Q: What do Google, 223 other businesses, 14 attorneys general, 11 U.S. senators, and more than 25 environmental, public health, and clean energy organizations all have in common?
A: They all told EPA that renewable energy should play a strong role in reducing emissions from existing power plants under its proposed Clean Power Plan.
In fact, many of these groups explicitly endorsed the “Demonstrated Growth Approach” that UCS proposed in our comments to the EPA, which would increase non-hydro renewable energy sources to 23 percent of U.S. electricity sales by 2030—or nearly double EPA’s proposed renewable energy target. Recent UCS analysis shows that achieving these levels is affordable and would result in additional reductions in U.S. power plant carbon emissions from EPA’s estimated 30 percent below 2005 levels to 40 percent. (For more details, see my October blog.)
Google: “EPA’s renewable energy goals are modest”
Google’s comments to the EPA called for stronger renewable energy targets, indicating that both of EPA’s approaches resulted in “modest” levels of renewable generation. Google also identified many of the same concerns with the EPA’s methodology that we highlighted in our comments, including:
- Some states currently have more renewable generation than the EPA’s 2030 targets
- The EPA did not fully capture future state commitments to renewables under existing laws
- The EPA did not assume any increase in renewables between 2012 and 2017
- The EPA’s alternative approach used static 2012 technology deployment rates that don’t capture future innovations or cost reductions, and
- The EPA used outdated cost assumptions for renewables in their economic modeling.
Because of these and other anomalies in EPA’s methodology, Google concluded:
“For all these reasons, we believe EPA underestimates the demand and opportunity presented by renewable energy over the next 10-20 years. Accordingly, the renewable energy goals in the final rule should better account for the full range of renewable energy opportunities in states and, at the least, should certainly be no less stringent than the additions of generation already required.”
Renewable energy “makes good business sense”
As a major user and investor in renewable energy, Google executives clearly know what they’re talking about. They have signed contracts for 1,040 megawatts (MW) of renewable energy—enough to provide 35 percent of Google’s electricity use in 2013, the equivalent of powering more than 300,000 U.S. households. Google’s long‐term goal is for renewable energy to provide 100 percent of their electricity needs. In addition to being a large consumer of clean zero-carbon electricity, they have invested more than $1.5 billion in 17 renewable energy projects that will add 2,500 MW of new capacity to the grid.
The main reason why Google is so bullish on renewable energy is because it’s good for their bottom line:
“For example, using renewable energy helps Google diversify our power supply, provide protection against fuel price variability, and support business innovation and economic growth in the regions in which we operate. We are seeking affordable, reliable power that reduces our carbon footprint and meets the technology needs of our business…Today, renewable energy is more cost-effective in more regions of the country than ever before, and prices continue to decline.”
Other Fortune 500 companies support a strong role for renewables
Like Google, 223 other businesses sent a letter to the EPA, emphasizing the important role that renewables and efficiency can play in reducing emissions and saving money as part of the Clean Power Plan. The letter was signed by 40 companies with over $100 million in annual revenues, including several Fortune 500 companies. This includes companies such as Kellogg’s, Starbucks, IKEA, Nike, Levi Strauss, Mars, and Nestlé that have recently made significant investments in renewables. For example:
- Starbucks purchased more 50 percent of its electricity from renewable energy in 2011, and has a goal of 100 percent renewable energy by 2015.
- Mars recently purchased a 200 MW wind farm in Texas that will generate enough electricity to make 13 billion Snickers bars, and provide 100 percent of their power.
Organized by the Business for Innovative Climate & Energy Policy (a project of Ceres) in coordination with CDP and the Climate Group, the letter stated:
“Clean energy policies are good for our environment, the economy, and companies. Increasingly, businesses rely on renewable energy and energy efficiency solutions to improve corporate performance and cut costs…60 percent of the combined Fortune 100 and Global 100 companies have set a renewable energy goal, a greenhouse gas reduction goal, or both. Today’s rules will help spur investment and provide the long-term certainty necessary for our businesses to thrive and to meet these goals.”
U.S. senators propose improvements to the EPA’s renewable energy targets
On December 9, eleven U.S. Senate Democrats from CA, NJ, HI, MA, MD, OR, RI, and VT sent a letter to the EPA calling for stronger renewable energy, energy efficiency, and state emission reduction targets:
“For the Clean Power Plan to be a success, it must achieve the level of emission reductions that the science calls for to avoid the most dangerous impacts of climate change. Maximizing the deployment of cost-effective renewable energy and energy efficiency will be the key to achieve the necessary emissions reductions.”
State Attorneys General support UCS approach for strengthening the EPA’s renewable targets
In addition to supporting the EPA’s legal authority to regulate carbon emissions from existing power plants under section 111(d) of the Clean Air Act, the Attorneys General from 12 states (CA, CT, MA, ME, MD, NM, NY, OR, RI, VT, WA), Washington DC, and New York City also specifically endorsed our approach for strengthening the renewables building block:
“Other methodologies for determining potential renewable generation on a state-by-state basis, such as that proposed by the Union of Concerned Scientists, have confirmed that increased renewable generation is feasible and cost effective at even higher rates of adoption than projected by EPA…Thus, the States prefer an approach to the renewable energy building block that results in a target that aggressively captures the technical feasibility and market potential of renewable energy. Based on such an approach, the States also believe that there is a demonstrated basis for strengthening state-specific targets for some states.”
Clean energy, public health, and environmental organizations support UCS approach
More than 25 national and state non-profit organizations also supported the UCS Demonstrated Growth approach and several other options for strengthening the renewable energy targets in their comments to the EPA. This included major renewable energy business groups like the American Wind Energy Association, the Solar Energy Industries Association, and Advanced Energy Economy. It also included public health and environmental justice groups like the U.S. Climate & Health Alliance and WE ACT for Environmental Justice, and consumer groups such as Public Citizen, Consumer Action, and Ohio Partners for Affordable Energy.
In addition, many national, regional, and state environmental organizations supported our approach and other alternatives, such as the Sierra Club, Natural Resources Defense Council, Environmental Defense Fund, Environmental Law and Policy Center in Chicago, Southern Alliance for Clean Energy, Southern Environmental Law Center, several Minnesota organizations, and Utah Clean Energy.
Next steps for the EPA
As the EPA weighs the millions of comments it received on the Clean Power Plan, this diverse and comprehensive support sends a strong signal to the EPA to strengthen the state renewable energy and emission reduction targets when the final rule is released next June.
When combined with stronger targets for energy efficiency, renewable energy allows states to affordably deliver the much deeper emission reductions that are needed to avoid the worst consequences of climate change.