Clean Power Plan blog post series

Clean Power Plan blog post series

Clean Power Plan blog post series

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As the December 1 comment deadline approaches for the Obama administration’s proposed Clean Power Plan, Friends of the Earth is launching a series of blog posts on Daily Kos explaining the rule’s deficiencies and how it could be made even more effective at reducing carbon emissions. 

The first post, by Climate and energy campaigner Kate DeAngelis, now up on Daily Kos, explains the importance of a carbon tax in reducing power plant emissions.

A carbon tax would qualify as a measure that reduces the emissions of power plants in a way that is both enforceable and in compliance with the Clean Air Act. In order to qualify as a compliance mechanism, the standard of performance must be an emissions standard that would perform as effectively as the “best system of emission reduction.” A carbon tax is an emission standard as clarified in the Supreme Court case Engine Manufacturers Association v. South Coast Air Quality Management District, which found that a standard includes different methods of regulation. The EPA and states can demonstrate that a robust carbon tax would result in the required emission reductions with economic models, which the Supreme Court has found to be an acceptable method of mandating reductions. Moreover, section 111(d) requires that the EPA use similar procedures as those used for national ambient air quality standard state implementation plans, which allow the use of fees.

A carbon tax could match or even exceed the EPA’s emission reduction targets as proven by data from the Energy Information Agency. In order to accomplish this, the price must be meaningful and rise slowly over time. Even a starting price of $15 per ton — as would be required by the Managed Carbon Price Act of 2014 — would result in reductions of more than 40 percent. These projections are greater than the EPA’s goal of reducing emissions by 30 percent by 2030, which provides strong evidence that an individual state could design a carbon tax that could meet EPA’s emissions target.

The second post, “What’s in a baseline? Why starting in 2005 matters a lot,” by Climate and energy campaigner Lukas Ross, is also available for those who want to learn the significance of the benchmark year.

Reaching the 2030 target based on 2005 levels only requires a 17 percent overall reduction from 2013 levels. By lowering the bar, the Obama administration is simultaneously setting an easier target and positioning itself to take credit when the target is reached. In other words, the president would like to begin a marathon more than one-third of the way past the starting line and then celebrate when he runs a record time.

This policy is at best lazy and at worst dishonest, especially since the rule is radically under-ambitious at building a more sustainable energy mix through efficiency standards and renewables. The rule could be twice as ambitious about reducing overall emissions from the power sector and remain achievable. At the state level, where the reduction targets are implemented and enforced, the World Resources Institute has identified at least ten states where the EPA has set the target well below what could reasonably be achieved.

In “Does Obama’s new EPA rule place a dangerous bet on natural gas?” Lukas Ross takes a look at the implications of what would be the Clean Power Plan’s biggest winner: natural gas.

These trends suggest that the new EPA rule, and its tacit endorsement of gas, is shackling our economy to an unreliable fuel. That’s a shame because unlike gas, renewable energy is not part of a hyper-competitive commodity market. We do not use the sun as a feedstock to make plastics or fertilizers, and we do not use the wind to heat our homes. In a basic sense, every renewable technology runs on a free source of fuel.

Even profit-driven institutions like Citibank are bullish on renewables for purely economic reasons; the price of gas will rise, its analysts argue, while the cost of renewables can only drop. In many regions, solar and wind are already better bargains and more utilities are choosing the price stability of renewable electricity over the whip-sawing price of fossil fuels. Especially when it comes to building new capacity, renewables are frequently the cheapest option. In a landmark ruling this January in Minnesota, a judge even ordered a utility to build solar capacity instead of gas because over time it would provide a fairer and more reliable deal for consumers.

The fourth post, “The country has greater renewable energy potential than the Clean Power Plan demands,” details why the EPA should push states for greater renewable energy targets.

The Union of Concerned Scientists found that EPA underestimated by about half the proportion of cost-effective renewable energy that could be included in the state emission reduction targets. This analysis finds that EPA’s approach barely results in an increase of renewable energy’s proportion of electricity sales when the Clean Power Plan could actually result in it more than doubling. Part of UCS’s approach was to better reflect the deployment rates already being achieved and assume compliance with policies already in place. The majority of states have mandatory or voluntary renewable energy standards, many of which require more renewable energy than the EPA predicts those states to bring on-line. For example, Missouri’s existing clean energy policies have them on track to meet the EPA target by 2021. In fact, Missouri’s renewable energy goal is about five times more ambitious than EPA projections of what the state can accomplish. Ambitious targets are necessary for the rule to generate significant increases in each state’s renewable energy generation.

Stay tuned as more posts are released in coming weeks.

Image: Campaigners Luisa Abbot Galvao (left) and Kate DeAngelis (right) provided testimony to the EPA on the Clean Power Plan this summer.

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