In preparing for this talk, I tried to step back from the specifics of the Environmental Protection Agency's (EPA) proposed carbon rule for existing power plants and look at the broader discussion surrounding the various elements we're having.
The EPA's proposal suggests we can meet our targets with a combination of cost-effective measures collectively known as the "best system of emission reductions," including the following:
- Heat Rate Improvement
- Redispatch of Coal To Natural Gas Combined Cycle
- Preserving Nuclear Generation
- Increasing Renewable Energy
- Improving Energy Efficiency
When you take a step back from the specifics, you will surely notice that, even though our goals are achievable, the EPA proposal is generating a good deal of opposition and controversy. You may also notice that much of the controversy seems to be focused on "issues" that are not as significant while ignoring important questions that we should be asking. The proposal to redispatch coal generation for natural gas combined cycle (NGCC) is an example.
Since redispatch implies that existing coal plants will lower production or shut down, it is not surprising that the PA Coal Alliance and others in the industry are very vocal about this issue. The reality of the situation, however, is that enough coal-fired power plants have already retired for economic reasons that we are on track to exceed the EPA's goals with no further plant retirements. With no real issue there, much of the argument turns to manufactured issues.
For example, the Pennsylvania Department of Environmental Protection (DEP) has recommended to EPA that things such as improvements in household energy efficiency should only be creditable if they are "coupled with the replacement or retirement of an existing source or facility" -- a move which would massively undercut otherwise creditable measures that will more than pay for themselves. EPA isn't going to agree with DEP but if forced to adopt this interpretation, it would need to revise its proposal. This would mean some combination of replacing energy efficiency with less cost-effective measures and/or revising statewide targets to make sure the plan continues to be achievable.
That is a bad idea, but not by itself a manufactured issue. It becomes one when DEP representatives say publicly that the EPA plan will result in 70 percent of our 2012 coal-fired power plants shutting down. This isn't the EPA's plan. In fact, this would only be true if EPA accepted DEP's own plan and ignored all other creditable measures, then compounded the problem by leaving the targets exactly as they are. Even if EPA wanted to do such a thing, the requirements of the Clean Air Act would prevent it. Old coal plants are having an increasingly hard time competing in an open market with cheaper sources of energy, so it won't surprise anyone if additional plants happen to retire in the coming decades, but we shouldn't confuse this with the results of EPA's plan.
While DEP has been spending time calculating unrealistic scenarios and debating what would happen if they came true, the real problem with relying on natural gas isn't getting the attention it deserves: That problem is methane leakage. Since methane is up to 86 times as harmful as other forms of carbon pollution in the first 20 years after its release, it is essential that leakage be controlled if we hope to see climate benefits as we move from coal generation to gas. While some improvements have been made in recent years, we are still a long way from having a detailed accounting of our actual leakage rates and a comprehensive program that will control that leakage.
DEP recently held a listening session on its plan. A number of people at that session echoed this very point. If DEP is listening, it's time for them to act and get serious about methane leakage.
Rob Altenburg is senior energy analyst for PennFuture and is based in Harrisburg. He tweets @RobAltenburg.