Clean Power Plan: The clock is ticking

EPA Clean Power Plan: GHG emissions by energy sector. Electricity is 32 percent of the total

Austin, June 19, 2014 —You have until October 16th, 2014 – exactly 119 days from today – to make your opinion known on a newly proposed EPA regulation that may increase electric rates $1,200/month for a family of four and kill 600,000 jobs. It’s called the Clean Power Plan.

The new proposal appeared as document 2014-13726 in the Federal Register yesterday. That automatically triggers the start of a 120-day written comment period where stakeholders can provide public input before the proposal takes effect. EPA plans to implement the new regulation early next year.

EPA Administrator Gina McCarthy announced the President’s Clean Power Plan on June 2nd before a supportive audience at EPA headquarters in Washington DC. It’s the most far reaching environmental regulation in history. Despite what McCarthy said, it will increase your electric bill.

If you are dissatisfied with Obamacare, you’ll hate the Clean Power Plan.

There are only four public hearings scheduled to make your feelings known:

Public Hearings: Clean Power Plan
Date Time Location
7/29/2014 9AM-8PM Atlanta, GA
7/29/2914 9AM-8PM Denver, CO
7/30/2014 9AM-8PM Washington DC
7/31/2014 9AM-8PM Pittsburg, PA


EPA has limited oral testimony to 5-minute increments spread over 36 hours, crammed into a three day whirlwind through four cities.

Why the urgency for citizens to comment? Just for starters:

  • It affects every single American in big ways
  • The plan description, widely repeated in the press, is faulty

The Proposed Regulation

In her prepared remarks, Gina McCarthy said the proposed regulation is a 30 percent reduction in CO2 emissions below 2005 levels by 2030. “30 in 2030” might make a catchy slogan for plan supporters in the upcoming 2014 elections.

However, that description does not agree with what one of McCarthy’s chief assistants, Janet McCabe, said in the official EPA blog on June 4th. She said percentage reductions aren’t set against a baseline year.

I hope this explanation makes clear that EPA is not setting goals based on percentage reductions against a baseline year.
-Janet McCabe, EPA Acting Assistant Administrator for the Office of Air and Radiation, “Understanding State Goals under the Clean Power Plan“, 6/4/2014

As it turns out, both are incorrect. Individualized reductions are set against a baseline year, but the year is 2012, not 2005.

What is the big deal about 2012 instead of 2005?

Author/EIA data: C02 emissions were 12 percent lower in 2012 than in 2005

If 2005 were the real baseline year, as Gina McCarthy said, we’d already be 12 percent of the way to meeting the goal. A logical person would look at the above graph and say, “Heck, we are almost half way there now. Should be easy to get the rest of the way”.

Unfortunately, it isn’t true. Just like Obamacare, the devil is in the details of the Clean Power Plan. For perspective, think, “If you like your health care plan, you can keep it!”

The real proposed regulation

Hidden deep in the bowels of the plan is a innocent looking one-page spreadsheet showing each state’s target goal. It is just a list of four raw numbers for each state, but it is the heart and soul of the whole plan.

The last number lists the 2030 target amount of CO2 emissions expressed in pounds/megawatt-hour for each state. EPA goes into great, convoluted detail in the plan about how each state’s target reduction level was determined.

The second to last number shows the state’s average emissions in the year 2012, also expressed in pounds/megawatt-hour. A check of EIA records shows the numbers and the year, 2012, are correct as listed. It’s not just a typo.

Add up the numbers and calculate the percent reductions for each state, which EPA does not do, and you find that the real proposal calls for a 31.4 percent reduction in CO2 emissions below 2012 levels (not 2005) by 2030. It works out to 614 million metric tonnes.

The higher 31.4 percent target reduction goal is not the problem, the year 2012 is.

What it means is the 12 percent in reductions that have already happened since 2005 don’t count. That is the big deal about 2012!


This concludes a brief introduction to the Clean Power Plan. The worst is yet to come.

It’s the first installment in an investigative series on the EPA’s new Clean Power Plan. It barely scratches the surface of a draconian new regulation with an astronomical price tag that only reduces U.S. overall CO2 emissions by about 11 percent.

The real plan buried in the proposed regulation includes 12 percent more CO2 reductions than the advertised plan. Compared to the advertised plan, the real plan calls for 43 percent reductions in CO2 emissions below 2005 levels.

Among other things, this series will investigate the advertised health benefits and how that relates to carbon dioxide. It will realistically estimate the plan’s total costs and how that will affect ordinary Americans in the next few years, if implemented in its current form.

For example, calculations show the equivalent of somewhere between 227 to 454 of the existing 557 coal-fired electric power plants in 2012 will have to be retired and replaced to reduce CO2 by 614 million metric tonnes, as called for in the plan.

Is the plan worth it, as is, or are there better, cheaper ways to achieve the reduction goals? Nobody really knows.

That is why it is vitally important that as many people as possible study the 645-page monster regulation and make their discoveries known to the EPA and to their elected officials ASAP.

The clock is ticking. There are only 119 days to speak before it is too late to do anything about it.


About azleader

Learning to see life more clearly... one image at a time!

Posted on Jun 19, 2014, in Clean Power Plan, Climate, economics, Economy, Energy, energy policy, environment, EPA, Government, news, Opinion, Politics, science, technology. Bookmark the permalink. 2 Comments.

  1. Informative post. The EPA is simply nuts, and I hope the states rebel.

    This does bother me a bit, “Is the plan worth it, as is, or are there better, cheaper ways to achieve the reduction goals?

    Why not question the need for the goals? The observational evidence that they are not needed is well documented in the NIPCC report.

    • The Clean Power Plan does have a built-in, hidden fossil “out”. That out is NGCC, which just happens to be the cheapest electric energy source there is and it meets the proposed standard without any changes. In fact, EPA doesn’t even have any suggested improvements for NGCC, let alone mandated ones.

      Electric utilities can keep doing what they’ve been doing since 2007 and still be in compliance with the new plan.

      That being said, the proposed state 30% by 2030 CO2 reduction standard is another story. In some states it might require replacement of some natural gas plants with zero-emission alternatives and that would be very expensive.

      The affected states will be the ones that already get most of their electricity from natural gas. I haven’t done a full analysis to determine how big a problem will be yet.

      The most expensive problem faced by electric power isn’t the EPA, it’s state renewable portfolio standards. That is where a state mandates a certain percentage of electricity comes from renewable sources. Those will be the real cost killers.

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