Clean Power Plan: The clock is ticking

EPA Clean Power Plan: Greenhouse gas emissions by energy sector. Electricity contributes 32 percent of the total

AUSTIN, June 18, 2014 —You have until October 16th, 2014 – exactly 120 days from today – to make your opinion known on a newly proposed EPA regulation that may increase electric rates $1,200/month for a family of four and kill 600,000 jobs. It’s called the Clean Power Plan.

The new proposal appeared as document 2014-13726 in the Federal Register today. That automatically triggers the start of a 120-day written comment period where stakeholders can provide public input before the proposal takes effect. EPA plans to implement the new regulation early next year.

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EPA Administrator Gina McCarthy announced the President’s Clean Power Plan on June 2nd before a supportive audience at EPA headquarters in Washington DC. It’s the most far reaching environmental regulation in history. Despite what McCarthy said, it will increase your electric bill.

If you are dissatisfied with Obamacare, you’ll hate the Clean Power Plan.

There are only four public hearings scheduled to make your feelings known:

Public Hearings: Clean Power Plan
Date Time Location
7/29/2014 9AM-8PM Atlanta, GA
7/29/2914 9AM-8PM Denver, CO
7/30/2014 9AM-8PM Washington DC
7/31/2014 9AM-8PM Pittsburg, PA


EPA has limited oral testimony to 5-minute segments spread over 36 hours, crammed into a three day whirlwind through four cities.

Why the urgency for citizen comments? Just for starters:

  • It affects every single American in big ways
  • The plan description, widely repeated in the press, is faulty

The Proposed Regulation

In her prepared remarks, EPA Administrator Gina McCarthy said the proposed regulation is a 30 percent reduction in CO2 emissions below 2005 levels by 2030. “30 in 2030” might make a catchy slogan for plan supporters in the upcoming 2014 elections.

However, that description does not agree with what one of McCarthy’s chief assistants, Janet McCabe, said in the official EPA blog on June 4th. She said percentage reductions aren’t set against a baseline year.

I hope this explanation makes clear that EPA is not setting goals based on percentage reductions against a baseline year.”
-Janet McCabe, EPA Acting Assistant Administrator for the Office of Air and Radiation, “Understanding State Goals under the Clean Power Plan“, 6/4/2014

As it turns out, both are incorrect. Individualized reductions are set against a baseline year, but the year is 2012, not 2005.

What is the big deal about 2012 instead of 2005?

Author/EIA data: C02 emissions were 12 percent lower in 2012 than in 2005
Author/EIA data: C02 emissions were 12 percent lower in 2012 than in 2005

If 2005 were the real baseline year, as Gina McCarthy said, we’d already be 12 percent of the way to meeting the goal. A logical person would look at the above graph and say, “Heck, we are almost half way there now. Should be easy to get the rest of the way”.

Unfortunately, it isn’t true. Just like Obamacare, the devil is in the details of the Clean Power Plan. For perspective, think, “If you like your health care plan, you can keep it!”.

The real proposed regulation

Hidden deep in the bowels of the plan is a innocent looking one-page spreadsheet showing each state’s target goal. It is just a list of four raw numbers for each state, but it is the heart and soul of the whole plan.

The last number lists the 2030 target amount of CO2 emissions expressed in pounds/megawatt-hour for each state. EPA goes into great, convoluted detail in the plan about how each state’s target reduction level was determined.

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The second to last number shows the state’s average emissions in the year 2012, also expressed in pounds/megawatt-hour. A check of EIA records shows the numbers and the year, 2012, are correct as listed. It’s not just a typo.

Add up the numbers and calculate the percent reductions for each state, which EPA does not do, and you find that the real proposal calls for a 31.4 percent reduction in CO2 emissions below 2012 levels (not 2005) by 2030.

The 31.4 percent is not the problem. The year 2012 is.

What it means is the 12 percent in reductions that have already happened since 2005 don’t count. That is the big deal about 2012!


This concludes a brief introduction to the Clean Power Plan. The worst is yet to come.

It’s the first installment in an investigative series on the EPA’s new Clean Power Plan. It barely scratches the surface of a draconian new regulation with an astronomical price tag that will only reduce U.S. overall CO2 emissions by about 11 percent.

The real plan buried in the proposed regulation includes 12 percent more CO2 reductions than the advertised plan. Compared to the advertised plan, the real plan calls for 43 percent reductions in CO2 emissions below 2005 levels.

Among other things, this series will realistically estimate the plan’s total costs and how it will affect ordinary Americans in the next few years, if implemented in its current form.

For example, calculations show the equivalent of somewhere between 227 to 454 of the existing 557 coal-fired electric power plants in 2012 will have to be retired and replaced to reduce CO2 by 614 million metric tons, as called for in the plan.

Is the plan worth it, as is, or are there better, cheaper ways to achieve the reduction goals? Nobody really knows.

That is why it is vitally important that as many people as possible study the 645-page monster regulation and make their discoveries known to the EPA and to their elected officials ASAP.

The clock is ticking. There are only 120 days to say something before it is too late to do anything about it.

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