Coal Communications Kit - EPA Regulations of Airborne Emissions
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EPA Regulations of Airborne Emissions

The Clean Power Plan (CPP) has been promoted by government officials as being a “Landmark action to protect public health, reduce energy bills for households and businesses, create American jobs, and bring clean power to communities across the country (Office of the Press Secretary of the White House, 2015).” But, when the CPP is analyzed on a closer level we begin to ask ourselves… are these results plausible? Before delving into this, a list of main points summarizing the CPP has been displayed below:

  • On August 3rd, 2015, Gina McCarthy released the final CPP. The CPP expressed the best system of emission reduction (BSER) in the form of two source-specific carbon dioxide emission rates for power plants – one performance rate for coal steam and oil steam plants, and one performance rate for natural gas plants (Sidley Austin LLP, 2015).
  • The U.S. Environmental Protection Agency (EPA) Greenhouse Gas Utility Regulations consists of two parts, which are as follows:
    1. Standards of Performance for Greenhouse Gas Emissions for New, Modified and   Reconstructed Sources
      • Clean Air Act (CAA) section 111 (b) establish standards for carbon dioxide emission rates for new and modified energy generating units (EGUs) (Sidley Austin LLP, 2015).
    2. Carbon Pollution Emission Guidelines for Existing Stationary Sources
      • Clean Air Act (CAA) section 111 (d) establishes requirements for each state for performance for carbon dioxide for existing fossil fuel fired EGUs (Sidley Austin LLP, 2015).
  • Overall, the national carbon dioxide (CO2) reduction target increased from 30 percent below 2005 levels by 2030 in the proposed rule, to 32 percent (Sidley Austin LLP, 2015).
  • The CAA incentivizes renewable energy and demand size energy efficiency. This rule discourages the use of natural gas as an alternative to meet the stringent 32 percent reduction target of 2030 (Sidley Austin LLP, 2015).
  • The rule is designed to promote zero carbon renewable energy and energy efficiency (Sidley Austin LLP, 2015).
  • Compliance begins in 2022, though EPA has instituted a new “Clean Energy Incentive Program” that rewards states with emissions credits for taking actions prior to 2022 (Sidley Austin LLP, 2015).
  • Individual state targets are significantly changed from the proposed rule. According to EPA, this change helps to “rebalance” state goals and make the rule more equitable (Sidley Austin LLP, 2015).
  • Compared to the proposed rule, 33 states have less stringent targets and 16 states have more stringent targets (see graphic below). However, it is important to compare final targets to baseline projections to understand and compare state compliance challenges. (Grant, 2015).

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The Clean Power Plan will cost 227,000 hardworking blue collar people their job by 2030 (Dayaratna, 2015). #CPPReality #SupportJobs

From a public health stand point, air pollutants under the CPP are regulated under three categories.

  1. Section 111 does not apply to air pollutants that are not regulated as a criteria pollutant under section 108, or as a hazardous air pollutant (HAP) under section 112.
  2. Hazardous air pollutants are chemicals that are known, or suspected, to cause cancer or other serious health effects, such as reproductive problems or birth defects, and that adversely affect the environment.
  3. Other criteria pollutants such as sulfur dioxide fall under section 108. Regulations under section 111 are separated into two parts: (b) applies only to air pollutions for which the existing source would be regulated under section 111 if it were a new source and (d) establishes emission guidelines for existing sources.

CO2 is not a criteria pollutant regulated under section 108, or a HAP under section 112. EPA classes CO2 under S.111 as a pollutant that may be harmful to public health or welfare (Environmental Protection Agency, 2015).

The focus for reducing carbon dioxide emissions is that burning coal and natural gas for energy emits CO2, which is thought to lead to global climate change. CO2 emissions are measured in gigatons (GT) and occur in nature as follows: plants 120 GT, oceans 90 GT, and human – from fossil fuel use – 9 GT. After it is emitted, CO2 is re-absorbed by oceans, forests, and other "carbon sinks" which naturally absorb excess CO2 from the atmosphere. “About 50 percent of the CO2 released from the burning of fossil fuels and other human activities has already been re-absorbed by the earth’s carbon sinks” (ProCon, 2015). Therefore, without clear scientific proof from the EPA that CO2 is actually known to harm people or the environment, a rule has been issued restricting it.

EPA claims that the Clean Power Plan will reduce energy bills for households and businesses, and create American jobs. As can be seen in the chart below, which shows a relative reference of where states fall in terms of progress meeting the CPP restrictions, some states will need to spend vastly more than others to meet the emission goals.

Cost of New Replacement Power Capacity Through 2030
Difference Between Proposed and Final Rate-based Goal

States that rely heavily on coal, in regions such as Wyoming, the Southeast, and the Midwest, are required to make the most stringent cuts. These states rely on coal to power their infrastructure. If the utilities in these states need to replace their current generation with new sources, the capital costs of doing so will flow directly to the ratepayer. In addition, if states wanted to retrofit older coal or natural gas boilers to be compliant with the rule, the CPP language makes it near impossible to do so.

Wholesale Electricity Price Increases by 2030
(Association, 2015)
Cumulative Wholesale Electricity Prices Attributable to CPP
(Association, 2015)

The CPP restricts CO2 emissions from natural gas and coal fired facilities as follows:

Generation Type

Section 111 (b) (NEW)

Section 111 (d) (Existing)

Coal fired power plant

1,400 pounds  CO2/MWh

1,305 pounds CO2/MWh

Natural gas combined cycle

1,000 pounds CO2/MWh.

771 pounds CO2/MWh

These restrictions show that existing coal and natural gas plants must output less CO2 than the newest technology available. CCS would be an option if it were proven on a commercial scale. However it has not been, and if it does get there it will be extremely costly for the utilities, and the ratepayers to construct (Allison, 2014).

In terms of American jobs, the CPP will have a significant negative impact on manufacturing and mining states. Workforces in states such as Alabama, Georgia, and Wisconsin are projected to see approximately a 4 to 6 percent decrease of total manufacturing jobs by year 2023 (Dayaratna, 2015). Across the entire United States, it is projected that 500,000 jobs will be lost in manufacturing due to the CPP (Dayaratna, 2015). This includes the elimination of more than 45 percent of coal-mining jobs, and a total income loss per person of $7,000 (Dayaratna, 2015). Economists predict that the new CPP regulations will create 273,000 jobs overall (IEC, 2015). Therefore, overall the CPP ends up being a bad deal for American workers as these projections indicate a net job loss of 227,000.

In terms of providing clean power, yes the CPP supports wind and solar projects, which may provide “clean power” while generating. However this does not take into account the carbon created when mining the rare earth metals for their production, or refining the steel used in their construction, or the spinning reserve power–typically fossil fuels–that is required to firm, or back up, renewable energy when the wind does not blow and the sun does not shine. Therefore, wind and solar cannot claim to be carbon free sources either.

The CPP may reduce CO2 emissions, but otherwise it appears benefits of the CPP listed by government officials are, at best, speculative. It is not known if the CPP will have any effect on public health. As the CPP will end up costing many families more on their utility bills, and is projected to result in net job losses around the country, overall impacts on health and well-being are likely to be profoundly negative.

EPA Regulations of Airborne Emissions: Facebook Post

EPA claims that the Clean Power Plan will reduce energy bills for households and businesses, and create American jobs. But, if you live in major coal powered state this will not be true, as costs for these new generating sources eventually are passed on to rate payers. Job growth? Try job loss. About 500,000 manufacturing jobs by the end of 2030 are expected to be eliminated due to the Clean Power Plan (Dayaratna, 2015).

EPA Regulations of Airborne Emissions: Elevator Speech

The Clean Power Plan’s (CPP) goal is to reduce CO2 emissions from point sources such as coal and gas-fired power plants by pushing states towards renewable sources of energy. By doing so, government officials claim that public health will improve, energy bills will be reduced, and American jobs will be created (Office of the Press Secretary of the White House, 2015). However, when analyzing the CPP, none of these desirable effects seem plausible. The Environmental Protection Agency (EPA) describes CO2 as a compound that may or may not cause harm to the environment or people, meaning that the EPA does not possess firm proof of any actual harm due to its presence (Environmental Protection Agency, 2015). In terms of energy bills, utilities will have to spend billions of dollars to construct wind and solar projects to replace gas and coal-fueled generators. Utilities are allowed to recoup costs associated with these projects from ratepayers, which will most likely correlate to an increase in electricity costs for them, not a decrease. Lastly, it is estimated that 500,000 manufacturing jobs will be lost due to the CPP, with only an increase of approximately 273,000 jobs from the bill (Dayaratna, 2015) (IEC, 2015) . This results in a net decrease of 227,000 jobs across the United States. The CPP is a step back for American society; both from an employment and economics stand point, without any concrete evidence of increased health benefits.