EPA’s Clean Power Plan: We Can Do Better

How Can Someone Who is Concerned About Carbon Emissions and the Potential Impacts of Climate Change Be Opposed to EPA’s Clean Power Plan?

[A version of this post entitled, “U.S. Missing the Mark on Climate Policy” was published in GeorgiaPol as a guest Op-Ed]

The old expression, “Every little bit helps”, doesn’t hold true for global CO2 emissions if the little bit that helps in one country doesn’t translate and scale up to something systemic and impactful in emerging economies throughout the world where billions live in energy poverty and more energy is needed, not less. EPA’s Clean Power Plan is such an example as it gives the appearance of commitment to addressing climate change issues, yet will have little-to-no impact on the actual issues of energy, carbon, and climate at the scale of concern: the global scale. We don’t need this sort of regulatory greenwashing to respond to an issue of this magnitude.
We can do better than this…we have to.

Top 15 GDP’s in the world (based on 2015) ranked by CO2 intensitytop-15-gdp-for-cpp-blog

The Clean Power Plan Under Fire
Climate change, CO2 emissions, fossil fuel consumption, EPA’s Clean Power Plan (CPP) and the U.S. power sector. In some circles these topics are generally inseparable and they’re often conflated into mischaracterizations. Currently, a 24-state coalition is petitioning President-elect Donald Trump and congressional leaders to withdraw EPA’s Clean Power Plan, which proposes to, by the year 2030, reduce CO2 emissions from the U.S. power sector by 32% indexed to 2005 levels. The argument of the petitioners is based on constitutional grounds. However, the rule was developed based on global climate change rationale, and on that basis the substance of the rule falls far short of its hype.

Some Facts and a Mischaracterization
How can someone who is concerned about global CO2 emissions and the potential impact of climate change be opposed to EPA’s Clean Power Plan? It’s a fair question and it deserves a fair answer. I’ll begin with some specific facts and a general mischaracterization:

  1. CO2 emissions are increasing annually
    • This is a measurable fact
  2. Atmospheric CO2 concentrations are increasing
    • This, too, is a measurable fact
  3. Climate is changing
    • Independent of causation, this is a scientific fact
  4. EPA’s Clean Power Plan was proposed in order to lower CO2 emissions by reducing emissions from the U.S. power sector
    • This, too, is a fact.
  5. Anyone opposed to the Clean Power Plan denies the science of climate change, is unconcerned about human welfare and environmental health, is a shill for big energy, and is willing to sell out the future of our children and grandchildren for the sake of money and corporate profits.
    • Here, I’ll draw the line between fact and selective mischaracterization; selective mischaracterization being translated as: “if you’re not for us, you’re against us”.

I accept the fact that annual CO2 emissions and atmospheric CO2 concentrations are increasing. I accept the current science that climate is changing, independent of who is causing it, and I’m concerned about the potential impact of climate change and I want to work toward solutions that are technically realistic and economically feasible. I accept that EPA proposed the Clean Power Plan to reduce CO2 emissions.

With that said, I also oppose the Clean Power Plan as a misguided rule that may give us a good feeling we’re solving a problem, but only greenwashes over the one aspect that’s often little more than background noise in our energy-climate debates: that word being, “global”.

U.S. Energy-Climate Policy
Global CO2 emissions, global atmospheric CO2 concentrations, global climate: These are global issues, not just U.S. issues, and they will require global solutions, not just U.S. solutions. And the regions where these issues are of greatest concern are emerging and developing economies on the other side of the world where fossil fuel consumption and CO2 emissions have been increasing for years and where emissions are just beginning to ramp up (Figure 1). Even though China has escalated carbon to unprecedented levels, India represents an immediate concern as it is positioning itself for rapid economic development. If India follows China’s model of carbon-intensive economic growth, which no one can rightfully blame them for wanting to do, carbon increases will follow. It’s evident, then, that the current escalation in CO2 emissions is not from the U.S. economy nor is it from the U.S. power sector, where CO2 emissions have been decreasing for some time (Figure 2). As such, my concern with the CPP is not to dismiss the U.S. from all efforts to reduce CO2 within the U.S. My concern is that U.S. climate policy is misdirecting our attention away from the current source of the issue and toward a sector that’s already reducing carbon emissions–although this reduction trend in the U.S. power sector is being threatened by the potential loss of nuclear capacity in markets that can’t appropriately value zero-carbon baseload power. Within the context of global CO2 emissions, the U.S. power sector shouldn’t be the focus of U.S. climate policy (Figure 3). The CPP promotes the transition from coal to natural gas combined-cycle plants (which the power sector is already doing) and specifically incentivizes solar and wind to the exclusion of nuclear power. Why the plan targets solar and wind but not nuclear is another debate unto itself. What is clear is that for us to address global CO2, we’re gonna need a much bigger boat than just the U.S. power sector and it will need to be powered by something far more reliable than intermittent solar and wind energy.

Figure 1. CO2 emission trends for the top 15 gross domestic product countries (based on 2015) in the world. China leads, the U.S. is decreasing, India is increasing.co2-emissions-top-15-gdp

Figure 2. CO2 emission trends for the U.S. electric power sector. In 2015, the U.S. power sector was at 1993 levels and was 20.6% below 2005 levels. EPA’s Clean Power Plan proposes to reduce emissions 32% (indexed to 2005) by 2030.co2-us-power-sector-epa-cpp

Figure 3. CO2 emissions from the U.S. power sector in the context of total global CO2 emissions.epa-cpp-opposition

Perhaps even more telling is an analysis of current carbon intensities. Since energy consumption, carbon emissions and economic growth are generally linked, it’s helpful to normalize carbon emissions to economic activity as an indicator of how efficient an economy is at generating economic output while emitting CO2 (Table 1). In this regard, the U.S. (at 304.1 mtons of CO2 per million US$), ranks lower than the world total, which stands at 453.5 mtons of CO2 per million US$. In addition, China’s carbon intensity of 831.6 mtons of CO2 per million US$ is 2.73 times that of the U.S., while India’s intensity of 1,058.7 mtons of CO2 per million US$ is 3.66 times greater than the U.S. The issue of concern here is that the country where economic growth is expected to ramp up most immediately and most quickly is also the country with the 2nd highest carbon intensity in the world—India.

Table 1. CO2 emissions, GDP, and CO2 intensities (metric tons per million US dollars of gross domestic product) for the top 15 GDP producing countries in the world for 2015. U.S. CO2 intensity is below the world total. In addition, India’s CO2 intensity is 3.66 times that of the U.S. and China’s is 2.73 times greater than the U.S. top-15-gdp-for-cpp-blog

In light of these data trends and overarching concerns about global carbon emissions, it’s reasonable to conclude that EPA’s Clean Power Plan focus on the U.S. power sector is misdirected in its intention to reduce global carbon emissions. Moreover, since it will incur costs, it’s a misappropriation of U.S. resources that could be better invested in developing next-generation nuclear power technologies for the U.S. and modern power generation systems in countries where carbon reduction is most needed. My overall recommendations are offered in a paper that will be published next month in The Electricity Journal (click here for In-Press article) and as part of those recommendations I propose that U.S. energy policy focus on cultivating investment opportunities for U.S. industry to engage with emerging economies in the development of power generation systems to provide reliable, affordable, safe and lower-carbon electricity. And this should include nuclear power at the very center with natural gas combined-cycle plants, geographically appropriate renewables, microgrids, and energy storage technologies around it.

This is a big issue at the largest of all possible scales—the global scale—with billions of people living in energy poverty needing dependable power generation systems to support their economic hopes. And this will not yield to greenwashing-type regulations that wring out a few more ounces of CO2 from the U.S. power sector—no matter how good those regulations may make us feel.

In the global context, the substance of EPA’s Clean Power Plan just doesn’t measure up to its hype.


2 thoughts on “EPA’s Clean Power Plan: We Can Do Better”

  1. I’m glad someone feels similarly as I do about this topic. We’ve sacrificed so much in the name of efficiency that we forget about possible conflicts of interest, such as in the situation of internal auditing. And in giving the excuse of wanting efficient governance, we’ve subverted democratic institutions (such as the separation of powers in the executive, judicial and legislative branches to government) to the extent that their existence almost certainly misses the point as far as the principles behind their existence are concerned.


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