Why FAQ’s?

Not everyone has the time or inclination to read the EPA’s 645-page proposed rule to reduce CO2 emissions rates from existing power plants, so we thought it would be useful to present answers to frequently asked questions about the rule. The following FAQ’s are distilled from EPA fact sheets, newspaper articles, and numerous webinars, white papers, and analyses that have appeared about the proposed rule since it was released on June 2, 2014.

Navajo Generating Station. Photo: EPA

What is the Clean Power Plan? On June 2, 2014, the U. S. Environmental Protection Agency (EPA) released a proposed rule that requires each U.S. state to reduce its CO2 emissions rate from existing fossil fuel plants to meet state-specific standards starting in 2020, with a final emissions reduction target date of 2030. EPA estimates that the rule will achieve a 30% reduction in CO2 emissions from the U.S. electric power sector in 2030 relative to 2005 levels. This interactive map from EPA shows CO2 emissions reduction targets by state.

What authority does EPA have to do this?

• In 1970 the Clean Air Act was enacted by President Nixon to address growing national concern over air pollution. The Clean Air Act gave EPA the responsibility for setting emission standards for certain air pollutants.
• In 2007 the U.S. Supreme Court ruled in Massachusetts v. EPA that greenhouse gases are air pollutants, so they must be regulated by EPA if they threaten or endanger public health.
• In 2009 an EPA endangerment finding declared that current and projected concentrations of six key greenhouse gases— including CO2—threaten the public health and welfare of current and future generations. With this finding, EPA’s authority to regulate greenhouse gas emissions was established.

Why all the different names: 111(d), Clean Power Plan, carbon rule?

These are all terms for the same thing.

• 111(d) is the section of the Clean Air Act that gives the EPA authority to regulate dangerous air pollutants not specifically included in the original Act. This has become a very important section of the Clean Air Act because it allows EPA to regulate pollutants that were not understood to be hazardous in 1970 when the Clean Air Act was passed. The term 111(d) is now used by some people to denote EPA’s proposed rule to control carbon pollution from existing power plants.
• EPA regulates air pollution by proposing and implementing “rules,” so “carbon rule” is another term used for the CO2 emission standards EPA is proposing.
• Clean Power Plan is the term EPA is using for the proposed rule.

Why power plants? How much do they contribute to CO2 emissions?

Power plants are the largest source of CO2 emissions in the United States, making up a third of our nation’s greenhouse gas emissions.

Does the rule regulate all greenhouse gases?

No. The Clean Power Plan only sets emissions reduction targets for Carbon Dioxide (CO2).

How are CO2 emissions measured in the proposed rule?

Emissions are measured as a rate: Pounds of carbon dioxide per megawatt hour of electricity generation, or lbs/Mwh

How will the Clean Power Plan affect Nevada?

EPA is proposing that Nevada develop a plan to lower its carbon pollution to meet a proposed emission rate goal of 647 lbs/Mwh in 2030.

EPA suggests “building blocks” for each state to meet its emission reduction goal. These building blocks consist of switching from coal generation to generation from either new or existing natural gas facilities; credit for new or existing nuclear power; using credit for renewable energy; and credit for energy efficiency improvements.  Nevada will choose how to meet the goal through whatever combination of measures reflects its particular circumstances and policy objectives. A state does not have to put in place the same mix of strategies that EPA used to set the goal.

Nevada may work alone or in cooperation with other states to comply with the proposed rule. EPA estimates that states could achieve their goals most cost effectively if they work with others.

What are Nevada’s CO2 emissions now from existing power plants? What will they be in 2030?

• In 2012, Nevada’s power sector CO2 emissions were approximately 14 million metric tons from sources covered by the rule.
• Nevada’s 2012 emission rate was 988 pounds/megawatt hours (lb/Mwh).
• EPA is proposing that Nevada develop a plan to lower its carbon pollution to meet its proposed emission rate goal of 647 lb/Mwh in 2030. This is a reduction of 35%.

Is this just something EPA is imposing, or does the state have a say?

Under the Clean Power Plan, EPA sets a carbon emission reduction target for each state, then the states have flexibility in designing a plan to meet those targets. The ways states can meet their targets are broad and varied, and could include energy efficiency programs, switching from coal to cleaner-burning natural gas, expanding renewables like wind, geothermal and solar, and even joining together with other states in regional “cap-and-trade” markets. Only if states do not come up with a state plan to meet the emission reduction targets will EPA impose standards on them.

In the proposed rule, the emission reductions targets for each state are different. How did EPA determine what reduction target to assign to each state?

In determining the state-by-state reduction targets, EPA considered a wide range of potential measures to reduce CO2 emissions from existing power plants, and came up with a “Best System of Emissions Reduction” (BSER) that includes coal heat rate improvements, switching from coal generation to combined-cycle natural gas, increased deployment of renewable energy and nuclear power, and increased energy efficiency. EPA then used these four “building blocks” in a formula to calculate the emission reduction that each state could achieve. Since the existing mix of electricity generation and the capacity to switch to different fuel sources is different in each state, the reduction targets vary by state.

Though EPA relied upon these four “building blocks,” in calculating state-by-state emissions reduction targets, states have broad flexibility to use other strategies in implementing their own emissions reduction plans.

How do emission reduction requirements for Nevada compare with those for other states?

• Nevada’s emission reduction target is 647 lbs/Mwh. This is a 35% reduction from 2012 levels.
• The national average reduction target is 987 lbs/Mwh. This is a 25% reduction.
• As a comparison, South Carolina is being asked to lower its emissions rate by 51%; Wyoming is being asked to lower its emissions rate by only 19%.

This interactive map from EPA shows CO2 emissions reduction targets by state.

Is it possible for Nevada to achieve the required reduction without “freezing in the dark?” CO2 emissions from electrical generation in Nevada have already dropped significantly over the past decade, as Nevada utilities switched from coal to cleaner-burning natural gas and to renewables. In the ten years from 2002 to 2012, CO2 emissions from electrical generation in Nevada dropped from about 21 million to 14.9 million metric tons annually.

The switch away from coal in Nevada will continue, EPA rule or not. SB123, passed in the last Nevada legislative session, mandated that NV Energy close the Reid Gardner coal-fired power plant in southern Nevada and withdraw from its share of the Navajo coal plant in Arizona, replacing the coal capacity with natural gas and renewables.

With state and NV Energy initiatives including the implementation of SB123; a state Renewable Portfolio Standard mandating 25% renewable energy by 2025; the ongoing switch from coal made possible by the historically low price of natural gas as well as the plummeting costs of renewable energy; and building on energy efficiency efforts already underway, Nevada is in a good position to meet the emissions reduction target with minimal impact on ratepayers.

How much will it cost?

EPA projects  that the nationwide compliance costs for this rule would be between $7.3 billion and $8.8 billion annually by 2030. This would lead to about a 3 percent increase in electricity rates by 2030.

The New York Times reports that while “Opponents attacked Mr. Obama’s plan in vociferous terms, with the claim about Americans ‘freezing in the dark’…more optimistic assessments of the plan came from utility executives and many state officers who would have to carry it out. Some independent energy experts said that electricity prices may rise by a few percentage points in some states, but even that is not a foregone conclusion. ‘I predict this will be far easier and far faster and far cheaper than most people realize,’ said Hal Harvey, chief executive of Energy Innovation…”

A study by the U.S. Chamber of Commerce puts the cost much higher, but according to an article in The New Republic, “The Chamber’s study included all kinds of shaky assumptions and its prediction of higher electricity prices was not actually that big. As Jonathan Chait observed in New York magazine, ‘Even the Chamber’s unrealistically dire number is still low enough that most people would barely notice it.’”

What are the benefits?

EPA says the Clean Power Plan will lead to climate and health benefits worth an estimated $55 billion to $93 billion in 2030, including avoiding 2,700 to 6,600 premature deaths and 140,000 to 150,000 asthma attacks in children.

What does the proposed rule say about nuclear power?

Nevada has no nuclear power plants, but in some states, nuclear power may play a role in achieving the state’s emission reduction goal. In the rule, the EPA acknowledges the role of “clean” nuclear power in achieving the state goals. The EPA assumes states will be “completing all nuclear units currently under construction, [and] avoiding retirement of about six percent of existing nuclear capacity” The EPA says that the challenge of nuclear waste disposal, contamination risks, and other environmental impacts associated with nuclear power are outweighed by its clean energy benefits.

What does the proposed rule say about energy efficiency as a way to meet emissions reduction goals?

The EPA proposes a “portfolio approach” to meeting a state’s emissions reduction goals. The portfolio could include energy efficiency measures implemented either by electrical generators or by other entities.

What difference will the proposed rule make in halting global warming?

According to the EPA, the Clean Power Plan will result in:

• By 2030, a 30% reduction in CO2 emissions from U.S. power plants from 2005 levels
• 30 million metric tons less carbon pollution

Unfortunately, this is not enough. According to the New York Times, “Climate scientists say that emissions in the developed countries need to fall 80 percent or more by 2050 if global warming is to be held to tolerable levels. Mr. Obama’s draft plan does not put the United States on a trajectory that would make such a huge cut likely to be achieved.”

But expected regulations reducing methane emissions from landfills and pipelines will also help the US reduce greenhouse gas emissions to the levels pledged by President Obama in 2009. Moreover, the Clean Power Plan sends a very strong message to the rest of the world that the US is serious about cleaning up carbon pollution. So it’s a start. And in the continued lack of congressional action on climate change, it’s much better than nothing.

What’s the timeline?

• June 2, 2014: draft rule released
• Comment period open until October 16, 2014
• Rule finalized 2015 S
• tates will have until June 2016 to submit initial state implementation plans
• State plans finalized by June 2017 for stand-alone plans, and by June 2018 for multi-state plans
• Emission reduction target date is 2030

How can I comment to the EPA about the Clean Power Plan?

Use this link to see a public meeting schedule or to comment (by October 16, 2014):  This link takes you to EPA’s webpage about the Clean Power Plan where there are also many fact sheets, as well as the full 625-page rule and technical supporting documents.

Carson City after Waterfall Fire

Climate change heats up this summer – the issue as well as the air temperature – and what takes place this spring and summer will determine what we as a nation will do – or not do – to mitigate climate change.

No surprise, no action on climate is coming out of a deadlocked Congress . This month there were anti-climate amendments to a very good – now dead – energy efficiency bill, one of them sponsored by our own Dean Heller. And in the lack of action, the thirty-eight members of the Congressional Safe Climate Caucus continue to fight the “conspiracy of silence in Congress about the dangers of climate change” by standing up and talking about it at any opportunity. Their grandchildren will thank them.

Nevada’s Congressional Representatives Dina Titus, Joe Heck, Mark Amodei, and Steven Horsford are not part of the cCongressional Safe Climate Caucus. Maybe their constituents should ask that they join. Their grandchildren will thank them.

Executive action

It’s clear that the Obama Administration has settled on executive action to do what Congress will not. Here’s a rundown of how all this climate activity relates to Nevada.

EPA carbon standards for existing power plants due June 2

The EPA will issue draft standards for carbon pollution from existing electrical generation on June 2. The standards will apply to all existing electrical generation facilities, and they are the subject of much speculation: How much leeway will states have to draft standards to fit their own circumstances? Will utilities be allowed to use energy efficiency and renewable energy to offset their carbon emissions? Will the standards direct an actual reduction in the total amount of carbon emitted, or only a reduction in the carbon intensity? And finally, who will sue the EPA first?

What will Nevada do?

Nevada is in a good position to comply with new carbon standards. With the closure of three units of the Reid Gardner coal-fired power plant this year, the closure of the forth unit next year, and withdrawal from its share in the Navajo Plant in Arizona, NV Energy’s only remaining coal-fired generation facility will be the Valmy Generating Station in northern Nevada. Natural gas has become the fuel of choice for NV Energy, and while some carbon pollution results from the burning of natural gas to generate electricity it is much less than coal. (Though methane pollution from mining, transporting and incompletely burning natural gas does occur – and methane is a much more potent greenhouse gas than carbon dioxide.)

NV Energy also plans to replace a portion of the coal generation with renewable energy. If NV Energy established a firm commitment to move to renewable energy for most or all of its generation capacity, with the state’s abundant renewable resources, the state could be a leader in a clean energy economy.

Nevada’s Dean Heller joins in Republican resistance derailing Portman Shaheen energy efficiency bill

Republican resistance to EPA’s upcoming carbon standards helped derail a bipartisan energy efficiency bill this week. Senate Majority Leader Harry Reid refused to allow Republican amendments supporting the Keystone XL Pipeline and opposing the pending carbon regulations. Neither side backed down, and the bill died. Heller’s proposed amendment would have required the EPA to go through an exhaustive list of potential economic impacts before establishing any pollution standards for the production, use or supply of energy.

National Climate Assessment released last week – Nevada fact sheet

Last week the Obama administration released the third U.S. National Climate Assessment—the most comprehensive scientific assessment ever generated of climate change and its impacts across every region of America and major sectors of the U.S. economy. Here’s the climate change bottom line for our region:

“Increased heat and changes to rain and snowpack will send ripple effects throughout the region, affecting 56 million people – a population expected to increase to 94 million by 2050 … Severe and sustained drought will stress water sources, already over-utilized in many areas, forcing increasing competition among farmers, energy producers, urban dwellers, and ecosystems for the region’s most precious resource.”

Increased warming, drought, and insect outbreaks, all caused by or linked to climate
change, have increased wildfires and impacts to people and ecosystems in the Southwest.
Fire models project more wildfire and increased risks to communities across extensive
areas. ”

Maybe Dean Heller should start proposing amendments directing the EPA to evaluate the costs of drought and wildfire in the lack of significant action on climate change. This is, after all, the region he represents – as climate change heats up.

Working Group 2 of the international Panel on Climate Change is tasked with evaluating the impacts of climate change and how we might adapt to it. Their report, Climate Change 2014: Impacts, Adaptation, and Vulnerability came out today. Here’s some of the take-away, with links to more information.

“In recent decades, changes in climate have caused impacts on natural and human systems on all continents and across the oceans.”

Shepherd and sheep in Tibet: A key risk of climate change is the loss of rural livelihoods, especially in the least developed countries. The impacts of climate change will be felt most strongly by the poor and vulnerable in all nations.

Here are key risks to human and natural systems that the working group has a high confidence will occur, based on the state of our knowledge so far:

• food insecurity and the breakdown of food systems linked to warming, drought, flooding, and precipitation variability and extremes, particularly for poorer populations in urban and rural settings.

• loss of terrestrial and inland water ecosystems, biodiversity, and the ecosystem goods, functions, and services they provide for livelihoods.
• loss of marine and coastal ecosystems, biodiversity, and the ecosystem goods, functions, and services they provide for coastal livelihoods, especially for fishing communities in the tropics and the Arctic.
• death, injury, ill-health, or disrupted livelihoods in low-lying coastal zones and small island developing states and other small islands, due to storm surges, coastal flooding, and sea-level rise.
• severe ill-health and disrupted livelihoods for large urban populations due to inland flooding in some regions. risks due to extreme weather events leading to breakdown of infrastructure networks and critical services such as electricity, water supply, and health and emergency services.
• mortality and morbidity during periods of extreme heat, particularly for vulnerable urban populations and those working outdoors in urban or rural areas.
• loss of rural livelihoods and income due to insufficient access to drinking and irrigation water and reduced agricultural productivity, particularly for farmers and pastoralists with minimal capital in semi-arid regions.
• Many key risks constitute particular challenges for the least developed countries and vulnerable communities, given their limited ability to cope.

“Increasing magnitudes of warming increase the likelihood of severe, pervasive, and irreversible impacts. “

This is a sobering list. Loss of ecosystems. Increased food insecurity. Ill health. Disrupted livelihood.

This chart from the IPCC shows projected temperatures with little or no mitigation efforts (orange) and projected temperatures with mitigation efforts (blue).

Yet the effects will be even worse if we do nothing to mitigate climate change by lowering global greenhouse gas emissions and undertaking other mitigation efforts. The Climate Change 2014 report says that while some risks of climate change are considerable at 1 or 2°C above preindustrial levels, climate change risks become “ very high” with global mean temperature increase of 4°C or more.

These risks include “severe and widespread impacts on unique and threatened systems, substantial species extinction, large risks to global and regional food security, and the combination of high temperature and humidity compromising normal human activities. The precise levels of climate change sufficient to trigger tipping points (thresholds for abrupt and irreversible change) remain uncertain, but the risk associated with crossing multiple tipping in human and natural systems increases with rising temperature .”

“The overall risks of climate change impacts can be reduced by limiting the rate and magnitude of climate change. “

But all is not lost.

The Climate Change 2014 report says that risks are reduced substantially with lower temperature rise. Climate change impacts may be less likely to overwhelm human and natural systems and might be easier to adapt to. But the sooner mitigation efforts are undertaken, the less dire the consequences of climate change.

This is a challenge, when few national governments are making even close to the efforts that will be needed to avoid the worst effects of climate change. It is the task of everyone alive in the world today – and our governments – to make sure that the higher temperature rises do not occur. 

Here’s a link to a video about the Climate change 2014 report.
And here’s a link to a page where you can download the full Climate Change 2014 report or a summary for policymakers.

More on the IPCC

The Intergovernmental Panel on Climate Change (IPCC) was established by the United Nations Environment Program (UNEP) and the World Meteorological Organization (WMO) in 1988 to provide the world with a clear scientific view on the current state of knowledge in climate change and its potential environmental and socio-economic impacts.

The IPCC reviews and assesses the most recent scientific, technical and socioeconomic information produced worldwide relevant to the understanding of climate change. Thousands of sicentists from throughout contribute to the IPCC”s work (on a voluntary basis)
It is the role of the IPCC to inform governments about the most up-to-date scientific knowledge on an issue and, where appropriate, to highlight policy options to overcome challenges, but the IPCC never promotes one set of policy options over another.

The Assessment Report and the three working  groups

The decision to prepare a Fifth Assessment Report (AR5) of the Intergovernmental Panel on Climate Change (IPCC) with three Working Group contributions and a Synthesis Report was taken by the member governments of the IPCC at their 28th Session in April 2008.
Working Group II assesses impacts, adaptation, and vulnerability. Working Group I assesses the physical science basis of climate change, while Working Group III assesses the mitigation of climate change.. Working Group I deals with “The Physical Science Basis of Climate Change”, Working Group II with “Climate Change Impacts, Adaptation and Vulnerability” and Working Group III with “Mitigation of Climate Change”. A Synthesis Report will draw on the assessments made by all three Working Groups

What does Working Group 2 do?

The IPCC Working Group II (WG II) assesses the vulnerability of socio-economic and natural systems to climate change, negative and positive consequences of climate change, and options for adapting to it. It also takes into consideration the inter-relationship between vulnerability, adaptation and sustainable development. The assessed information is considered by sectors (water resources; ecosystems; food & forests; coastal systems; industry; human health) and regions (Africa; Asia; Australia & New Zealand; Europe; Latin America; North America; Polar Regions; Small Islands).