Proposed Clean Power Plan Research Articles

Renewable energy policy formulation for electricity generation in the United States

While the United States (U.S.) has state-level policies that support renewable energy development, the country does not currently have any federal-level renewable energy policies that are formulated to include national renewable electricity targets. U.S. renewable energy policies include state-level renewable energy portfolio standards (RPSes), which stipulate the minimum renewable electricity that local utilities should provide, the proposed Clean Power Plan, which sets state-by-state targets for emission reduction by 2030, and the Clean Energy Act of 2007, which includes provisions that aim to increase energy efficiency and renewable fuel production. As the RPSes are established at a state level, they have varying renewable energy targets and related timelines that cannot readily be translated into federal law. This study uses an Analytic Hierarchy Process (AHP) to propose national targets for renewable electricity, by first reviewing electrical energy potentials based on the geographic areas defined by the U.S. Census Bureau regions, and then establishing regional and national renewable electricity goals. The goals are based on a quadruple-bottom-line approach (4P) considering technical or “progress”, social or “people”, economical or “profits” and environmental or “planet” factors. The study proposes a model for selecting mandates versus incentives for the renewable electricity alternatives using a benefit/cost ratio computed from the AHP analysis.

White certificate trading: A dying concept or just making its debut? Part III: Future market potential in the U.S.

Challenges to white certificate markets are formidable, but they are not insurmountable, as demonstrated by successful white certificate schemes worldwide. This article discusses the future potential for these certificates in the U.S. A promising development that could affect implementation of a white certificate-type instrument is the inclusion of an instrument called an emission rate credit in the proposed Clean Power Plan. Other potential drivers include energy efficiency resource standards and voluntary markets.

In the eye of the storm: Exploring how Montana and Ohio are framing the debate about the Clean Power Plan rule

ABSTRACTRulemaking is an integral component of environmental policy at both the federal and state level; however, the role states play in implementing federal rules is often overlooked. States frequently have to devise their own plans for implementation—subject of course to federal oversight—and this is the case with the new Clean Power Plan rule proposed in 2014 and finalized in 2015. This exploratory research examines the newspaper coverage of proposed Clean Power Plan rule in Montana and Ohio in an effort to surmise how these two states will proceed with implementation. To investigate these responses to the proposed rule, we utilize Nisbet’s (2010) framework for science-policy debates in the media to conduct a content analysis and identify the driving frames from the ten leading newspapers in each state. Our analysis concludes that although the leading frame in both states is economic development and competitiveness, Montana seeks a pathway forward, while Ohio wants a two-year freeze on renewable energ...

Civil Society in an Age of Environmental Accountability: How Local Environmental Nongovernmental Organizations Reduce U.S. Power Plants’ Carbon Dioxide Emissions

Institutional scholars have argued that in the absence of legislation on the issue of climate change, nongovernmental organizations (NGOs) can help reduce the amount of anthropogenic greenhouse gases being emitted to the environment by disseminating environmental norms. Consistent with this reasoning, they have shown that from the middle of the last century up through the mid‐1990s, nations with more memberships inNGOs have tended to have lower carbon dioxide (CO2) emissions in the aggregate. Doubts remain, however, about whetherNGOs have reduced emissions in the time since and at the level of individual power plants where the lion's share of carbon pollution is emitted. Using plant‐specific information onCO2emissions recently collected by the Environmental Protection Agency (EPA) under its Greenhouse Gas Reporting Program, we investigate the effects of local environmentalNGOs (ENGOs) on plants’ environmental performance. Consistent with our expectations, we find that localENGOs not only directly reduce plants’ emissions but indirectly do so by enhancing the effectiveness of subnational climate policies that encourage energy efficiency. We discuss the implications of our findings for research on the decoupling of normative systems, social movements, environmental sociology, and theEPA's proposed Clean Power Plan.

Variation in outcomes and leakage potential across Clean Power Plan compliance designs

This paper presents results from a “modeler's choice” suite of runs that model the US Environmental Protection Agency's proposed Clean Power Plan (CPP) regulating carbon dioxide emissions from existing power plants under Section 111d of the Clean Air Act more closely than does the core EMF 31 Technology Performance Standard (TPS) case. While the TPS case imposed a national emissions rate standard for the power sector, the CPP imposes its budgets at the state level and provides states a great deal of flexibility in designing their implementation approaches. States may convert their CPP rate targets to a mass basis, and they may join with other states in multi-state trading plans. Under the proposed rule, EPA also left open the question of how new gas units were to be treated under the CPP. This design flexibility leads to a range of possible outcomes when it comes to the impacts of the proposed CPP on emissions, policy costs, electricity generation patterns, and gas markets. We analyzed 40 CPP scenarios in the Framework for Analysis of Climate-Energy-Technology Systems (FACETS), permuting these three design dimensions along with energy efficiency and low shale resource scenarios.Many designs have significantly higher emissions than EPA's original June 2014 design, while others deliver greater emissions reductions. In particular, the EMF TPS is closest to one of the more stringent possible designs. We observed substantial potential for emissions leakage when generation is able to move from covered to uncovered sources or from lower to higher rate states. Movement of generation is stimulated by the very different incentives that are set up across states by the differences in state rates. We discuss the features in each design that drive emissions impacts along with measures that can be taken to mitigate leakage risks. Since the EMF 31 study was completed, EPA has released the final CPP rule, which differs from the proposed rule in many important respects. We discuss the impact of those changes on the leakage potential observed here.Policy impacts on the gas market are found to be highly sensitive to the levels of energy efficiency (EE) achieved. Without EE, the CPP boosts gas production and increases prices by stimulating a shift from coal to gas. However, when the EE levels projected by EPA are achieved as part of state compliance approaches, gas production and price fall below no-policy levels by the mid-2020s.

Inconsistencies in Risk Analyses for Ambient Air Pollutant Regulations.

This article describes inconsistencies between health risk analyses that the U.S. Environmental Protection Agency (EPA) uses to support its decisions on primary National Ambient Air Quality Standards (NAAQS), and in the associated Regulatory Impact Analyses (RIAs) that accompany each NAAQS rulemaking. Quantitative risk estimates are prepared during the NAAQS-setting deliberations using inputs derived from statistical associations between measured pollutant concentrations and health effects. The resulting risk estimates are not directly used to set a NAAQS, but incorporated into a broader evidence-based rationale for the standard that is intended to demonstrate conformity with the statutory requirement that primary NAAQS protect the public health with a margin of safety. In a separate process, EPA staff rely on the same risk calculations to prepare estimates of the benefits of the rule that are reported in its RIA for the standard. Although NAAQS rules and their RIAs are released simultaneously, the rationales used to set the NAAQS have become inconsistent with their RIAs' estimates of benefits, with very large fractions of RIAs' risk-reduction estimates being attributed to populations living in areas that will already be attaining the respective NAAQS. This article explains the source of this inconsistency and provides a quantitative example based on the 2012 revision of the fine particulate matter (PM2.5 ) primary NAAQS. This article also demonstrates how this inconsistency is amplified when criteria pollutant co-benefits are calculated in RIAs for non-NAAQS rules, using quantitative examples from the 2011 Mercury and Air Toxics Standards and the currently proposed Clean Power Plan.

Estimating customer electricity and fuel savings from projects installed by the US ESCO industry

The US energy service company (ESCO) industry has a well-established track record of delivering substantial energy and dollar savings in the public and institutional facilities sector, typically through the use of energy savings performance contracts (ESPC). The ESCO industry has the opportunity to play an important role in achieving demand-side energy efficiency under the US Environmental Protection Agency’s (EPA) proposed Clean Power Plan. The EPA considered demand-side energy efficiency as a compliance strategy for proposed greenhouse gas (GHG) emissions standards under section 111 (d) of the Clean Air Act. To date, there has been little or no research in the public domain to estimate electricity or fuel savings for the entire US ESCO industry. Estimating these savings levels is a foundational step in order to determine total avoided GHG emissions from demand-side energy efficiency measures installed by US ESCOs. We find that on average, 66 % of total energy savings are in the form of electricity, but that in more comprehensive projects, almost 50 % of savings are produced from fuel resources. Overall, we estimate that active US ESCO industry projects generated about 34 TWh of electricity savings in 2012. About 15 TWh of these electricity savings were for municipal, local, and state government facilities; universities/colleges; K-12 schools; and healthcare (MUSH) facilities customers who did not rely on utility customer-funded energy efficiency programs. We extend the electricity analysis to estimate total energy savings and find that the US ESCO industry saved ∼224 million MMBtu in 2012 or ∼1 % of the total US commercial building energy consumption.

Considering the Role of Solar Generation under Rate-Based Targets in the EPA's Proposed Clean Power Plan

An analysis of the impact of solar generation under the Environmental Protection Agency's proposed Clean Power Plan using the Renewable Energy Deployment System finds that the proposed CPP results in increased solar generation relative to a no-CPP scenario and that the proposed rule produces fewer changes in the overall 2030 generation mix when future solar costs are lower.

Head Start: Most States Already on Track to Meet Targets in Proposed Clean Power Plan

Most states are already making progress toward cutting carbon emissions from power plants by shifting from coal-fired power to cleaner generation sources like renewable energy, energy efficiency and natural gas. As a result of recent decisions and state laws that predate the proposed Clean Power Plan, 31 states have already made commitments that would put them more than halfway toward meeting the 2020 benchmarks set out by EPA, and 14 of those states are already on track to meet or exceed them.

Is the EPA's Clean Power Plan Legal? Lawyers and Law Professors Disagree

A poll of 130 environmental attorneys and law professors from around the country revealed deep division on the issue of whether the Environmental Protection Agency's proposed Clean Power Plan is legal. About 80 percent of environmental law professors polled believe the Plan is legal, compared to only 27 percent of private environmental attorneys who responded.

Putting a Carbon Charge on Federal Coal: Legal and Economic Issues

US policy to limit greenhouse gas emissions is currently driven, in part, by the US Environmental Protection Agency’s proposed Clean Power Plan, which seeks a drop in carbon dioxide (CO2) emissions from fossil-fueled power plants — a “downstream” approach to regulation. Here, we consider an alternative, or possibly complementary, regulatory perspective: What is the legal and economic feasibility of imposing an “upstream” CO2 charge on coal production at its extraction site? Specifically, our focus is on leased coal from federal lands managed by the Bureau of Land Management (BLM). Such a carbon charge is designed, in principle, to embody the cumulative “lifecycle” externalities from coal mining to combustion (or other “downstream” utilization). Our legal analysis concludes that BLM has the statutory and regulatory authority to impose such a charge and that it would be best to add it to the royalty rate. But a large fee that would dramatically reduce revenues could invite judicial concern. The economic case is weaker than the legal case because production on state, private, and tribal lands (60 percent of total production) would not be subject to the charge and so could ramp up in response to the economic disadvantage the charge would cause for coal on federal lands, among other reasons. Best would be a comprehensive set of charges on royalties for all fossil fuels, irrespective of ownership.

A Primer on Comprehensive Policy Options for States to Comply with the Clean Power Plan

The US Environmental Protection Agency (EPA) has proposed regulations to reduce emissions of carbon dioxide (CO2) from existing fossil electricity generators in its proposed Clean Power Plan rule under section 111(d) of the Clean Air Act. The proposal is based on the best system of emissions reductions (BSER) and calls for states to develop plans to achieve reductions that are demonstrated to be equivalent to those attained by the application of BSER to each state. Policy options from which states may choose are not restricted; the BSER and state plans are distinct from one another. This primer describes the different types of incentive-based comprehensive policies that states could adopt and how policy design features can address particular objectives including overall cost-effectiveness, distributional consequences for electricity consumers and producers, administrative costs, and emissions of other pollutants. We also elucidate some trade-offs that state policymakers will face as they develop their plans for Clean Power Plan compliance.

State Cooperation Under the EPA's Proposed Clean Power Plan

Under the EPA's 111(d) rule, states can choose to comply individually or in cooperation. States can also choose to comply with a rate-based standard, which limits the average emissions rate of affected electricity generating units (EGUs), or a mass-based standard, which limits the mass of CO2 emitted by affected EGUs. Modeling the economic effects of these decisions suggests that compliance is likely to increase electricity costs, significantly increase net revenues for natural gas combined-cycle units and reduce net revenues for coal units.

Carbon Reduction Credit Program: A State Compliance Tool for EPA's Clean Power Plan Proposal

A credit-based CO2 emission rate reduction program for existing power plants can provide an easy-to-administer system for state policymakers and regulators to comply with the EPA's proposed Clean Power Plan. The program developed by the authors is flexible, technology-neutral, market-based, and designed so that state programs can later merge into multistate efforts, if desired.

A sustainable “building block”?: The paradoxical effects of thermal efficiency on U.S. power plants’ CO2 emissions

Under its recently proposed Clean Power Plan, the U.S. Environmental Protection Agency (EPA) gives states several “building blocks” to choose from to reduce their power plants’ CO2 emissions, including improving plants’ heat rate efficiency. However, skeptics suggest that precisely because efficiency enhances electrical output, it may reduce power plants’ emission rates but increase their emission levels. Using the EPA’s new Greenhouse Gas Reporting Program (GHGRP) data, this paper conducts the first analysis of the effect of thermal efficiency on the rate and level at which individual power plants emit carbon dioxide. Consistent with the arguments of skeptics, we find that while efficiency lowers CO2 emission rates, it actually increases CO2 emission levels. In suggesting to states that improving efficiency is one of the best systems of emission reductions, therefore, the EPA needs to consider whether more efficient plants are subject to such “rebound effects.”

The Clean Power Plan: Environmental Protector or Job Killer?

It is an interesting debate when two societal principles so integral to our long-term survival seem to come to a head. The Clean Power Plan, a new proposed rule by the EPA to reduce carbon emissions, appears to have sparked just such a battle. A clash seemingly between goals of environmental protection and protection of existing individual jobs is sure to garner public attention. However, this debate is less about jobs versus the environment and more about a shift in jobs from more traditional energy sectors to newer, less established sectors. This article explores the goals of the Clean Power Plan and how proponents and opponents alike frame the issue, especially in Pennsylvania, which is at the center of the changing energy landscape in the United States. President Richard Nixon signed the Clean Air Act into law on December 31, 1970. Many Federal environmental acts were signed into law in the 1970’s as a result of growing citizen concern for the environment. The Clean Air Act authorized EPA to enact federal regulations and employ enforcement mechanisms that would control air emissions from both stationary and mobile sources. The Clean Air Act’s main purpose has always been protecting the environment, although the cost of compliance and the impact of regulations on American industry were considered by Congress in conjunction with enactment of the Clean Air Act and its amendments. Additionally, any proposed rules, changes, or enforcement mechanisms are required to do the same. This article also addresses those impacts in the context of the recently proposed Clean Power Plan. The science community’s knowledge about humans’ impact on our climate has changed vastly since 1970 when we knew very little about the future of the world climate and were only beginning to realize that carbon dioxide emissions cause our planet to warm. In addition, coverage of this concept has also increased. These climate change stories have gone from being hidden in the back of technical journals to at the forefront of our mainstream media. In response to increasing concern about the current state of our environment and growing scientific consensus about global climate change, the EPA, on June 18, 2014, proposed a new rule establishing emissions guidelines for states to follow as they develop plans to address greenhouse gas emissions from fossil fuel electric generating units. This rule would mandate a thirty percent cut in carbon dioxide emissions from 2005 levels by the year 2030. This plan would develop state-specific goals for carbon dioxide emissions from power-related sources and continue progress already underway in reducing carbon dioxide emissions from fossil fuel-fired power plants.

Agricultural Energy Use and the Proposed Clean Power Plan

Agricultural Energy Use and the Proposed Clean Power Plan

U.S. Clean Power Plan Provides Opportunity for Significant Cuts in State Budget Deficits

The 2014 mid-term election that put Republicans in control of Congress reduced any chance of federal legislative action to limit greenhouse gases such as carbon dioxide from electric power plants. However, the executive branch already has authority from the U.S. Supreme Court to limit emissions under the Clean Air Act. In June 2014, the Obama Administration issued its proposed Clean Power Plan, which sets a specific limit on emissions for each state and then allows each state to decide how to meet its target. Comments are invited on this plan, and President Obama can modify the executive order before it is issued in June of 2015. The U.S. Clean Power Plan uses a formula to determine the target for each state, expressed as a maximum emission rate per unit of electricity, but it provides states with exibility regarding how to meet that target. It even allows states to convert that emission rate target to an absolute quantity of emissions and then to sell permits for that many tons of carbon dioxide. Any state that chooses to comply with the federal mandate by selling permits can collect revenue for the state, and this revenue can be used for additional spending, to cut other taxes, or to reduce the projected budget deficit. Indeed, many states since the Great Recession are still facing major deficit projections. This federal mandate provides an opportunity for states like Illinois to address some significant budget problems. In Illinois, for example, projections of the deficit under current law increase from $1 billion in FY2014 to $14 billion in FY2025. Our purpose here is to calculate the fraction of several states’ projected future deficits that can be offset by collecting their own permit revenue.