Defend Clean Air Act Protections - and how they will help us curb global warming

Jan 12, 2010

The original version of this letter was written and signed by Environment America, FCNL, and other NGOs

We must ensure that Congress does not repeal the sections of the Clean Air Act that require coal-fired power plants to meet modern standards for global warming pollution. Senator Murkowski (AK) is attempting to offer amendments that would strip those Clean Air Act protections and keep the EPA from beginning to set minimum greenhouse gas standards for the largest emitters.

Old, "clunker" coal plants are the nation's largest source of global warming pollution; it will be significantly more difficult to stop global warming, transition to clean energy, and create more clean energy jobs if we do not hold these plants to modern pollution standards.

Old, clunker coal plants must be required to meet smokestack-specific standards. For the same reasons we require cars, air conditioners, and light bulbs to meet technology standards, we must also set standards for coal plants, the nation's single largest source of global warming pollution. If we are to transition smoothly to a clean energy economy and solve global warming, coal plants - old and new alike - must not be permitted to keep running on inefficient, decades-old technology.

The pollution cap will not be enough by itself to significantly cut pollution from coal plants in the next decade. The cap alone is not sufficient because, consistent with the House-passed bill and legislation under development in the Senate, (1) the emissions ceiling likely will decline relatively slowly for the first decade of the program; (2) companies likely will receive free pollution allowances to cover most of their emissions; and (3) companies will be able to avoid reducing pollution at their plants by purchasing offsets generated by projects in the United States and abroad. Indeed, EPA's analysis of the House-passed energy bill (which repeals New Source Review and New Source Performance Standards for carbon dioxide from existing coal plants) projects that only 6.9 percent of existing coal generation capacity will be retired by 2025, with most of the retired capacity occurring at "marginal units with low capacity" that are "part of larger plants that are expected to continue generating."

Singling out existing stationary sources from complying with emissions and efficiency standards will give them a massive, unfair leg-up, tipping the market against clean sources like wind and solar. The U.S. Department of Energy projects that electricity demand will be relatively flat over the next 20 years (an annual average growth rate of less than 1 percent), even before considering the multitude of efficiency gains that would be achieved by the House-passed energy bill and other policies. If electricity demand is flat and old coal plants don't begin to retire, there will be a much smaller market for renewables. Indeed, EPA's analysis of the House-passed energy bill projects that coal will continue to provide nearly half of the nation's electricity through at least 2025.

Companies will be perversely encouraged to keep operating - and even expand the operation of - their oldest and dirtiest coal plants, if they are exempted from modern pollution standards. Under the House-passed energy bill, new plants would in a few years have to meet fairly stringent global warming limits. But old plants would not have to meet any smokestack-specific standards, even if they are expanded in ways that drive up pollution. This loophole invites the industry to ramp up their use of old, dirty coal plants instead of retrofitting them to reduce pollution or retiring the oldest dinosaurs to make way for renewable energy.

Moving to clean energy means leaving old, inefficient, and dirty technology behind. Just as emissions standards for automobiles help ensure that the dirtiest clunkers on the highway are replaced with newer models, so would effective global warming pollution standards help ensure that clunker coal plants, many of them 40 to 50 years old, don't keep operating indefinitely. Coal plants impose major costs on the environment and public health. The National Academy of Sciences has found that these ancient coal plants cost the U.S. economy tens of billions of dollars a year in public health damages. And in the meantime, countries like China speed ahead in the global renewable energy race.

Standards for clunker coal plants will require investment in America's aging energy infrastructure that will create clean energy jobs. By requiring that outdated coal plants install modern technology to reduce global warming pollution, we will unleash innovation and put America's workforce back in business.

We cannot stop the worst effects of global warming unless we start cutting pollution from coal plants now. A recent report on "The Future of Coal" by the Massachusetts Institute of Technology makes clear that there is "no credible pathway toward GHG stabilization targets without emissions reductions from existing coal plants." Steady reductions in pollution from coal plants are necessary to achieve the deep cuts in pollution the science already shows is necessary by 2030 and later.