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Untapped Potential

Clean Power Plan Leaves Carbon Reductions on the Table

The Clean Power Plan (CPP), the Obama administration’s legacy-shaping effort to reduce carbon emissions from existing power plants, marked a turning point in the nation’s effort to combat climate change. But an October 2016 analysis of the nitty gritty of the methodology undergirding the Plan by CPR Member Scholars Alice Kaswan and Kirsten Engel identifies a large gap between the reductions the Environmental Protection Agency (EPA) requires and the achievable reduction opportunities the agency identified.

Because EPA's data reveal that greater reductions from the power sector are available, the authors contend that more work remains to be done to take advantage of the opportunities EPA did not incorporate into the final rule’s requirements.

"The Clean Power Plan is an important achievement, and EPA deserves great credit for using existing authority under the Clean Air Act to attack greenhouse gas emissions," Kaswan said in releasing the paper. "But it’s a first step, not a final step. Whether it’s by legislation, interstate compacts, or regulation, there’s a lot more work to be done. But the good news is that EPA’s data reveal that significant reductions beyond those contemplated by the Clean Power Plan are readily achievable."

In Untapped Potential: The Carbon Reductions Left Out of EPA’s Clean Power Plan, Kaswan and Engel explore the implications of EPA's decision to establish nationwide performance rates for coal and natural gas plants, rather than using more stringent regionally tailored rates. In developing the CPP, EPA assessed achievable reductions by region, consistent with the Western, Eastern, and Texas interconnections that make up the nation’s power grid. But by subsequently settling for the least stringent eastern regional rates as the nationwide performance rates, the agency ignored the greater reduction opportunities it had identified in the western states and Texas.

The result is that the Plan allows some coal-dependent western states to emit as much as three-and-a-half times as much carbon dioxide as would have been allowed had EPA applied the more stringent western region rate. That, in turn, means that the nation’s power plants will pump almost 400 million tons of carbon into the atmosphere per year beyond the levels EPA concluded were achievable based upon analyses of regional reduction opportunities.

"The truth is that the western states and Texas got a good deal under the Clean Power Plan," said Engel. "EPA determined that the western grid offered extensive opportunities to shift to natural gas and develop cost-effective renewables, but the agency did not incorporate these opportunities into its requirements for the western states."  Kaswan observes that "even if potential legal and political challenges prevented EPA from applying more stringent regional rates, EPA’s data show us untapped potential that can inform our continued climate policy agenda."

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