By Lissa Lynch, Natural Resources Defense Council
NRDC submitted extensive public comments yesterday strongly opposing the Trump EPA’s irresponsible proposal to cancel the groundbreaking Clean Power Plan and replace it with a deeply flawed dirty power plan that will result in more power plant carbon pollution, harming public health and the planet. We contend Trump should drop this terrible proposal, reverse course, and strengthen the Clean Power Plan instead. NRDC’s modeling shows that doing so could slash power plant carbon pollution by 60 percent from 2005 levels by 2030, at a reasonable cost and yielding $100 billion in climate and health benefits.
The administration has the audacity to push its harmful proposed rule even as we’re already experiencing the effects of climate change across the country, increasing the risk of hurricanes battering our coasts, extreme heat baking our cities, and wildfires raging through our forests and communities. We’ve also just received sobering news from the world’s leading climate scientists who warned that much more severe climate change impacts will occur within two decades unless the U.S. and the world take unprecedented action. That’s why our comments argue that instead of tossing aside the Clean Power Plan, this administration should strengthen it to achieve much deeper cuts of carbon pollution from power plants and better protections for public health, which we show can be done at a reasonable cost.
NRDC has long supported and fought to defend the Clean Power Plan, which places sensible limits on emissions of dangerous carbon pollution from existing power plants, as a critical step toward reducing the threat of climate change to our communities. The recent Special Report by the Intergovernmental Panel on Climate Change only underscores the urgency of action to avert the worst climate change risks: avoiding irreversible, deeply disruptive, and unmanageable climate change impacts will require “deep emissions reductions in all sectors,” including the power sector, within the next decade and through the middle of this century.
Ignoring this reality, the Trump EPA has: proposed an outright repeal of the Clean Power Plan; initiated an Advance Notice of Proposed Rulemaking to consider whether to issue a replacement rule at all; and finally proposed the so-called “Affordable Clean Energy Rule”—a dirty power plan that is neither affordable nor clean, which EPA’s own analysis shows could actually increase pollution and could end up costing more than the Clean Power Plan.
NRDC staff testified against the repeal, and we submitted public comments detailingthe flaws in the repeal proposal and providing extensive input on the questions raised in the replacement advance notice. Over and over the public has weighed in against the Trump administration’s reckless plan to scrap limits on harmful power plant pollution.
Now we’ve filed detailed technical and legal comments urging EPA Acting Administrator Wheeler to withdraw this dirty power plan. Here are some highlights from our comments.
This proposal is far from the best system of emission reduction
The Clean Air Act requires the EPA Administrator to set an emission guideline for existing power plants that reflects the reductions achievable by the “best system of emission reduction.” Acting Administrator Wheeler is proposing that the “best system” for reducing power plants’ emissions is limited to only minimal improvements to the efficiency of coal-fired plants, known as “heat rate improvements.” This proposal is based on a legal theory, advanced in former Administrator Pruitt’s proposed CPP repeal, that the best system of emission reduction is limited to measures that “can be applied to or at a single source.” We show in our comments—as we have repeatedlyshown before—that the Clean Air Act sets no such restriction on the best system of emission reduction.
Moreover, the proposed heat-rate-only system is certainly not the best. It excludes the potential for reducing power sector carbon pollution by increasing investments in wind and solar power or switching plants to burn lower-carbon fuels, which were the foundations of the Clean Power Plan. And it even ignores other source-specific measures that fit within the proposed “applied to” or “at” the plant restriction, such as co-firing with natural gas or deploying carbon capture and sequestration.
Other source-specific emission reduction measures could achieve more
Even within the artificial constraints imposed by Acting Administrator Wheeler’s flawed legal interpretation, EPA must still base its determination of the “best system” on measures that achieve the greatest reductions at reasonable cost. NRDC conducted our own power sector modeling of the emissions and cost impacts to compare EPA’s proposal against other available source-specific control options: co-firing and carbon capture and sequestration. Our modeling demonstrates that implementation of heat rate improvements in isolation would not only achieve minimal emission reductions, but could also result in a “rebound effect”—diminished emission reductions, or even emissions increases, as a result of improvements that increase a coal plant’s operating efficiency (causing it to run more often), or extend its remaining useful life (causing it to run for longer), or both.
Our modeling also shows the enormous potential to reduce carbon pollution through co-firing with natural gas or applying carbon capture and sequestration. We analyzed a range of possible levels of ambition and found that significant emission reductions are possible from these measures—far greater than those expected from the proposed heat-rate-improvement-only approach. Arbitrarily excluding these opportunities from the best system of emission reduction is a major flaw in EPA’s proposal.
EPA should update the Clean Power Plan instead
The Clean Power Plan was based on well-established means of reducing carbon pollution already in use by the electric generating industry, including increasing lower- and zero-emitting generation. Using these very approaches, the power sector has reduced its carbon pollution by 28 percent since 2005. Meanwhile, the costs of compliance with the Clean Power Plan have continued to decline as the prices of wind and solar technologies have dropped dramatically and natural gas prices have fallen below forecasted levels.
Instead of the current proposal, EPA should have updated the calculations used to derive the Clean Power Plan targets building on the progress that the electricity sector has made since the Plan was finalized in 2015. We estimate that by applying the same methodology with the latest available data, the Clean Power Plan could be strengthened considerably; NRDC’s modeling shows that such a program would deliver emissions reductions of 50 percent below 2016 levels, or 60 percent below 2005 levels, by 2030. These emissions reductions are achievable at a modest annual cost of $6.2 billion in 2030 with smart planning and investment in clean and cost-effective resources, and would generate climate and health benefits of up to $101 billion.
The figure below shows how close EPA’s proposal is to doing nothing at all to reduce power plant carbon pollution. In contrast, our modeling demonstrates the significant emission reductions that could be achieved by updating the Clean Power Plan or by implementing source-specific emission reducing measures like co-firing and carbon capture and sequestration.
In addition to these legal and technical comments, NRDC and our partners also submitted comments detailing: the legal flaws in EPA’s proposal to dismantle the New Source Review program; the numerous problems with the proposed revisions to the Clean Air Act section 111(d) implementing regulations; the errors and gaps in the Regulatory Impact Analysis supporting the proposal; the issues with proposal’s treatment of biomass-based generation; and the proposal’s failure to properly consider carbon capture and sequestration. All of those comments are available here.
NRDC won’t stop fighting Trump’s climate rollbacks
The proposed repeal and replacement of the Clean Power Plan is part of a broader Trump administration assault on public health and the environment. Just last week NRDC and our partners filed extensive comments opposing the proposal to weaken carbon pollution and fuel economy standards for cars and light trucks. And we’re also preparing comments in opposition to the proposed rollback of EPA’s limits on methane pollution from oil and gas production. If EPA finalizes any of these disastrous proposals, we’ll challenge those rules in court. As the Trump administration wages relentless anti-regulatory war on our climate safeguards, NRDC will fight them every step of the way.