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Four reasons why Wheeler’s Clean Power Plan “replacement” will lead to more pollution

Dreamstime.com

By Rama Zakaria

EPA Administrator Andrew Wheeler has sent a draft rule that would roll back the Clean Power Plan to the White House for review – a step that suggests the rule is close to being finalized and released.

If this final rule looks anything like the hopelessly flawed and inadequate proposal that was released last August, it will scrap the Clean Power Plan – our nation’s only national limit on carbon pollution from the power sector – in favor of a “do-nothing” program that could actually increase pollution from inefficient, highly-polluting coal-fired power plants.

Even as the nation reels from wildfires, flooding, and hurricanes exacerbated by climate change, Wheeler’s proposal would place no meaningful limits on one of our nation’s largest contributors to climate-destabilizing pollution.

If our experience with the proposal is any guide, we can also expect the release of the final rule to be accompanied by a bevy of misleading assertions that Wheeler’s “replacement” for the Clean Power Plan is just as effective in protecting climate and public health.

Wheeler has already been making such claims. For instance, in testimony before the House of Representatives last month, Wheeler said that EPA’s proposed replacement for the Clean Power Plan would reduce carbon pollution from the power sector by 34 percent once fully implemented, and would go a long way towards meeting our carbon reduction goals for the country. These comments build on Wheeler’s claims during his Senate confirmation process that equated his replacement to the Clean Power Plan.

Here are four reasons why his claims are false:

First – EPA’s proposed replacement for the Clean Power Plan contains no binding limits on carbon pollution.

In stark contrast to the Clean Power Plan itself, the proposed replacement is not designed to achieve any particular level of carbon pollution reduction by any specific time. Instead, the proposed replacement simply provides a menu of “heat rate improvement” measures that would incrementally improve the operating efficiency of coal plants. The proposed replacement then leaves it up to the states to decide which – if any – of these measures to apply.

As a result, EPA’s projections about the extent to which the proposed replacement would reduce carbon pollution are based on pure speculation about how the states might implement the rule.

 Second – Wheeler’s statements are contradicted by EPA’s own analysis. Despite not requiring any binding limits, EPA assumes (in its Regulatory Impact Analysis for the proposed replacement) that heat rate improvements would be applied uniformly across all existing coal plants. But even according to this analysis, the proposed replacement would result in massive increases in climate pollution and health-harming soot and smog pollution when compared to the Clean Power Plan.

Those massive increases would result in more air pollution-related death and disease for Americans across the country. EPA’s own analysis shows that the proposed replacement would cause up to 1,630 additional premature deaths from air pollution and tens of thousands of additional childhood asthma attacks each year by 2030.

EPA’s analysis also indicates that the proposed replacement would lead to cumulative increases in carbon pollution of as much as 863 million short tons through 2030 when compared to the Clean Power Plan.

Most perverse of all, EPA’s own analysis shows that the proposed replacement would incentivize some coal-fired power plants to operate and pollute more – leading to more carbon pollution than no policy at all in as many as eighteen states in 2030.

 Third – Wheeler is taking credit for business as usual. That is, almost all of the emission reductions that EPA projects under the proposed replacement are due to power sector trends and cleaner baseline emission projections.

When the Clean Power Plan was finalized in 2015, the Energy Information Administration (EIA) projected that power sector carbon pollution in 2030 without the Clean Power Plan in place would be 10 percent below 2005 levels. Since then, the ongoing market shift towards a cleaner electricity resource mix has led to baseline emission projections declining over time. In its most recent 2019 Annual Energy Outlook, EIA projected that baseline carbon pollution without the Clean Power Plan would be 34 percent below 2005 levels in 2030. EPA’s proposed replacement would achieve trivial reductions below these baseline projections.

Worse still, the proposed replacement would do nothing to ensure that even this minimal level of emission reduction is actually achieved. Because the proposed replacement contains no binding limits on carbon pollution, and because the “heat rate improvements” upon which it is based are so ineffective, the proposed replacement would do nothing to ensure continued reductions in climate pollution if power sector trends begin to reverse themselves.

Wheeler’s House testimony thus claims credit for carbon pollution reductions that are expected to happen even without his proposed replacement – and his replacement would do nothing to reinforce or secure them.

 Fourth – Wheeler’s comparison of the Clean Power Plan and his proposed replacement misses a larger point – the missed opportunity at hand. His proposed replacement completely fails to consider the rapid reductions in climate pollution that scientists say are necessary to avoid the worst impacts of climate change – as well as recent trends in the power sector that make it possible to cost-effectively achieve far greater and faster reductions in that pollution than the Clean Power Plan originally contemplated.

As EDF demonstrated in our comments on the proposed replacement, the plummeting costs of clean energy have unlocked vast potential for low-cost reductions in carbon pollution. Updated analysis using the same power sector modeling platform that EPA relies upon shows that carbon pollution reductions of more than 50 percent below 2005 levels in 2030 can be achieved at similar costs to what the original Clean Power Plan envisioned. EIA has also found that even greater reductions of 68 percent below 2005 levels can be achieved by 2030 (along with steep reductions in health-harming soot and smog pollution) at modest cost.

Even as the Trump EPA has worked to roll back the Clean Power Plan, leading power companies across America have committed to steep reductions in carbon pollution and ambitious investments in clean energy. Just in the last few months, Xcel Energy, the Platte River Power Authority, and Idaho Power have all committed to completely decarbonize their generating portfolios.

In the face of these historic commitments and overwhelming data, the years-long rulemaking that Wheeler has undertaken to roll back the Clean Power Plan represents an outrageous lost opportunity to secure deep reductions in carbon pollution.

At a time when the consequences of climate change are urgent, and when some states and power companies are pressing forward with bold commitments to reduce pollution and deploy clean energy, Wheeler’s harmful proposal to replace the Clean Power Plan with do-nothing standards is especially damaging. It runs contrary to evidence and fails to meet EPA’s fundamental obligations under our nation’s clean air laws to protect human health and the environment.

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