Me to the EPA: Increase Renewables, Limit Carbon, and Protect Coal Miners

, , senior energy analyst | July 30, 2014, 2:53 pm EDT
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Today I testified at the Environmental Protection Agency’s (EPA’s) public hearing in Washington, DC on the proposed carbon standard for existing power plants. My prepared remarks are below.

Testimony of Dr. Jeremy Richardson at EPA’s Public Hearing on Carbon Pollution Standards for Existing Power Plants, on behalf of the Union of Concerned Scientists

July 30, 2014

Thank you for the opportunity to testify today in support of strong carbon pollution standards for existing power plants.

My name is Jeremy Richardson and I am a senior energy analyst at the Union of Concerned Scientists (UCS). UCS is the nation’s leading science-based nonprofit working for a healthy environment and a safer world.

I have a unique perspective on reducing greenhouse gas emissions from the burning of fossil fuels. As a scientist, I understand the urgency to reduce greenhouse gas emissions to protect the planet’s climate. As the brother, son, and grandson of West Virginia coal miners, the question of how we go about tackling climate change is deeply personal to me.

First, on behalf of UCS’s more than 450,000 supporters, I want to say today that we strongly support the Environmental Protection Agency’s (EPA’s) efforts to limit carbon emissions from fossil fuel-fired power plants under the Clean Air Act. Simultaneously, I want to emphasize the need for special consideration for the families and communities facing the negative consequences of the transition to a cleaner, low carbon energy system.

Human-induced climate change is already having impacts that are being felt by people here in America and around the world. If we collectively fail to make deep reductions in our carbon emissions, we will greatly increase the risk of serious economic, health, and environmental consequences from accelerating sea level rise, storm surges, heat waves, drought, wildfires, more frequent heavy downpours, and increased hurricane intensity.

These impacts are a direct consequence of the increasing concentration of greenhouse gases like carbon dioxide (CO2) in our planet’s atmosphere. Power plants are the largest single source of U.S. CO2 emissions, representing about 40 percent of the total. Reducing emissions from the electric power sector is therefore crucial to our overall efforts to tackle climate change.

These facts compel us to act, and to act decisively. In doing so, we must recognize that some regions of our country are facing a heavier burden than others in accelerating this transition to a less fossil-intensive electricity system.

The proposed carbon standard for existing power plants provides a sound framework for reducing emissions from the power sector, but is not ambitious enough in the overall result of a 30 percent reduction in emissions in 2030 relative to 2005. UCS analysis shows that we can achieve twice that – a 60 percent reduction in emissions in 2030 relative to 2005.

UCS supports EPA’s proposal to incorporate “outside-the-fence” emissions reduction measures, namely renewable energy (RE) and energy efficiency (EE), in state compliance plans. Renewables such as wind, solar, and geothermal energy emit no carbon, and are already delivering safe, reliable, and affordable power to consumers. They also help diversify their electricity mix, improve public health, strengthen state and local economies, and reduce the risks of over reliance on natural gas.

EPA used four “building blocks” to determine the Best System of Emission Reduction (BSER) and establish emission rate reduction goals for each state. For the renewables block, EPA has really proposed an “average” system of emission reduction, seriously underestimating the true potential for renewable energy to cut carbon emissions. EPA’s state renewable energy targets are in many cases close to a business-as-usual approach—four states had more renewable generation in 2012 than their EPA targets for 2030.

States could be more ambitious in using renewables to reduce emissions. Costs of renewable energy have fallen dramatically. For example, the cost of solar PV is already equal to retail electricity rates in 10 states, and this number could more than double over the next year and a half as the costs of solar continue to fall, according to a recent study by Deutsche Bank. Since the beginning of 2011, the average price of a solar PV panel has declined 60 percent, while the average installed cost has fallen by more than 35 percent.  Meanwhile, the cost of wind power dropped 43 percent in the last four years—and is now competitive with power from new fossil fuel plants in some regions of the country. Multiple market factors are making coal-fired power too expensive relative to other cheaper, less polluting options like natural gas, renewable energy, and energy efficiency.

EPA’s framework also includes the option for states to comply on a multi-state or regional basis, which not only rewards early actors like the RGGI states but also creates an opportunity for new or expanded multi-state collaborations to drive down emissions at a lower cost.

States have a major role to play in developing implementation plans for carbon standards. Together with federal policy makers, states should help ensure that economic diversification and resources for worker transition are an important part of their plans. In doing so, together we can not only establish a strong standard to protect the planet’s climate, but also ensure that workers and communities have fresh economic opportunities, as market forces drive a shift away from coal.

I do not accept that this is an “either-or” proposition.

Our children and our grandchildren will face the risks of a vastly different climate caused by our failure to act to reduce emissions today. My young niece, and maybe someday her children and grandchildren, will face an uncertain future if we don’t get the second part right too.

It is much harder, but it is imperative that we do both.

Thank you.

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  • Warren

    Pollution is Bad, Energy is good. Wasted energy is bad, this is why over-govermentalization is bad.

    These proposed solutions, based on one single generation of scientists and new technologies, are truly a “climate change” all by themselves.

    This is a governance issue, not a science issue. It is about the power of governments in a free country to regulate the basic factors of economic production.
    Your theory, Doctor, is that government should do “all it can”, while individuals and corporations should do no harm.
    There is no fear of harm from the over-reaching government regulations, taxes, and structured preference for the development of new technologies. It is utopia of well-meaning advocates like you to “set in place”, “a regulatory pathway”, that “establishes baselines” and “a means to properly limit”, free americans from building what they choose, living as they wish, and it promotes the subservience of all but the noblest of it citizens.
    There is only a subtle tip of the hat for the “changes” that will be forced upon communities that dared to choose fossil sources for fuel, and there is no damage that will come from government rules, only from the reality of the past poor choices that have brought the community to the “battle” with government forces.
    There are not TWO sides to this argument, there is only the uneducated opposition, like me, that has simply not yet embraced the need for an all powerful government in control. Your fear of the future drives you Doctor, as does mine.
    But while you only acknowledge your fear of the individual, the polluter, the evil corporation etc., history will show that the danger to humans has been far more prevalent from dictatorial governments than from weather and environmental challenges… Including pollution. Nobody doubts your motives, I doubt your memory.

  • John Carter

    Good testimony, I agreed with it. In a somewhat similar plan that would also raise revenues by its implementation (with the design of being revenue neutral) it specifically mentioned offsetting revenue use to help businesses, and workers in transition from policy changes, as well as for the poor in helping adjustment.
    On a lesser note, here’s another person who commented the other day, testifying before the senate on climate change remediation, and comment/analysis regarding

    Great point on the “either or idea” this fallacy drives most resistance to sensible redress.

  • Jeremy

    Thanks, both of you. A stimulating conversation for sure. (And please,
    you can call me Jeremy…. the only person who uses “Dr.” is my mom!)

    First, UCS is an active member of the Blue Green Alliance (, which supports strong action on climate change and is finding areas of agreement between environmentalists and labor. We take this partnership seriously.

    Second, UCS put together a forum on economic diversification in West Virginia back in September. You can read about that event and my work in West Virginia here:

    I have worked hard to raise awareness of this issue within UCS and other allies. And it’s paying off–there was great enthusiasm about the work in WV. And I can say that UCS recognizes the importance of the transition issue at the highest levels, and that there is an ongoing discussion about how we can be most helpful as an organization.

    Our team will be submitting substantial technical comments on the EPA standard. And we are engaging with partners in key states to advocate for strong state compliance plans. Our exact work on state compliance plans has not been determined, but I expect to continue to raise the issue of transition, and hope to dig in and be more specific about policies that states could consider. So stay tuned!

    • Tim

      Thanks Jeremy. Your prompt response and thoughtful engagement is much appreciated!

  • Tim

    I agree that EPA does not have the direct authority to fund or initiate such efforts. However, the President, who precipitated this as part of his policy goals could be making a greater effort to work on such programs. For example there is a federal Trade Adjustment Assistance Act that was passed which provided transition assistance to those who lost their jobs due to outsourcing overseas or foreigh trade. This is a good template for something that could be done for workers who are going to lose their jobs at the mines, plants, etc…I haven’t seen the President, Gina McCarthy or anyone else talk about ideas like this. Yes, you can point to new jobs that are created but these aren’t necessarily created near or for the individuals that are losing their jobs through no fault of their own, but rather through government guided policy. I agree with the direction of the CPP, I agree that it is complex, but to not be thoughtful enough to prepare these individuals ahead of time is incredibly short sighted. What is the UCS doing to promote ideas like this? Or do you just focus on the “scientific” side and leave the other pieces of the puzzle to be figured out elsewhwere? It seems you have a vested interest to care and can see the real effects on real people but I hope your organization does too.

  • Jeremy

    Hi Tim, Thanks for your comment.

    The problem is that the EPA has no authority under the Clean Air Act to address job training and resource needs. But States can. Policies that direct revenue to affected communities could be part of state compliance plans. Examples exist in the RGGI states, Massachusetts for example.

    I’m saying that it’s critical to reduce emissions AND to provide resources to affected workers and communities. It will require honest engagement from state leaders, and to get them to move beyond fighting the standard. Any thoughts on how to have that conversation would be most welcome!

  • Tim

    So you want them to consider the implications to job loss for coal miners but you suggest them to make deeper cuts? Sounds like lip service to me. If you cared so much why wouldnt you suggest that they take specific actions to help buffer these losses, via government provided job transition training, unemployment resources, etc….

    • Giggidy

      1. The author’s priority is to reduce carbon emissions to address climate change. There is no contradiction between viewing this as the primary objective yet still caring about the effects carbon reduction policies will have on coal miners. When two values are in tension, prioritizing one over the other doesn’t mean you don’t care about the other.
      2. The author has made it clear that he prefers state action to federal action on the issue of job retraining and resource needs. Note that thinking the states are better equipped to deal with some issues (e.g. job retraining) while the federal government others (e.g. carbon emissions reductions) does not indicate hypocrisy.
      3. The author made his remarks before the EPA, so even if he did believe (which he doesn’t) that specific federal job training programs should be implemented, there would be no point in advocating for those policies in front of an agency that clearly does not have the authority to implement them.
      4. Enough with “scientific” (in quotes), and phrases like “lip service” and “if you cared so much.” Dr. Richardson earned a PhD in physics, has devoted much of his life to service that he believes (though you may not) to be in the public interest, and wrote a considered and respectful response to your post. If the fact that you disagree with some of his positions renders you incapable of returning that respect, then don’t post on fora like these.

      • Tim

        Thank you for your opinion on the matter. I very much respect it. I also very much respect Dr. Richardson and his education credentials. I was calling neither his expertise nor the scientific nature of the matter into question. I was, however, looking for more information on ways in which Dr. Richardson or the UCS planned to engage in the process of helping these workers. As he noted, he is directly affected and concerned. I appreciate concern, I really do, but want to know more about what they are doing to mitigate that concern. If you are going to represent such an important body, say you are concerned, and then ask for deeper cuts I think it is only fair that you share your ideas on how you plan to help create solutions to the problem that you are only increasing with your recommendations. I am also not asking whether this should be handled at the state or federal level. There are pros and cons to both. My question was are they engaging only on the scientific aspect of the matter or are they also engaging on the worforce/economy issues. If the both, then I would be curious how, as it might provide for good ideas for other organizations. I do agree that putting scientific in qoutes was misplaced, I was trying to create separation, not question credibility.

      • Giggidy

        Thanks for that, Tim. My dander is back down and I see where you’re coming from now. Good questions – hopefully you’ll get a response.

      • Tim

        Me too! Thank fors for the dialogue. Cheers!