Republicans are vowing to try to derail the Obama administration’s proposed rules for reducing carbon emissions for existing power plants, but on the last day for public comment on the Environmental Protection Agency plan, the organizations that support it weren’t giving any ground – in fact, they offered analysis and argument pressing the EPA to go further.
The EPA said on Monday that it had received more than 1.6 million comments on the plan [PDF]. Most weren’t accompanied by a press release, but such was the case for the Sierra Club (“Sierra Club Comments Support Clean Power Plan, Urge Stronger Action 0n Carbon Pollution”), Natural Resources Defense Council (“NRDC Analysis Shows EPA Can Achieve Deeper Power Plant Carbon Pollution Cuts by Adopting More Clean Energy”) andPublic Citizen (“EPA Greenhouse Gas Rule Should Be Stronger, More Consumer-Friendly”).
One common theme among the green heavyweights was that the EPA was overestimating the cost of renewable energy and underestimating the impact of energy efficiency initiatives, and was thus setting the bar too low for their adoption.
“The cost of clean energy is falling dramatically and the June plan was not based on current costs,” NRDC policy director David Doniger said in a teleconference with media. Doniger said updating the baseline costs, combined with other tweaks the group outlined, would deliver a 44 percent carbon reduction by 2030 while also reducing other pollutants.
The EPA plan, unveiled in June, gives states, or states working together, fair leeway to reach unique targets that together would cut carbon emissions from U.S. power plants by 30 percent by 2030 from their 2005 level.
In its comments, NRDC asserted that current data “show that wind and solar costs are each approximately 45 percent lower than EPA assumed in its analysis.”
According to U.S. research released in September, “The price of electricity sold to utilities under long term contracts from large-scale solar power projects has fallen by more than 70 percent since 2008, to just $50 per megawatt-hour on average within a sample of contracts signed in 2013 or 2014 and concentrated among projects located in the southwestern United States.”
On wind, the investment bank Lazard recently said the cost of producing wind energy fell by nearly 60 percent between 2008 and 2013.
So while climate hawks praise President Barack Obama for the Clean Power Plan, as they have from the moment it was announced, the sense that it is less ambitious than it could be has grown, particularly with respect to bringing new renewables onboard. Not counting big hydro, last year renewable sources provided around 6 percent of U.S. electricity generation, according to the government; the Clean Power Plan as originally written would push that proportion to just 7 percent by 2020, and then 12 percent by 2030.
Raising a point highlighted by the Union of Concerned Scientists in a report issued in October, the Sierra Club said one big reason EPA’s renewable energy expectations were so low was because it was using existing renewable portfolio standards to determine the renewable energy potential for states in the different regions of the country.
“The primary approach assumes that an average RPS target represents a reliable RE potential for states in that region, when, in fact, this target merely reflects the political will that states in each region have thus far exerted toward RE development,” the Sierra Club wrote. “Hence, a region such as the Southeast has the lowest average of all regions (based on the RPS of just one state), even though it has an above-average technical potential for renewable generation. Furthermore, the regional RPS averages generate RE targets for many states under Block 3 that actually fall below the legally-enforceable RPS goals in those states.”
The Sierra Club endorsed a UCS recommendation to base future renewable energy use on recent growth rates. Doing this – and assuming renewable energy growth between 2013 and 2017, as the plan currently does not – would increase renewable energy’s share of US electrical generation to 23 percent in 2030, instead of the EPA’s 12 percent, UCS has said.
