The EPA states that the goals are to be achieved by “application of the best system of emission reduction.” In practice, this has four major components: (1) decreasing reliance of coal-power power plants, (2) shifting electricity generation from coal to natural gas, (3) increasing electricity generation from renewable sources of energy, and (4) improving energy efficiency. States are free to choose combinations of these “systems” in order to meet the stated goals. States that have significant hydropower generation of electricity and existing (pre-2012) renewable energy installations cannot count these toward the new goals. Although commercial solar PV can be part of a state plan, distributed solar PV (e.g., rooftop solar installations) cannot be considered except post hoc as part of the compliance measurements. Energy from nuclear power plants can only be considered when the plant comes on line; no consideration is given for planned nuclear power installations.

Overall, this plan has much to recommend it. Certainly in this toxic political atmosphere where scientific consensus on anthropogenic climate change is ignored by a large number of the members of the U.S. Congress and a significant fraction of the public, any new environmental regulation is a heavy lift, even one that is as modest as this plan. Indeed, immediately after the release of this document, twelve states (Alabama, Indiana, Kansas, Kentucky, Louisiana, Nebraska, Ohio, Oklahoma, South Dakota, South Carolina, West Virginia and Wyoming) sued to block its implementation. Decreasing electricity production from coal and increasing renewable energy production accompanied by an increase in energy efficiency can only be considered a positive step. However, there are aspects of this plan that are problematic.

Perhaps the first is the exclusion of distributed solar from state plans. One of the criticisms of solar energy is its large footprint. Putting solar arrays on as many south-facing roof-tops as possible requires no additional space and empowers individuals to produce their own energy, either as a grid-tied or off-grid installation. One of the less touted, but nevertheless, important aspects of solar power is that the production is highest when the grid is under the highest load (the middle of the day on sunny days). This tends to smooth the fluctuations in the demand curve and decreases the need for new power plants. Making this a part of a state’s energy plan and providing incentives for individuals to invest in solar should be part of the EPA’s strategy. Communities throughout the country have successfully developed “Solarize” programs for bulk purchases of solar panels, discounts from installers, and creative payment plans to help individuals move to solar energy. Programs such as these combined with increased state and federal incentives would serve to level the playing field in an environment in which the fossil fuel industry is heavily subsidized by tax incentives, lax regulation, and lack of responsibility for the external costs of pollution.

The second issue is the suggestion that shifting from coal to natural gas (methane) would be a net gain for the environment. This is certainly a contentious issue, and the EPA’s analysis of the data in the Clean Power Plan gives little comfort. The overwhelming consideration in this document is given to CO₂ emissions. Since CO₂, with the exception of water vapor, is present in the highest concentration of any greenhouse case, this is certainly a good place to start. The problem is that, depending on how the data are considered, methane can be a very important contributor as well. In order to arrive at its conclusions, the EPA uses a value for the “Global Warming Potential” (GWP) of methane of 25 from the 2007 IPCC report. This means that they consider methane to have a 25-fold greater GWP than CO₂ over a 100-year time frame.

There are two problems with this. First, the number is out-of-date; the IPCC now considers the GWP of methane over 100 years to be 34. But that is not the worst of it. The 100-year time frame has always been considered arbitrary, with most of the effect of methane occurring in the first ten years. So that in the time-frame for which we are most concerned (10-20 years), the GWP of methane is on the order of 80 to 120. Given the leaks of methane from every step in the process of extraction, processing and distribution (which are likely underestimated by the EPA), the differences between the climate effects of coal and natural gas are much smaller than simply the 50% difference in CO₂ measured at the smoke stack of the power plant. More recently, the EPA has released a draft of regulations concerning fugitive emissions of methane and volatile organic compounds (VOCs).

These regulations, while still underestimating the GWP of methane, will be helpful at least for methane emissions at drilling sites, but perhaps less so in the distribution system and processing plants. Questions remain as to content of the final release of the regulations and how they will be enforced. Nevertheless, we can certainly support phasing out our dirty coal plants, but transitioning those plants to natural gas may not be the best solution and may in fact just delay our inevitable transition to renewable energy (accompanied by upgrades in the electrical distribution system). A good example is in our own upstate New York community, where the coal-fired Cayuga Power Plant is reaching the end of its useful life. One proposal is to replace the plant with a combined natural gas/coal-fired plant, the cost of which would be heavily subsidized by the electric rate payers. The alternative is a modest upgrade of the electrical grid at a fraction of the cost. The upgrade of the grid is the obvious solution and is consistent with the New York State Energy Plan.

The release of these encouraging regulations, however, comes at the same time that President Obama has approved Royal Dutch Shell’s application for drilling in the Arctic. This can only be seen as two steps forward and a giant step backward for combating climate change. Giving approval for drilling in a pristine and very dangerous environment with no room for error and at a time of very low oil prices is completely inconsistent with the positive steps taken by the EPA.

 

About the Authors

Robert Oswald is a professor of molecular medicine at Cornell University and the recipient of Fulbright and Guggenheim fellowships. They serve on the advisory board of Physicians, Scientists, and Engineers for Healthy Energy. Bamberger and Oswald live in Ithaca, New York.

 

 

Michelle Bamberger is a veterinarian and the author of two books on first aid for cats and dogs.