On June 18, 2014 the United States Environmental Protection Agency (EPA) published the “Carbon Pollution Emissions Guidelines for Existing Stationary Sources: Electric Utility Generating Units: Proposed Rule”, informally known as the Clean Power Plan (CPP). For more background, visit the EPA’s web link to the technical details of the plan: http://www2.epa.gov/carbon-pollution-standards/clean-power-plan-proposed-rule

IEER submitted these comments on December 1, 2014, to the United States Environmental Protection Agency for Docket EPA-HQ-OAR-2013-0602 on behalf of the authors, Arjun Makhijani, PhD, and M.V. Ramana, PhD, IEER, and Seth Shonkoff, MPH, PhD, Executive Director, PSE Healthy Energy and Elena Krieger, PhD, Director, Renewable Energy Program, PSE Healthy Energy. These comments are also being submitted by attorney Diane Curran as part of a larger set on behalf of a number of clients.

The comments were resubmitted, with corrections, to the EPA on December 8, 2014. Minor corrections made to numbers related to natural gas emissions and CO2eq costs – see Errata included in the comments.

Contents of IEER’s submitted comments

(download the full comments [PDF] here)

  1. Introduction
  2. Description of IEER and qualifications of Dr. Makhijani and Dr. Ramana
    1. Dr. Arjun Makhijani and IEER
    2. Dr. M.V. Ramana
  3. Importance of significantly reducing carbon emissions and long-term considerations
  4. Methodological issues raised by the proposed clean power plan
    1. Technical problems with the derivation of the target emission rates for the states
    2. Background on EPA’s Building Blocks
    3. Treatment of baseline year generation, future generation, and efficiency
      1. The EPA should use a consistent baseline year and use generation consistently for each year of emission target calculations
      2. The EPA approach to renewable energy (RE) and energy efficiency (EE) in the October Notice of Data Availability is an improvement over that published in the CPP
  5. EPA can and must set targets for 2030 carbon emissions reductions that are more stringent and lay the groundwork for subsequent long-term carbon reductions
    1. EPA’S Targets for Emission Reductions Are Too Low.
    2. EPA’s Proposed Methods for Achieving Carbon Reductions Are Not Justified and Are Not Consistent with BSER Criteria
      1. EPA has not taken adequate account of the problem of natural gas venting and its effect on carbon-equivalent emissions
      2. EPA has not justified reliance on nuclear power as BSER.
      3. EPA has not demonstrated that its proposed methods for achieving carbon reductions will be effective long-term.
    3. As IEER Shows in the IEER Climate Protection Scenario, Carbon Reductions that are Consistent with Climate Protection are Feasible and Cost-effective.
      1. IEER’s model is based on a consistent approach that addresses methodological issues in the CPP
      2. IEER’s Climate Protection Scenario would reduce carbon emissions by about 40 percent below 1990 levels
      3. IEER Climate Protection Scenario is necessary & technically feasible and cost effective
  6. Conclusions and Recommendations
  7. References and Errata