Ensuring the Clean Power Plan is Actually "Clean": Resources for Citizens
The Clean Power Plan is EPA’s set of rules for reducing carbon dioxide emissions from power plants. The rule is now final, and states have until September 6, 2016 to draft initial implementation plans (SIPs) to show EPA how they’ll reduce emissions (if they fail to finish a plan by this date, states can ask EPA for an extension).
Some states are holding hearings to get the public’s input. PFPI is presenting testimony in Pennsylvania on the various problems we’ve found in the Clean Power Plan which, if not fixed in the Pennsylvania SIP, could weaken the state’s ability to reduce emissions.
We’ll be posting our Pennsylvania testimony here, along with other resources for citizens who want to weigh in on state plans. We encourage others to adapt these resources to their own needs for commenting on state implementation plans around the country.
Pennsylvania: Written comments on Clean Power Plan implementation
- Comments on role of bioenergy are here
- Comments on role of natural gas and problem of uncounted methane emissions are here
Webinar on bioenergy and the Clean Power Plan
Slides are available here. Email us at info at pfpi dot net for the audio file.
Comments to EPA on the draft Federal Implementation Plan
Spoken comments on bioenergy offered at EPA’s November 12th listening session are here.
Pennsylvania: Testimony offered at hearings on Pennsylvania’s SIP
Information from Pennsylvania DEP on public hearing schedule, how to submit comments, and other relevant material.
The Clean Power Plan doesn’t take climate-warming effects of natural gas leakage into account; EPA underestimates climate forcing factor for methane; bioenergy can’t provide meaningful and verifiable emissions reductions.
Cumulative emissions reductions required by the Clean Power Plan in Pennsylvania only represent a 6 to 8 percent decrease in 2030, relative to a no-action scenario. Pennsylvania should commit to more aggressive emissions reductions and a faster timeline. (Testimony includes spreadsheet that shows cumulative emissions reductions modeling).
Increased reliance under the CPP on natural gas will increase health risks from gas drilling and infrastructure. Converting coal plants to burn waste wood could increase emissions of toxic air pollutants. Pennsylvania should maximize opportunities to clean up the air with the CPP.
Pennsylvania should only participate in a regional carbon trading program if it can set a high bar (no combustion-based renewable energy, ie biomass and waste-burning) and ensure that other states also meet the same standard.
Pennsylvania DEP’s request for input on how the state can employ indigenous resources and a diverse fuel mix are worrisome, if these phrases refer to bioenergy and waste-burning. Meanwhile, CPP implementation can help Pennsylvania counties come into attainment with EPA’s new air quality standard for ground-level ozone.
Pennsylvania is home to some very polluting bioenergy facilities, like the Evergreen plant in Reading, Berks County, which burns contaminated fuels. Berks County, where the plant is located, is one of just a few areas in the country where the air fails to meet EPA’s health standard for airborne lead. Pennsylvania should eliminate co-firing biomass as a compliance strategy in the CPP.
By submitting a detailed state plan to EPA outlining clean energy compliance, the state can avoid opportunistic energy developers coming in with polluting energy projects. Examples of current threats are the “Crawford Renewable Energy” tire-burner proposed in Crawford County, and a proposal to make municipal waste incinerators eligible for Tier I subsidies, alongside wind and solar.
This work is supported by a grant from The Heinz Endowments.