Clean Power Plan Reductions Greater Than EPA Says

Tomorrow's final release of EPA's Clean Power Plan will require carbon dioxide reductions of 44 percent below 2005 levels by 2030

1,534 Mw Sandow Station coal-fired power plant in Rockdale, Texas. Credit: Steve Davidson

AUSTIN, Texas, Aug 2, 2015 – The Wall Street Journal this morning came out with an exposé revealing that the EPA has upped the ante for its controversial Clean Power Plan regulations. The final release of the plan is set for tomorrow. It’s the centerpiece to President Obama’s second-term climate change agenda.

There is much more to the story than the WSJ investigative team dug up.

According to the WSJ, at the last minute the EPA has ratcheted up the standard for carbon dioxide reductions for electric power plants from 30 percent below 2005 levels to a tougher 32 percent reduction.

That isn’t correct. The standard has been a 32 percent reduction since day one. Not only that, it’s not 32 percent below 2005 carbon dioxide levels; it’s 32 percent below 2012 levels. 2012 is the base year for EPA’s Clean Power Plan. In 2012, U.S. carbon dioxide levels had already dropped 12 percent below 2005 levels.

Thus, the real reduction level that EPA is setting for fossil fuel electric power plants is 44 percent below 2005 levels by 2030 and always has been.

Proof the standard has always been 44 percent is found in this EPA technical support document for the Clean Power Plan dated July 2nd, 2014 and titled “Clean Power Plan — Proposed State Goals”:

Shows the top of the Clean Power Plan State Summary Table. Source: EPA
Shows the top of the Clean Power Plan State Summary Table. Source: EPA

It’s an Excel spreadsheet, also sometimes called the state summary table. The URL for the document shows it’s a production file dated July 2nd, 2014. Column C of the spreadsheet clearly identifies its base year as 2012. U.S. Energy Information Administration 2012 carbon dioxide state-by-state emission figures confirm that the figures in column C are indeed from 2012 as labeled, not 2005. Column G sets the all-important 2030 reduction goals (in lbs/MWh) each state must meet.

That EPA table is the heart and soul of the entire plan. This writer discovered it and used the spreadsheet during preparation for EPA public testimony on the overall cost of the plan that I presented in Atlanta on July 30, 2014.

A cross check, using EPA’s naming convention, to see if there are any updates to that table for any of the subsequent addendum releases, including tomorrow’s final release, shows there aren’t any. Of course, a change to the table could still show up tomorrow when the final version of the rule is officially released.

The table data isn’t summarized by EPA within the spreadsheet itself. It’s just a list of four columns of numbers with one row per state. It’s a bit tricky to extract, but the data in the table contains all the information needed to show it has always required a 32 percent reduction below 2012 levels by 2030, instead of EPA’s publicly claimed 30 percent reduction below 2005 levels.

The table also contains some evidence of targeting of individual coal-fired power plants in states based on curiously odd individual state reduction settings in the table.

Here is one example…
Oregon gets most of its electricity from renewable sources, primarily hydroelectric. For its population, Oregon’s per capita emissions should be 1.2 percent of the nation’s total electric plant emissions, but it’s only 0.3 percent. Oregon is an exceptionally green state.

Oregon has only one coal-fired power plant. It’s the 550 Mw plant located in Boardman, Ore. Boardman generated 4 megatons (60 percent) of the 6.9 megatons of carbon emissions generated by Oregon power plants in 2012.

Boardman is also one of the coal-plants specifically targeted for closure by the Sierra Club, according to Wikipedia.

Oregon’s EPA Clean Power Plan goal is to reduce its carbon emissions by a suspiciously large 48 percent by 2030. No matter what, the only way for Oregon to meet its standard is to close Boardman. You could close all the other fossil fuel plants and not come close to enough to exclude Boardman from closure. But close Boardman and the standard is met with room to spare.

Washington State also has only one coal plant. It’s nation’s highest carbon reduction standard of 72 percent can only be met by closing its lone coal-fired plant.

Since the day it was first proposed, the EPA’s Clean Power Plan always required a 44 percent reduction in carbon dioxide emissions below 2005 levels by 3030. There has been no toughening of the rule. There is also some evidence that certain coal-fired plants have been specifically targeted for closure.

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