The Environmental Protection Agency recently issued a proposed plan for greenhouse gas mitigation: the electricity sector must cut greenhouse gas emissions by 30 percent by 2030. The rules are set on a state-by-state basis.
I am in favor of cutting carbon emissions, but the EPA plan is arbitrary, ineffective, and political. The abatement standards are plain backwards: states that already have a clean-energy mix have to do a higher percent of abatement than states that burn large amounts of coal.
EPA's criteria for reduction goals are, frankly, opaque, including complex “building blocks” for reduction. To decide on the level of reduction required, the EPA looked at various issues, such as coal plants that might be already slated for retirement, and whether a state has natural gas available.
Per kilowatt hour of electricity produced, burning coal produces twice the carbon dioxide as burning natural gas. Logically, the EPA would require greater cutbacks in coal-burning states.
That did not happen.
For example, West Virginia generates 90 percent of its electricity from coal - and it must cut its carbon dioxide emissions by 19 percent.
In contrast, New York state has a pretty clean energy mix and, according to state profiles compiled by the U.S. Energy Information Administration, gets less than 10 percent of its electricity from burning coal - and it must cut its carbon emissions by 44 percent.
With this sort of regulation, it is no surprise that New Hampshire, which gets less than 10 percent of its electricity from coal, must cut carbon emissions by 46 percent.
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Vermont, on the other hand, is a poster child for a low-carbon state. Vermont and the District of Columbia use very little fossil fuel to make electricity, so they are the only two states (well, state and district) that don't have to submit a plan for carbon abatement in the electricity sector.
However, more than 70 percent of the electricity generated within Vermont comes from Vermont Yankee, a very low-carbon electricity supplier. When Vermont Yankee shuts down at the end of the year, Vermont will be importing energy from states with more carbon-heavy profiles.
Will it cease to be a shining example of a low-carbon state?
No. According to the EPA, Vermont will still be a low-carbon state as long as it doesn't generate high-carbon electricity in state.
EPA regulates carbon according to power actually generated within the state, not by power purchase contracts. If other states are burning more fossil fuels to supply Vermont, the carbon mitigation rules will be their problem, not Vermont's problem. Vermont will have exported any possible compliance problems.
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That brings us to New Hampshire, which has to cut back 46 percent of its carbon emissions. With more than half of its electricity coming from nuclear and less than 10 percent from coal, cutting back to that degree might be hard.
However, the state is in the Regional Greenhouse Gas Initiative (RGGI) with Vermont and other states. New Hampshire is already cutting back its carbon emissions to meet RGGI requirements, and it hopes these cuts will be enough to meet the EPA requirements also.
In case New Hampshire's RGGI cutbacks are not enough, a Concord Monitor story reported, the state is looking at whether the EPA emission caps could be set as a combined target for all the RGGI states, thereby possibly involving Vermont in the cutbacks, in a manner that has yet to be determined.
However New Hampshire meets its requirements, it won't have to do so very quickly. Starting now, there's a one-year period for public comment on the EPA plan, followed by another year (or more) for the states to design their mitigation plans.
According to a Bloomberg New Energy Finance white paper, state plans are due by June 2017 and multi-state plans are due by 2018. It sounds as if New Hampshire might choose to participate in a multi-state plan. In such a scenario, New Hampshire's choices might also affect Vermont's status. Maybe.
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The whole thing is unreasonably complicated. It is no wonder that many commentators expect a raft of lawsuits.
You can also think satire: The Onion (a humor website) describes the situation with this headline: “New EPA Regulations Would Force Power Plants to Find 30% More Loopholes by 2030.”
Or you can think confusing: The Bloomberg New Energy Finance white paper is entitled “EPA's Clean Power Plan: 50 Chefs Stir the Pot.”
Or you can think political: The EPA clearly made major concessions to the coal states in the state-by-state requirements.
At any rate, when rules require a state that doesn't produce much carbon to cut its production drastically while allowing comparatively minor cutbacks to a state that produces a lot, it's hard to justify this policy as “carbon mitigation.”
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In the early part of my career, I worked on finding abatement methods for nitrogen oxide pollution: reducing these emissions was required under the Clean Air Act.
Nitrogen oxide emissions are the cause of the dirty brown color of photochemical smog, and they are caused by high-temperature combustion. At a high-enough flame temperature, the air burns itself, uniting nitrogen and oxygen in the air to make nitrogen oxides. This happens in cars and in almost all fossil-fired power plants.
If an area had particularly dirty air, it had to make more drastic cutbacks on pollution. For example, California cars eventually had to have more pollution controls on nitrogen oxide emissions.
Comparing these new carbon rules to my experience regarding nitrogen oxide pollution, I have a hard time wrapping my mind around the idea that an area that produces lots of carbon dioxide has to do less abatement than areas that produce little.
I do not mean to imply that in those good old days, back when I worked on nitrogen oxide pollution, nothing was political. Of course things were political. States and utilities sued one another, they sued the EPA, and so forth and so on.
However, the nitrogen regulations did not start as political: they started as general rules, and then various interest groups attempted to get changes made. In contrast, the recently issued carbon rules are strongly political from the start.
In my overview of the EPA plan, I sadly admit that I think The Onion is right: there will be 30 percent more loopholes by 2030.