Comments on Improving EPA’s Proposed Clean Power Plan

The summer deadline is approaching for finalizing the Environmental Protection Agency’s first-ever limits on dangerous carbon pollution from the nation’s power plants, and opponents are ratcheting up their complaints….

Source: www.huffingtonpost.com

“> […] Some 1500 mostly coal- and gas-fired power plants spew out more than two billion tons of heat-trapping carbon dioxide each year — 40 percent of the nation’s total. The vast majority of the millions of public comments submitted last fall express strong support for the Clean Power Plan, which as proposed last June starts in 2020 and ramps emissions down gradually over the next decade.

But big coal polluters and their political allies have big megaphones.

Many hope to kill the proposal outright. But for others the back-up agenda is to get the standards weakened and delayed past 2020. Their comments and speeches read like Armageddon is coming if power plants have to start limiting their carbon pollution in 2020 — five years from now. Republican members of the Senate environment committee banged that drum over and over at a hearing last week. As on so many issues, they hope endless repetition will make their story seem true.

The truth is that the standards and timeline EPA proposed last June are quite modest and readily achievable. They can be met without any threat to the reliability of electric power. A new report from the highly respected Brattle Group shows that states can meet the EPA’s proposal “while maintaining the high level of electric reliability enjoyed by U.S. electricity customers.” […]

The plan as proposed in June sets state-by-state targets that, on an overall national basis, would cut power plants’ carbon pollution by 26 percent by 2020 and 30 percent by 2030, when compared to 2005 levels.

We found that with three specific improvements – I’ll describe them below – the plan could achieve 50 percent more carbon pollution reductions (36 percent by 2020 and 44 percent by 2030).

Here are the three factors:

First, the costs of clean energy are falling dramatically, and EPA’s June proposal was based on out of date cost and performance data for renewable electricity and efficiency energy. An NRDC issue brief published last fall details how sharply the cost and performance of energy efficiency and renewable energy have improved. When we factored in up-to-date data, our analysis shows that the Clean Power Plan’s state-by-state targets as proposed in June 2014 can be met at a net savings to Americans of $1.8-4.3 billion in 2020 and $6.4-9.4 billion in 2030. More reliance on energy efficiency and renewables will also create hundreds of thousands of good-paying jobsthat can’t be shipped overseas.

The lower cost of clean energy technologies opens the door to getting substantially more carbon pollution reductions from the nation’s largest emitters.

We also took two other specific improvements into account:

In an October 2014 notice seeking further public comment, EPA explained that the formula it had used to calculate state targets in the June 2014 proposal did not correctly account for the emission reductions made by renewables and energy efficiency. The formula did not fully account for the reduction in generation at coal and gas power plants that occurs when additional renewables are added to the grid and when businesses and homeowners reduce how much electricity they need by improving the efficiency of our buildings, appliances, and other electricity-using equipment. NRDC corrected the formula in our updated analysis to capture the full emission reduction associated with ramping up renewables and efficiency.EPA also asked for comment on an approach to better balancing state targets by adopting a minimum rate of transition from older high-emitting generation to lower-emitting sources. NRDC analyzed state targets that include conversion of 20 percent of coal generation in 2012 to natural gas generation over the period between 2020 and 2029.

These three factors — updating the cost and performance data for renewables and efficiency, correcting the target-setting formula, and including a minimum rate of transition from higher- to lower-emitting plants — produce the substantial additional carbon pollution reductions in our analysis, all at very reasonable costs. […]”<

 

See EPA’s Clean Power Plan:  http://www2.epa.gov/carbon-pollution-standards/clean-power-plan-proposed-rule

 

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Clean Power Plan Seen as Historic Opportunity to Modernize the Electrical Grid

Following the launch of the Clean Power Plan, concerns were raised about how adding renewable energy to the grid would affect reliability. According to a new report […] compliance is unlikely to materially affect reliability.

 

image source:  http://phys.org/news/2010-10-electric-grid.html

Source: domesticfuel.com

>”[…] Report lead author Jurgen Weiss PhD, senior researcher and lead author said that while the North American Electric Reliability Corporation (NERC) focused on concerns about the feasibility of achieving emissions standards with the technologies used to set the standards, they did not address several mitigating factors. These include:

The impact of retiring older, inefficient coal plants, due to current environmental regulations and market trends, on emissions rates of the remaining fleet;Various ways to address natural gas pipeline constraints; andEvidence that that higher levels of variable renewable energy sources can be effectively managed.

“With the tools currently available for managing an electric power system that is already in flux, we think it unlikely that compliance with EPA carbon rules will have a significant impact on reliability,” reported Weiss.

In November 2014, NERC issued an Initial Reliability Review in which it identified elements of the Clean Power Plan that could lead to reliability concerns. Echoed by some grid operators and cited in comments to EPA submitted by states, utilities, and industry groups, the NERC study has made reliability a critical issue in finalizing, and then implementing, the Clean Power Plan. These concerns compelled AEE to respond to the concerns by commissioning the Brattle study.

“We see EPA’s Clean Power Plan as an historic opportunity to modernize the U.S. electric power system,” said Malcolm Woolf, Senior Vice President for Policy and Government Affairs for Advanced Energy Economy, a business association. “We believe that advanced energy technologies, put to work by policies and market rules that we see in action today, will increase the reliability and resiliency of the electric power system, not reduce it.  […]”<

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