EESI Gives EPA Comments on Power Plant Regulations of Carbon Emissions

On December 1, the Environmental and Energy Study Institute (EESI) submitted comments to the Environmental Protection Agency (EPA) on its Clean Power Plan, a draft regulation to cut carbon emissions from existing power plants. EESI’s comments stem from its position as an independent, non-partisan nonprofit, dedicated to advancing the transition to a low-carbon economy through energy efficiency, wisely-built infrastructure and a diverse portfolio of low-carbon power generation. EESI’s comments applauded EPA’s efforts to provide states flexibility in choosing compliance options, particularly by allowing states to cut emissions using “outside the fence” options, such as consumer energy efficiency and renewable energy. However, EESI pointed out that EPA’s plan does not recognize the full array and potential of compliance tools available to states, and relies too heavily on a strategy of expanded natural gas power generation.

In its comments, EESI acknowledged that many states will need to rely heavily on natural gas to meet the emissions targets outlined in the Clean Power Plan; however, EESI is deeply concerned about the climate and public health impacts of fugitive methane emissions from natural gas production and transport. Methane is a powerful climate-warming pollutant, which warms the climate 87 times more than carbon dioxide over a 20-year time span. Leaks from the oil and gas sector release 29 percent of U.S. methane emissions. EPA is considering regulating fugitive emissions and may release a draft regulation soon; EESI urges EPA to make these regulations strong. Regulating methane will be a critical component of the Clean Power Plan, if it is to live up to its intended promise of mitigating climate change.

Renewable energy is one of the Clean Power Plan’s four “building blocks” of compliance measures states can adopt to cut their emissions. But EESI is concerned that EPA’s renewable energy targets are not strong enough to account for the progress renewable energy has already made and will continue to make. A recent study by the Natural Resources Defense Council (NRDC) found that analysts price renewable energy at almost half the cost used by the agency. Another study by the Union of Concerned Scientists (UCS) stated that seven states are already producing more renewable energy than EPA’s 2030 targets for them, with an additional 17 states legally bound to produce more renewable energy than EPA’s targets. EESI asked EPA to recalculate its data to help states understand the true costs and benefits of renewable energy as a compliance strategy.

In addition, EESI advocates the use of combined heat and power (CHP), district energy, biomass power generation, bioenergy, building codes and energy efficiency retrofits as compliance options. These technologies are the underappreciated workhorses of greenhouse gas emission reduction efforts.

CHP and district energy are ways of increasing efficiency within traditional fossil fuel power plants, by capturing waste heat and using it to provide heat and/or hot water to either the plant itself or to nearby buildings, urban areas, college campuses, etc. CHP and district energy raise the efficiency of a traditional fossil fuel power plant from around 34 percent (two thirds of the combustion energy used to generate electricity is typically wasted) to close to 90 percent.

Biomass power, according to the Energy Information Administration (EIA), generates 22 percent of the renewably-produced electricity in the United States. EPA’s plan should recognize bioenergy as a low-carbon source of consistent, baseload power that also provides significant local economic and environmental co-benefits. Purpose-grown biomass crops can support multi-function agricultural systems by increasing organic carbon in the soil, and using waste biomass as a feedstock monetizes a waste stream that would otherwise pose significant environmental problems to communities.

Building codes and energy efficiency retrofits strike at the building sector’s carbon emissions, which amount to 40 percent of total U.S. greenhouse gas emissions. Buildings consume 70 percent of the electricity produced in the United States, much of which is wasted due to poor design and construction, deterioration over time, and old appliances that consume outsized amounts of electricity. EESI recommends that EPA include updated, more energy-efficient building codes as a Clean Power Plan compliance option. In addition, EESI urges EPA to also recognize energy efficiency retrofit programs for buildings, which exist both in the public and private sectors, as Clean Power Plan compliance options.

In conclusion, EESI notes that the finalized Clean Power Plan will provide a baseline for future regulation of greenhouse gases. It is, therefore, imperative that the final regulation not be short-sighted and not give outsized influence to natural gas at the expense of cleaner, cheaper renewable and energy efficiency measures.

Please refer to EESI’s comments for more information about the compliance strategies listed above, as well as information about how resilience and better electricity transmission can support overall greenhouse gas reduction efforts.