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Untapped Potential: The Carbon Reductions Left Out of EPA's Clean Power Plan

The Center for Progressive Reform, (2016), CPR Paper 1607

Univ. of San Francisco Law Research Paper No. 2016-26

37 Pages Posted: 1 Nov 2016 Last revised: 23 Nov 2016

Alice Kaswan

University of San Francisco - School of Law

Kirsten H. Engel

University of Arizona - James E. Rogers College of Law

Date Written: October 1, 2016

Abstract

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

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

Alice Kaswan (Contact Author)

University of San Francisco - School of Law ( email )

2130 Fulton Street
San Francisco, CA 94117
United States
(415) 422-5053 (Phone)

Kirsten H. Engel

University of Arizona - James E. Rogers College of Law ( email )

P.O. Box 210176
Tucson, AZ 85721-0176
United States
520-621-5444 (Phone)

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