reflects any announcements as of May 2015.
  • Renewable Energy: We only included renewable energy that would be brought on line between 2012 and 2020 to meet mandatory state RESs, based on projections from Lawrence Berkeley National Lab. We conservatively did not include voluntary state RES goals in this analysis, nor do we include additional renewable energy investments—beyond mandatory requirements—that are being deployed in many states like Texas and Iowa simply because it is cost-effective to do so.
  • Energy Efficiency: We made similarly conservative estimates for energy efficiency improvements from mandatory EERS, based on data from the EPA. We did not include voluntary energy efficiency or conservation goals, or other complementary state policies focused on energy efficiency.
  • Nuclear energy: In keeping with the EPA’s draft proposal, we included under construction nuclear plants that are scheduled to come on line by 2020 as committed actions by states that would help them meet their 2020 emissions benchmarks.
  • Carbon caps: The nine states that participate in RGGI plus California all have mandatory carbon caps in place that will cut their emissions sufficiently so that they can meet the 2020 benchmarks.

Emission rates calculations are all adjusted according to the EPA’s proposed building blocks formula to take account of under construction natural gas and nuclear power capacity, as well as 6 percent of the generation from EPA’s estimate of existing “at-risk” nuclear plants.

The path forward

In short, states in every region of the country are demonstrating that they can cost-effectively and reliably transition to low-carbon power sources. This conservative look at state progress toward carbon emission reductions by 2020 suggests that states are well on their way toward meeting the EPA’s targets. States can and should continue to invest heavily in renewables and efficiency to further their progress to a clean energy economy.

Download additional materials on our analysis:

Overview of Analysis and Results

Table of State Level Results

View a slide show of our analysis:

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  • Phil the Pill


    I disagree with you that a state like Delaware is ahead of the curve because, as you say, it can “meet [it’s] benchmark through collective action with the nine states that are part of the Regional Greenhouse Gas Initiative (RGGI).” To my knowledge (and correct me if I’m wrong), Delaware has not entered into a regional agreement, permissible under the CPP, with the other RGGI states. Your own analysis shows that it is 88% of the way towards meeting it’s 2020 benchmark, and while this is laudable, it is not ahead of the emissions rate reduction curve. I mean, it’s not like Delaware can just borrow or claim as its own the surplus reductions from Maine because they both participate in RGGI, although this is what you appear to be arguing. I guess I’m taking exception to how you translate the double asterisk in the Table of State Level Results to your inclusion of three states (Delaware, NY, and NH) among the other 11 that are on target to exceed 2020 emissions reduction benchmarks.

    Also, it would be great if you could post your methodology and data. As someone who works in DE, I’d like to see how you arrived at the 88% figure.


    • Jeremy

      Hey Phil,

      Yes, we are implicitly assuming that the RGGI states will agree to comply with the Clean Power Plan as a group. There is no reason to believe otherwise, given that a system like RGGI will count toward compliance, at least as described by the proposed rule. The RGGI states have already shown that they can obtain low cost emissions reductions and stimulate local economies by working together.

      You are quite correct, however, that the states will have to collectively decide to submit a joint compliance plan. They will also have to agree to continue to lower the cap through 2030. Given their strong record of success, it seems like a safe assumption that they will continue along that path.

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  • Josh

    It’s become apparent that in our modern day America that the prospects of our environment has become a more critical. President Obama always seems to stress the idea that current politicians shouldn’t see environmental policies as a political stance, but instead as a necessity for the better of the people. As more states try to hit this bench march by 2020 it becomes more clear on what we want as a nation. It becomes essential to note that every company is going to be compliant with this clean power plan. Ideally, a variety of companies will find this plan to be coherent, but to what extent will these big companies reduce carbon emissions? The point I’m trying to make is that we can only go further as a state to improve how energy is managed. Once we hit 2020 what then? You then must think who has the most influence in making these environmental decisions and take into account that the way our government is ran ultimately alters our way of life. Despite this being a very simple notion, a lot of people don’t note that we can also alter the way our government functions. We can do the little things that we deem as “saving the environment” or “saving energy”, but it’s ultimately up to our Federal Government and various corporations to make a profound impact on the prospects of our environment and society as a whole. #UCIGCB2015

  • MJ Williams

    Vermont already has one hundred percent clean energy, right? That’s why it’s gray on your map?

    But more importantly, wanted to say: I wish you would not have called nuclear energy “clean” !!!

    • Ed Norris

      It is for the purposes of this issue. It’s CO2 emissions are as low as wind’s, and it’s safety record, so often maligned, has as few deaths associated with it as wind does as well. Cancer rates are higher in many places with no nuclear plants compared to places that do have them.

      In addition, nuclear waste, about a coke can sized container of radioactive material for an American’s electricity usage in a full lifetime, is manageable. At least theoretically. Natural gas, touted as a “bridge fuel,” is not. We have no way to mitigate those levels of CO2 emissions without giving up lands already developed, or worse, devoted to agriculture. In other words, nuclear gives us a shot of avoiding the complete collapse of all the ice sheets, all coastal cities with that, and the desertification of huge swaths of inhabited lands needed to support human life and biodiversity. Getting down to zero emissions CO2 without nuclear is a *really* steep road not likely to be overcome.

      On top of that, Gen III and IV nuclear have passive shutdown as features, making another Fukushima impossible, and Gen IV nuclear could eat the radioactive waste we already have and reduce it’s time to safe levels by a factor of about one thousand- from hundreds of thousands of years to about 300. We need nuclear, especially the cutting edge versions that China and India are racing ahead of us on. What we don’t need is fracking and unconventional oil. Ask Dr. James Hansen, environmental activist formerly of NASA that first raised the alarm about global warming during the Reagan administration. He’s advocated for nuclear over fracking for years.

      • Erik Blakeley

        That is OK as long as the nuclear lobby don’t get into bed with the anti-renewables lobby to suggest that we don’t need to bother with renewables. Furthermore I think we need to be skeptical about statements like “Gen III and IV nuclear have passive shutdown as features, making another Fukushima impossible” I am old enough to remember being taught at school that the magnetic lifting of control rods made the Chernobyl/Fukushima generation of reactors failsafe. Not only do I feel deceived in that people should have been saying that it was safe just as long as the cooling systems kept on going for at least a couple of days after a shut down (not quite so failsafe then) but the point about any of these extreme accidents is that they are not entirely predictable. We may have designed out another Fukushima but we don’t know for sure what other routes to catastrophic failure are out there. On balance I think that the scale of the problem means that we need to use all low carbon techs including nuclear but that nuclear should be literally the last thing that we do. Another point is that the global problem of climate change needs a global solution. If we prioritize nulcear to the extent of starving renewables of investment as happened in the 1970s in the UK we need to give it to North Korea, Somalia, Iran. Who’s up for that then?

    • Jeremy

      Vermont is not included in our analysis because it has no emissions rate reduction targets under the Clean Power Plan.

      We generally refer to nuclear as low carbon. It’s included in this analysis because the EPA has included it in setting state emission rate reduction targets.


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  • hotdamn

    What are the four states of Key Finding #1? I couldn’t find it in the link to the analysis slide deck. In fact, that slide deck does not include all of state results. Are these presented somewhere else?

    • Jeremy

      Hi there. The four states are Alaska, Idaho, North Dakota, and Louisiana. These have no shading in the map on slide 10.

      The table with all the state level results doesn’t work well as a slide, so it is presented separately. Click on the “Table of State Level Results” link at the end of the blog post and you’ll see the % progress number for all states. (Well, except Vermont, which doesn’t have a target under the Clean Power Plan.)

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