EPA Clean Power Plan Public Comment

EPA Clean Power Plan Public Comment

Denver 29 July 2014

Posted by Ed Leaver 1 August 2014

I was privileged to speak in-person in support of the United State’s Environmental Protection Agency’s Clean Power Plan July 29, 2014, in Denver. These are my brief remarks along with supporting notes, and links to EPA resources and directions for submitting public comments (deadline 16 October 2014).

Public Comment of Edward W. Leaver

Good morning. I am a physicist speaking as a private citizen. I wish to thank EPA for hosting these hearings, and unequivocally support EPA’s Clean Power Plan to reign in carbon dioxide emissions. The cause of limiting Global Warming is not lost.

  1. Yet “Global energy consumption will double by mid-century, regardless of what the United States does. Not from the 1 billion people already using vast amounts of electricity, or the 1 billion using modest amounts of electricity. But from the 1.6 billion people that do not have any access to electricity whatsoever, the 2.4 billion that have almost no access to electricity... and the 3 billion new people that will be born by mid-century who will need electricity.”
  2. Green house gas emissions too are a global problem. Limiting domestic emissions will be of no consequence if we continue to increase fossil fuel exports abroad. We continue to lease public coal from public lands. Yet we freely give much of it away to be burnt, not here but in Europe and Asia, thus encouraging our neighbors to neglect their own clean air responsibilities.
  3. Even domestically we have no long-term low-enough carbon plan to economically replace coal as a dispatchable and reliable power source. Numerous studies – including EPA’s – have shown Wind+Solar+Gas alone will not, by themselves and at reasonable cost, decrease power-sector carbon emissions to the near-zero level required by mid-century. And it’s a global problem. Coal is ubiquitous, easy to mine and transport, and fossil power plants are comparatively simple to build at reasonable cost. The global power problem is staggering, and coal is the simplest solution. If we – the United States – do not exert leadership and demonstrate and implement low-carbon power solutions that are globally applicable, the rest of the globe will continue to apply coal.

We can do better and we must do better. EPA’s Clean Power Plan represents a regulatory approach which, while a necessary and welcome first step, is hardly the last word.

Senator Michael Bennett has called for development of a Comprehensive National Energy Plan to take optimal advantage of all low-carbon energy sources. And yes, this most certainly does include safe, reliable, modern nuclear power. Germany has a National Energy Plan. Britain has one. France had one. We, the world’s second largest energy producer and source of green house gas, need a Comprehensive National Energy Plan as well. One that adds up. I ask we all support Senator Bennett’s efforts to formulate such a plan, and again support EPA’s Clean Power Plan as a critical step in that direction.

Thank you.

(End delivered remarks)

Supporting Notes Not Part of Public Comment

I will not repeat AGW arguments here: see Why Anthropogenic Global Warming for a concise review. For my other points:

  1. Future doubling of global energy consumption – see What is Our Energy Future? (James Conca 2012).
  2. From Is the U.S. Exporting Coal Pollution? (Keiran Cooke, March 2013).

    “A recent report from the UK’s Tyndall Centre for Climate Change Research looked at the growth of the shale gas industry in the United States and questioned whether it had contributed to a global drop in CO2 emissions... The answer was no: Tyndall’s calculations suggest that more than half of the emissions avoided in the U.S. power sector – through the switch from coal to gas – may have been exported as coal. “Without a meaningful cap on global carbon emissions, the exploitation of shale gas is likely to increase total emissions,” said the report. ”For this not to be the case, consumption of displaced fuels must be reduced globally and remain suppressed indefinitely. In effect, displaced coal must stay in the ground.”

  3. Nuclear is one technology with a chance of displacing coal for reliable base load generation. Three present and former EPA Administrators have come together to support an increase in nuclear energy to help meet our carbon reduction goals: present administrator Gina McCarthy, Carol Browner, who served under President Clinton, and Christine Todd Whitman, EPA Administrator under President George W. Bush:
    • Carol Browner, If You’re Concerned About Climate Change, You Should Support Nuclear Power (2014):

      “Multiple analyses of climate change by a variety of independent organizations, including National Academies of Science, Electric Power Research Institute, EPA and U.S. Energy Information Administration, show that reducing carbon emissions requires a portfolio of clean energy technologies, including nuclear energy. Many of these organizations agree that preserving existing nuclear energy plants is essential in successfully meeting carbon reduction goals. This is corroborated by the recent report by the United Nations’ Intergovernmental Panel on Climate Change, suggesting that nuclear energy could be a key source of low-carbon energy worldwide...”

    • Christine Todd Whitman, Nuclear Power Cuts Emissions (2014):

      “America’s commercial reactors are carbon-free and are also one of the most efficient and reliable producers of electricity... America’s decades-long leadership in nuclear energy means that every year, we prevent the emission of 570 million metric tons of carbon pollution, essentially the same amount of carbon emitted by almost all U.S. passenger cars... Unfortunately, due to several factors, four reactors shut down in 2013 and another is scheduled to shut down this year. Some of the contributing factors are market-distorting forces and a marketplace that has not fully valued low-carbon production and reliability. Basing long-term energy policies on short-term energy demands is a mistake. The loss of just five reactors will raise carbon emissions by more than 40 million tons per year. In light of the new regulations and the need to protect our environment for future generations, it behooves us to protect the only highly efficient and zero-emissions source of base load electricity we have.”

    • Gina McCarthy, EPA: Carbon rules could ensure nuclear power’s survival (2014):

      “There are a handful of nuclear facilities that because they are having trouble remaining competitive, haven’t yet looked at re-licensing (to extend their operating lives)... McCarthy acknowledged that EPA’s mandate to prop up the 6 percent of nuclear power that is threatened with closure wasn’t broken down by state. This may be inelegant, and commentsare welcome. While energy efficiency and renewable energy may certainly count toward carbon reduction goals and states ultimately will decide how to meet targets, McCarthy warned that if nuclear capacity goes away, “it’s a lot of carbon reduction that needs to be made up for a long period of time.”

    It is a lot of carbon. The four U.S. reactors shutdown in 2013 were Crystal River 3 (860 MWe), Kewaunee (560 MWe), and San Onofre 2 and 3 (2 GWe). Vermont Yankee (605 MWe) will close at end of 2014, for total loss of 4 GW essentially zero-carbon electric. Assuming 90% capacity factor and (somewhat high but believable) 1150 tonnes CO2e/GWh from coal, then we are emitting an additional 40 million tons CO2e each year just from loss of these five plants. Over the twenty years commonly granted by NRC for license renewal that’s 800 megatons CO2e. If forty additional years were possible (which we won’t know for a few more decades) the cumulative CO2 burden from loss of these plants increases to 1.6 gigatons. No wonder EPA is concerned! But nuclear alone is no panacea: we shall need considerable contributions from all low-carbon resources, and natural gas as well.

  4. Comprehensive National Energy Plan. In Limiting the Magnitude of Future Climate Change (2010) the U.S. National Research Council strongly advocates immediate deployment of new nuclear technologies as well as renewables, subsidy reform, and implementation of carbon taxes and/or cap-and-trade.
  5. Many economists believe a market approach to limiting green-house gas emissions is preferable to regulation. As one example, Citizen’s Climate Lobby has suggested an aggressive Fee and Dividend (F&D) proposal that would tax all carbon sources at point of extraction, and immediately return the proceeds to American households by monthly check or direct deposit. Independent economic analysis concludes the proposal will result in both modest job growth and increase in GDP over business as usual, largely but not solely on the basis of health benefits from reduced toxic emissions from fossil use, and not counting indirect benefits from green-house gas reduction which would amount to an impressive 50% by 2035:

    An alternative is Senator Bernie Sanders’ proposed S. 332 carbon tax, the Climate Protection Act of 2013, which would amend the Clean Air Act to require the EPA Administrator to impose: (1) a carbon pollution fee on any manufacturer, producer, or importer of a carbon polluting substance; and (2) a carbon equivalency fee on imports of carbon pollution-intensive goods. Then requires the Secretary of the Treasury to transfer 50% of the amounts received each fiscal year as a result of the carbon equivalency fee to the EPA Administrator and to the Secretary of Transportation (for specified purposes).

    S. 332 is more general than F&D, but not revenue neutral. Neither prevents Department of Energy from continuing its programs for research and development. That said, any Carbon Tax or Cap-and-Trade scheme will require an Act of Congress to implement, which seems unlikely at present. But urgent action is required: EPA’s Clean Power Plan is admirably flexible and represents a huge step in the right direction. At minimum it will serve as lightning rod for healthy and much-needed debate.

I stress the importance of nuclear power as few others – EPA excepted – seem willing. Cost is an overridingly important consideration in any energy transition. Though often beneficial, the costs and complexity associated with renewables-only solutions are frequently understated (see Introduction to Electric Power). We are all in this together. We must pool all our resources.

EPA Resources