Abby L. Harvey
GHG Monitor
12/12/2014
The emissions reduction goals within the Environmental Protection Agency’s proposed carbon emissions standards for existing coal-fired power plants are significant, but not enough, a group of 10 Senate Democrats and an Independent wrote in a Dec. 9 letter to EPA Administrator Gina McCarthy. “We believe that the rule could be further improved to reflect real world market conditions, and better align with existing state energy policies by making modest changes to the methodologies used in setting targets for renewable energy and energy efficiency,” the group wrote. The EPA proposal, dubbed the Clean Power Plan, sets state-specific carbon emission reduction targets and requires states to develop action plans to meet those targets. Within the proposed regulations, EPA suggests a path to emissions reductions using four “building blocks”—heat rate improvements at the coal units, increased use of natural gas units, increased use of renewable and nuclear energy and demand-side energy efficiency.
However, according to the authors of the letter to McCarthy, the EPA underestimated the potential of renewable energy and energy efficiency measures when calculating possible emissions reductions. The letter was signed by Sens. Jeff Merkley (D-Ore.), Brian Schatz (D-Hawaii), Ben Cardin (D-Md.), Barbara Boxer (D-Cali.), Ed Markey (D-Mass.), Cory Booker (D-N.J.), Ron Wyden (D-Ore.), Bernie Sanders (I-Vt.), Sheldon Whitehouse (D-R.I.), Dianne Feinstein (D-Cali.) and Elizabeth Warren (D-Mass.).
Non-Fossil Energy Targets Inaccurate
The third “building block” of the Clean Power Plan calls for an increase in non-fossil energy including renewables and nuclear. The group notes that the nation’s energy systems do not follow state borders and thus calls on the EPA to recognize renewable energy potential at the regional as opposed to state-specific level. “This approach would result in an accurate depiction of achievable state goals for renewable energy use,” the letter says.
Further, the group of senators wrote that the data the EPA used in developing the rules was outdated and didn’t reflect the true potential of renewable energy generation. The group suggested that the “EPA should make use of data from not only the Energy Information Administration, but also the National Renewable Energy Laboratory and Lawrence Berkeley National Labs, to reflect the latest renewable energy and energy efficiency technology costs and resource potentials.”
The group also noted that the proposed rule does not account for distributed generation. “Utilities are increasing the use of distributed generation within their energy portfolios, and are purchasing renewable energy credits from distributed units to reduce carbon emissions in a cost-effective manner. Distributed renewable energy generation is a well-demonstrated technology and market, and should be accounted for as a component of [Best System of Emissions Reduction] in the Clean Power Plan,” the letter says.
Energy Efficiency Target Can be Increased
The fourth “building block” in the EPA’s proposed rule addresses demand-side energy efficiency measures. The target of a 1.5 percent annual energy efficiency improvement was calculated based on what is currently done in “top performing states.” However, this calculation only reflects what is currently being done, not what can be done, the senators wrote. “We believe that the 1.5 [percent] annual energy savings target is a readily achievable level of ambition for the suite of energy efficiency measures generally pursued by utility-based energy efficiency programs,” the letter says. “We recommend that the EPA also consider the additional energy savings that can be achieved through measures outside of these programs, and increase the annual energy savings targets in Building Block Four accordingly.”
