The Center for Progressive Reform, (2016), CPR Paper 1607
37 Pages Posted: 1 Nov 2016 Last revised: 23 Nov 2016
Date Written: October 1, 2016
Although EPA’s Clean Power Plan represents EPA’s bold and commendable effort to reduce carbon emissions from power plants, our report reveals that the Plan’s requirements did not incorporate significant reduction opportunities, a finding that has important implications for the nation’s climate policy. We discuss the critical but little discussed methodological choices that resulted in the gap between the opportunities EPA identified and the rates it set. Had the reduction potential EPA identified been incorporated into the Plan’s requirements, the Plan would have reduced 2030 existing source emissions by 52% from 2005 levels rather than the 38% reduction achieved by the Plan, and would have provided much stronger incentives for utilities and states to shift to available low-carbon alternatives. Although we recognize that EPA and the states might have faced legal and political challenges if EPA had shifted its methodology to incorporate these opportunities, the data nonetheless reveals that additional climate initiatives, at the state, regional, or federal level, remain necessary to tap into the “untapped potential” EPA identified but did not include in the Clean Power Plan.
Keywords: climate change, power sector, greenhouse gases, Clean Power Plan, electricity sector, Clean Air Act
Suggested Citation: Suggested Citation
Kaswan, Alice and Engel, Kirsten H., Untapped Potential: The Carbon Reductions Left Out of EPA's Clean Power Plan (October 1, 2016). The Center for Progressive Reform, (2016), CPR Paper 1607; Univ. of San Francisco Law Research Paper No. 2016-26. Available at SSRN: https://ssrn.com/abstract=2862190