Yesterday the Union of Concerned Scientists (UCS) submitted its comments on the draft Clean Power Plan (CPP) to the EPA. Joining millions of others, we registered our strong support for these historic, first-ever limits on carbon emissions from power plants, which are the single largest source of these emissions in the United States. This rule could be a climate game changer. We also recommended a number of ways the plan should be strengthened and improved, especially by increasing renewable energy contributions.
Here’s where you can find an executive summary and our full comments.
Seven ways to strengthen and improve the Clean Power Plan
Our comments covered many aspects of the CPP. Here are some of our key recommendations to the EPA:
- Strengthen the emission reduction goal of the Clean Power Plan. The multiple flexibilities and cost-effective options for cutting emissions in the CPP lend themselves to a greater level of ambition in emission reductions than the EPA has proposed. Our analysis shows it is technically and economically feasible to raise the emission reductions achieved by the CPP from 30 to 40 percent below 2005 levels by 2030 simply by increasing the contribution from renewable energy.
- Strengthen the renewable energy targets. We recommended modifications to EPA’s proposal on renewables that use the most up-to-date renewable energy data, set renewable energy growth rates at levels already being achieved by leading states, incorporate full compliance with current state renewable electricity standards, and reflect expected renewable energy growth between 2013 and 2017. UCS analysis shows that this cost-effective approach would nearly double EPA’s renewable target, from 12 to 23 percent of U.S. electricity sales by 2030. It would also reduce emissions by an additional 10 percent compared with the draft CPP, while having a minimal impact on electricity prices (a typical household would see an increase of no more than 18 cents on their monthly electricity bill) and putting downward pressure on natural gas prices (the national average price of natural gas in the electricity sector would be 9 percent lower than BAU by 2030).
- Strengthen the energy efficiency targets. Energy efficiency, as a plentiful resource for meeting electricity needs and one that is almost always the lowest cost, can appreciably improve the economics of reducing carbon, providing sustained reductions in energy use for consumers and businesses. We recommended that the EPA strengthen its energy efficiency targets, using a target for incremental annual energy efficiency of at least 2.0 percent of electricity sales for each state and an annual ramp-up rate of at least 0.25 percent, based on inclusion of a broader suite of energy efficiency policies, measures, and technologies.
- Limit the risks of overreliance on natural gas. Natural gas has an important role in helping our transition to a low carbon power sector.But overreliance on natural gas poses significant and complex risks to consumers, the economy, public health and safety, land and water resources, and to the climate. We recommended that the EPA consider ways to avoid incentivizing natural gas generation at the expense of other cost-effective, lower carbon resource alternatives. We also recommend that the EPA simultaneously take steps to significantly reduce fugitive methane emissions from the oil and gas sector.
- Allow multi-state and market-based approaches to count toward compliance. Multi-state and market-based approaches provide flexibility to help achieve emission reductions at a lower cost. We recommended that the EPA provide further guidance to help more states take advantage of these options, if they so choose, and ensure that the emissions reductions achieved are equivalent to the state goals in the CPP and come only from the power sector. We also recommended that states use a portion of their carbon revenues to support or retrain displaced workers, invest in renewable energy and energy efficiency programs, and provide assistance to low-income and environmental justice communities
- Review and update emission reduction targets regularly. The emission reduction targets in the CPP should be reviewed and updated regularly, with the first update no later than 2025. This update process would help ensure that the CPP reflects the latest cost-effective opportunities for cutting CO2 emissions, which is especially important given that the costs of cleaner generation sources such as wind and solar are dropping rapidly. Updating the CPP’s goals will also help ensure they are responsive to the urgent need to cut emissions to slow the pace of climate change and limit its impacts.
- Address worker transition and environmental justice concerns. In our recommendations, we urged the EPA to work with states to ensure that these critical issues are addressed appropriately. Unless state compliance plans include specific worker transition provisions, the proposed standard for carbon emissions at existing power plants may have disproportionately negative impacts among certain coal-heavy geographic regions, coal-dependent communities, and coal-related workers. We recommended a number of ways states could help ameliorate these impacts, both within the context of state compliance plans and through complementary policies enacted by state legislatures, to retrain workers and invest in economic diversification. These include using carbon revenues from market-based programs that some states or regions might choose for compliance. We also recommended that the EPA require states to conduct an environmental justice analysis of their compliance plans; offer states data, methodology and tools to conduct these analyses; and ensure that EJ groups are at the table when key decisions about compliance plans are being made.
A strong Clean Power Plan is good for the U.S.…
Investing in cleaner generation sources like renewable energy and energy efficiency can create jobs, lower energy bills and reduce the public health burden of our dependence on fossil fuels. States that are moving ahead with programs to encourage clean energy and limit carbon emissions will reap huge benefits, including these examples from comments from 14 leading states to the EPA:
- California’s Renewable Portfolio Standard (RPS) is projected to generate $60 billion in the California economy and create up to 235,000 jobs.
- By 2015, Illinois’ RPS is projected to bring nearly $6 billion in new investment and create over 5,000 jobs, while its Energy Portfolio Standard is projected to save the average household close to $100 a year, to stimulate nearly $5 billion in economic activity, and to create over 16,000 new jobs.
- In Massachusetts, surveys by the Clean Energy Center show an 11.8 percent increase in clean energy jobs in 2013 and that clean energy employment has grown between 6 and 12 percent annually for the last five years. Nearly 80,000 employees are working in clean energy throughout the Commonwealth.
Americans are already facing many costly impacts of climate change, including heat waves, coastal flooding, drought, wildfires, extreme precipitation, and worsening ozone pollution. Without action to significantly curtail heat-trapping emissions, the risks of these impacts will grow. Cutting emissions can also help slow the pace of climate change and give communities more time to prepare.
… And can help contribute to global efforts to limit climate change
The United Nations Framework Convention on Climate Change (UNFCCC) negotiations now underway in Lima, and the next year leading up to the Paris meeting in 2015, are critical for reaching a fair and ambitious global climate agreement. The recent U.S.-China joint climate announcement commits both countries to serious steps to lower their emissions. The U.S. has set a goal of a 26 to 28 percent cut in its net GHG emissions by 2025, while China intends to reach a peak in its CO2 emissions by 2030 and has signaled that its use of coal will peak in 2020. China also plans to increase the share of non-fossil fuels in its primary energy consumption to around 20 percent by 2030. This agreement between the two major emitting nations represents a significant breakthrough and can help unlock equivalent actions by other nations. However, strengthening the CPP is critical to reaching (or going beyond) the upper end of the current U.S. offer of a 28 percent reduction in emissions from 2005 levels by 2025.
A strong final rule that delivers emission reductions of at least 40 percent below 2005 levels by 2030 will be a critical step forward in our transition to a clean energy economy and an important sign of our commitment to the global effort to limit climate change.
Support from UCS members make work like this possible. Will you join us? Help UCS advance independent science for a healthy environment and a safer world.