Yesterday the comment period closed on the Trump EPA’s proposed replacement for Obama-era Clean Power Plan, which the Agency proposed to repeal earlier this year. The Proposal, ironically named the “Affordable Clean Energy” (ACE) rule, is anything but affordable or clean. EPA’s own analysis shows that the Proposal would increase CO2 pollution from the electricity sector by as much as 117 million short tons in 2030 as compared to the Clean Power Plan, resulting in $3.4 billion in forgone climate benefits by 2035. And, by EPA’s own analysis, it would lead to at least 1,630 preventable premature deaths from air pollution as compared to the Clean Power Plan.
The Clean Air Act requires EPA to determine the best system of reducing CO2 emissions from existing power plants and set an emission limit based on that system. States then give each power plant its own standard based on that limit. But instead of setting any limit, the Proposal merely requires states to evaluate minor efficiency improvements.
The electric sector reduced its emissions by 28% since 2005, primarily by reducing demand and reducing generation at high-emitting, coal power plants and replacing it with generation from gas plants and renewable energy.
This is precisely the system of emission reduction that the Clean Power Plan is based on. However, instead of building on this system, EPA’s Proposal attempts to reverse these trends by increasing reliance on heavily-polluting coal. EPA’s own modeling, shown in the chart below, shows that, as compared to doing nothing, the Proposal increases coal generation and decreases reliance on gas, nuclear, wind and solar generation, leading to increased emissions of greenhouse gases and other health-harming pollution.
The shift seen under the Proposal is due to something called the “rebound effect.” EPA’s purported best system of emission reduction, heat rate improvements, increases the efficiency of a power plant by reducing the amount of fuel it needs to generate electricity. The improved coal plant economics results in them being called upon to generate more often, leading to increased emissions. The improved economics also extends the life of the coal plant and it takes a very short life extension to entirely wipe out any emission reduction associated with the efficiency improvement.
Under current law, if a power plant makes efficiency improvements that increase overall emissions, it must install the best available control technology, under the New Source Review program. But, to pave the way for increased coal use, ACE proposes to exempt heat rate improvement projects from this requirement, meaning that coal plants will run harder and longer increasing CO2 pollution but also deadly particle pollution and air toxics.
As the Clean Air Task Force told EPA yesterday in comments, the Clean Air Act requires the Agency to determine the best system of emission reduction for CO2 from existing power plants. This Proposal increases emissions and fails to build upon the very system of emission reduction the industry is using to great effect. The Agency’s only two options are to withdraw the Proposal or meet us in court!