Final Clean Power Plan More Ambitious, Flexible

On Monday, President Obama announced the release of the final Clean Power Plan (CPP), which sets mandatory limits on the amount of carbon dioxide emissions the nation’s fleet of existing power plants may emit. The rule is projected to reduce emissions 32 percent below 2005 levels by 2030.

“We’re the first generation to feel the impact of climate change. We’re the last generation that can do something about it,” Obama said, noting that power plants are the single largest source of carbon pollution, a key contributor to climate change. “Until now, there have been no federal limits to the amount of carbon pollution plants dump in the air.”

Some Plan Particulars

The complicated and controversial 1561-page rule was developed by the Obama administration using existing authority under the Clean Air Act—specifically, section 111(d). The plan, according to a Washington Post op-ed, “is about as flexible as possible,” because it allows each state to come up with its own compliance program to meet the federal standards.

In broad strokes, the plan is designed to accelerate an already-underway shift from coal-fired electricity to cleaner natural gas and renewables, along with increased energy efficiency, by requiring existing power plants to meet specific carbon dioxide emissions reduction guidelines. The U.S. Environmental Protection Agency (EPA) calculated the targets based on a “best system of emissions reduction” comprised of three building blocks: making existing coal plants more efficient; shifting generation from coal to gas plants; and increasing generation from renewables.

Once the targets are set, however, states do not have to use the building blocks as a framework for their plans, and have been given a range of market-based, flexible mechanisms to reach their state targets.  In fact, emulating the flexibility afforded power plants under the market-based program devised in 1990 to reduce sulfur dioxide emissions, the CPP allows states to create “trading-ready” plans that will allow affected plants to sell emissions credits or to buy credits, if that’s a less expensive option than taking other actions. Parallel compliance approaches remove the need for formal interstate trading agreements, an approach described in one of Duke University’s Nicholas Institute for Environmental Policy Solutions’ recent policy briefs. Also facilitating trading are new state goals reflecting uniform national emissions rate standards for fossil steam (coal and oil) and natural gas power plants, respectively, reports ClimateWire (subscription).

The centerpiece of the Obama administration’s push to slash U.S. carbon emissions 17 percent below 2005 levels by 2020 and 26–28 percent below 2005 levels by 2025, the final CPP was timed to build momentum toward the start of international climate talks in Paris in November. Lord Nicholas Stern, a prominent economist in the U.K., said the rule’s release will “set a powerful example for the rest of the world,” and will reinforce the credibility of the U.S. commitment to greenhouse gas emissions reductions as a new international agreement on climate change is being finalized.

Significant Changes from the Proposal

Changes to the final plan were expected, given some 4 million comments on the proposed plan, and the plan did not disappoint. One big change, according to Acting Assistant Administrator for the Office of Air and Radiation Janet McCabe, is based on the assumption that renewable energy and regional approaches have even greater capacity for helping the power sector reduce emissions than reflected in the draft proposal (subscription). Consequently, the final plan will cut power plant carbon emissions 32 percent below 2005 levels by 2030, rather than the 30 percent target in the proposed rule.

The final rule also axed what the draft proposal referred to as Building Block 4, a criterion for achieving emissions reductions through programs that improve electricity consumers’ energy efficiency, as a means of calculating the state targets. Although these efficiency standards and under-construction nuclear plants were left out of the criteria for setting state goals under the plan, both are still available as compliance options.

The plan also includes a Clean Energy Incentive Program that rewards states for investing early (2020–2021) in renewable energy, specifically solar and wind power as well as demand side energy efficiency in low-income communities. Details of the incentive scheme are yet to be worked out, but the final rule goals do now expect renewable energy sources to account for 28 percent of the nation’s capacity by 2030—up from 22 percent in the proposal (subscription). The aim, said EPA Administrator Gina McCarthy is to incentivize renewable energy, which will lessen the reliance on natural gas as a replacement for coal power as the dominant compliance strategy.

Many other changes were anticipated in the Nicholas Institute’s most recent policy brief, including:

• Additional time—an two extra years (to 2022)—for states to submit plans and begin cutting emissions;
• Easing of the interim goals “glide path,” which states can now craft for themselves; and
• New state mass emissions targets. These targets, based on states’ energy mixes and a uniform emissions rate for plants that use the same technology but no longer on demand-side energy efficiency, are less disparate than and also vastly different from those in the proposal. They also allow states to choose whether to use one target that includes the emissions from new natural gas units or another target that excludes these units (but still provides mechanisms to ensure that emissions cannot increase through new units).

The Climate Post offers a rundown of the week in climate and energy news. It is produced each Thursday by Duke University’s Nicholas Institute for Environmental Policy Solutions.