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The Clean Power Plan: NRDC's Initial Analysis of EPA's Landmark Proposal to Curb Carbon Pollution from the Nation's Power Plants

Derek Murrow

Posted June 8, 2014 in Curbing Pollution, Health and the Environment, Solving Global Warming, U.S. Law and Policy

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On June 2nd, the Environmental Protection Agency proposed the nation’s first limits on carbon pollution from the nation’s fleet of more than 1600 fossil fueled fired electric power plants.  The Clean Power Plan, as it is called, is the centerpiece of President Obama’s Climate Action Plan aimed at cutting the carbon pollution that is driving dangerous climate change. 

EPA’s proposal is a giant leap forward in protecting the health and well-being of all Americans and future generations.  The proposal has drawn praise and support from many quarters, but it will also face stiff opposition from factions of the fossil fuel industry desperate to hold onto the status quo. 

EPA now begins a year of taking public comment and working with states and other stakeholders to refine and improve its proposal before finalizing it in June 2015.  Now that EPA has issued the Clean Power Plan, it’s our job to make it stick and make it stronger.

NRDC’s team of clean air, climate, and energy experts have spent the week analyzing .the proposed standards and EPA’s extensive supporting materials, which you can download here.  

The following is our initial summary and analysis of EPA’s proposal. NRDC has also developed a more detailed fact sheet on the proposal, available here.  And we’re posting blogs on the Clean Power Plan, how it affects individual states, and many other topics.  You can find all of those blogs collected here.

Highlights of the Clean Power Plan

EPA has developed a flexible approach that allows for significant emissions reductions at low cost.  It is an approach that draws on a wide range of tools to reduce carbon pollution, and we are confident that the final standards, when issued next June, will pass legal muster. Under this part of the Clean Air Act – section 111(d) – EPA sets targets for each state to reduce the “carbon intensity” of the state’s power plant fleet (Carbon intensity is measured in pounds of carbon dioxide (CO2) emitted per megawatt-hour of electricity generated).  Targets are set in two phases, one beginning in 2020 and another in 2030.

EPA estimates the national impact of meeting the state targets will be to reduce national power sector CO2 emissions 26% below 2005 emissions by 2020 and 30% by 2030. That is equivalent to:

  • 18% below EPA’s forecast of what would happen without the standards (i.e., business-as-usual) by 2020 and 25% by 2030 or
  • 13% below 2012 emissions by 2020 and 17% by 2030.

These are significant carbon pollution reductions. By comparison, the Clean Car Standards set in 2010 and 2012 are projected to reduce CO2 emissions by 4,140 million metric tons from 2020 to 2030. This Clean Power proposal would reduce CO2 emissions by 5,344 million metric tons over the same period --almost 30% more.

Fig1-Emissions.jpg

In addition to these cuts in climate-changing carbon pollution, EPA estimates he proposal will also cut pollution that leads to soot and smog by over 25 percent in 2030 and lead to climate and health benefits worth an estimated $55 billion to $93 billion in 2030, including avoiding 2,700 to 6,600 premature deaths and 140,000 to 150,000 asthma attacks in children.

Important as these gains will be, EPA’s proposal can and should be strengthened. EPA is taking comments for 120 days on all aspects of the proposal, including the approach it used and the data and assumptions it employed to develop the state standards.  NRDC believes the final standards can achieve greater pollution reductions at a reasonable cost. In particular, states could do more to increase energy efficiency and the use of renewables than EPA assumed in setting the targets in its current proposal.

EPA’s proposal calculates an emission target for each state that respects differences in states’ power generation mix and utilizes a wide range of effective tools to cut carbon pollution.  EPA used four basic building blocks to determine the “best system of emissions reduction,” including a wide range of cost-effective methods to reduce emissions. The building block analysis does not prescribe how each state must meet its target.  Instead,  each state is free to develop its own plan to meet the target. The states asked for flexibility and EPA has provided it. This  approach – where EPA sets the targets and states develop implementation plans to meet them – has been used repeatedly over four decades to successfully cut pollution under the Clean Air Act.

EPA has set modest and achievable targets for each state based on that state’s current electricity generation mix. EPA started with each state’s 2012 generation mix and determined the state’s current “carbon intensity” – the average CO2 emission rate of its power generators. EPA then analyzed how much each state’s “carbon intensity” could be improved in future years by applying four types of emission-reducing measures that are already in demonstrated use in many states and regions of the country.  EPA determined each state’s emission rate reduction target for 2020 and 2030 by calculating how much the emission reduction tools could reduce a state's emission rate in each target year. Because each state has a unique energy mix, the various pollution reduction techniques achieve significantly different improvements from state to state, and thus the state targets differ significantly. 

The four “building blocks” – the emission reduction tools EPA used to set the state targets – are:

  • Making existing coal plants more efficient. 
  • Using existing gas plants more effectively.
  • Increasing generation from renewables and nuclear plants.
  • Increasing energy efficiency in homes, appliances, buildings, and other end uses.

States do not have to take the specific steps that EPA analyzed in calculating the targets.  They can choose to meet their targets however they choose.  But the target calculation shows EPA’s view of what emission rate improvements are reasonable, and thus required.

EPA is proposing a two-part target structure: an “interim goal” that a state must meet on average over the ten-year period from 2020-2029 and a “final goal” that a state must meet in 2030 and maintain thereafter.

NRDC analysts examine how the targets work out for specific states in a series of blog posts here.

Adding another important degree of state choice and flexibility, EPA’s proposal provides that a state may adopt the “carbon intensity” target set by EPA, which is stated in terms of the amount of carbon dioxide per megawatt-hour of power generation), or alternatively the state may choose a “mass-based” target – a total number of tons of CO2 emissions allowed per year – at an equivalent or lower level.   

Following the timetable established under President Obama’s Climate Action Plan last year, EPA is to issue the final standards by June 1, 2015.

Each state then must submit a state implementation plan to EPA by June 30, 2016.EPA is providing for conditional approval of a plan in some circumstances, with additional time allowed where needed to complete state rulemaking or legislative activities, or to develop multi-state plans.

Check out our more detailed fact sheet for more analysis of the proposed standards in EPA’s Clean Power Plan.  As we go forward, NRDC’s analysts will continue to post analysis and commentary in blogs and other fact sheets and reports collected here.

                                                                          This post written with David Doniger

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Switchboard is the staff blog of the Natural Resources Defense Council, the nation’s most effective environmental group. For more about our work, including in-depth policy documents, action alerts and ways you can contribute, visit NRDC.org.

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