The EPA “Clean Power Plan”–1.2 million public comments so far

Failure is not an option

On June 2, 2014, the US Environmental Protection Agency rolled out a “Clean Power Plan” proposal, the stated intent of which is to reduce carbon (equivalent) emissions from electricity generation by 30 percent (from a 2005 baseline) by 2030.  Such emissions have already dropped by about 15 percent from the 2005 levels.  Electricity generation is responsible for about 40 percent of total carbon (equivalent) emissions to the atmosphere.  So, taken at face value, the reductions if the proposal were implemented would be something like .3 times .4 equals 12 percent.  Given that one-half of the reductions have already occurred, the reductions due to the “Plan” would be something like six percent.  Still, even a small beginning could be significant in the gridlocked US political system.

On its face, this would be the first serious effort to limit planet-cooking emissions from US power plants.  The proposal is so complex, and in some ways so vague, that clear understanding of what it means is not easy to come by.  EPA has set a target for each state, some calling for more reductions than others.  Some states might be able to increase their carbon emissions and still be in compliance.  A reasonably clear explanation of the basics of the proposal is here.

As one would expect, reactions have varied widely.  Oil, gas, and coal interests, directly and through their wholly-owned politicians like Mitch McConnell, John Bohner, and Mary Landrieu, are saying the economy would be horribly damaged.  This is clearly not true.  Little that is meaningful comes out of the mouths of major Delaware pols like Carper, Coons, and Carney.

On the other side, some establishment Democratic pols and many “big green” NGOs with ties to the Obama Administration are raving about the plan, pretending or hoping it means more than it actually does.  They urge us to send in supportive public comments.  The present public comment period ends on December 1, 2014.  According to the EPA, 1,245,324 comments have so far been received.

Some fundamental problems with the proposal

It doesn’t do nearly enough.

Converting from coal burning to natural gas burning, encouraged in the proposal, quite likely increases rather than decreases global warming.  This is because natural gas is methane, and a lot of it leaks, and methane is a much more powerful greenhouse gas than carbon dioxide.  But, the proposal looks narrowly at powerplant smokestack emissions.

The EPA proposal seeks to encourage the continued operation of old, unsafe nuclear reactors.  This is strongly objected to by people familiar with the nuclear industry.

The proposal would also encourage the use of “biomass” and garbage incineration, which are much dirtier than coal in terms of both greenhouse emissions and traditional health-damaging air pollutants.  See more here.

Conservation and efficiency, by far the cheapest and cleanest approach, is in the proposal but as the last priority when it should be the first.  EPA has apparently overestimated the cost of energy efficiency (“negawatts”) by at least a factor of two.

“Environmental Justice” or “Climate Justice” concerns do not seem to have figured in the plan.  This is in contrast to the lip service to “EJ” that the EPA is paying.

It appears that many of the assumptions about the costs and emissions of various fuels and technologies are no longer correct, if they ever were.  The “Natural Resources Defense Council” (NRDC, no friend of Green Delaware) has recently produced an analysis of the EPA plan using more current numbers.  NRDC concluded:

  • The EPA used outdated renewable energy cost and performance numbers, including levelized costs for both wind and solar energy 46 percent above current averages.
  • The EPA used extremely conservative energy efficiency costs 68 to 81 percent higher than current averages.
  • EPA’s proposed state targets could be met at a total savings of $1.8 billion to $4.3 billion in 2020, instead of EPA’s estimated costs of $5.5 billion and $7.5 billion.
  • Total savings would reach $6.4 billion to $9.4 billion in 2030, instead of the EPA’s estimated costs of $7.3 billion to $8.8 billion.

Other work suggests that EPA is under-estimating the future cost of coal and over-estimating the available supply.  See this.  And lots more here.

Overall, my sense is that the proposal represents a step forward in a political sense but not very much in a technical sense.  Mother nature doesn’t care about out politics.

What about Delaware specifically?

The stated 2030 goal for Delaware is a “carbon intensity” of 841 pounds of carbon dioxide per megawatt hour generated.  Compare this to 873 for Minnesota, 576 for Massachusetts, 373 for Maine, and 537 for California.  Obviously, Delaware is not being asked to excel.

Delaware, as a member state of the Regional Greenhouse Gas Initiative, and having shut down some coal units, could be said to be ahead of the compliance game.  On the other hand, programs to promote investment in conservation and efficiency have largely been shut down, thanks to Delmarva Power, the “Sustainable Energy Utility,” and bad actor state senator Harris McDowell.

As the lowest-lying coastal state Delaware has arguably a greater stake in abating climate change and the resulting sea level rise than any other US state.  See: Waters rising … Delaware going away? and Planning and Sea level rise in Delaware–public comments needed

The DNREC Division of Air Quality held a “listening session” about the Plan on November 5, 2014.  The transcript of that is posted here.

The DNREC has also sent in comments on the proposal.

Solutions do exist

With US politics too gridlocked to make much progress, one might think the problem is hopeless, that we are doomed.  Not so.  Our problems are much more political than technical or economic.  How to overcome the power of change-resisting special interests?

The costs of low carbon energy are dropping and the costs of fossil fuels are rising.  The challenge that faces us is to figure out how to leave the carbon in the ground, and redirect our investment into truly “clean” sources.  It is unfortunate, but likely not accidental, that so much mental and rhetorical energy does into fighting the deniers, and the promoters of false solutions.  This does not seem to leave enough for discussing the real solutions.  But there is good work being done, we just need to look in the right places.  For example, based on the work of Mark Z. Jacobson,  Dept. of Civil and Env. Engineering, Stanford University.  The Solutions Project has developed “Roadmaps to Convert the 50 United States to Wind, Water, and Sunlight (WWS) for all purposes.”

Here is the infographic for Delaware.  Spend a few minutes looking it over.

Here is the detailed paper.

And lots more info on this page.

Jacobson and colleagues are far from the only workers in this area.  At the University of Delaware, some interesting work has been done from time to time by Willett Kempton, Jeremy Firestone, and John Byrne.


The “Clean Power Plan” is far too weak and defective to support as it is.  The important thing is to urge the Obama administration to make it a lot better.  Here is a summary of the points made by the Energy Justice Network.  We agree:

  • Set more aggressive targets
  • Comply with the Civil Rights Act and address environmental justice
  • Regulate power plants (not states) and disallow pollution trading and offsets
  • Close the methane loophole and not bless the move from coal to gas, which is worse for the climate than coal
  • Close the biogenic CO2 loophole, and disallow a shift from coal to biomass and waste incineration, whose CO2 emissions are also worse than coal
  • Disallow nuclear power subsidies
  • Disallow new investment in old coal plants
  • Reject carbon capture and sequestration and enhanced oil recovery

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