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Eco-Justice Notes
The E-mail Commentary from Eco-Justice Ministries

Thanks, EPA ... but More!
distributed 8/1/14 - ©2014

On Wednesday evening, here in Denver, I spoke at one of the EPA's public hearings on the proposed Clean Power Plan. The very-short version of my 5 minute statement was "Thanks, but make them stronger."

The proposed regulations from the Environmental Protection Agency are very important in reducing US greenhouse gas emissions. They are also controversial, with powerful businesses in the coal industry fighting the rules.

The EPA needs to hear from all of us who are in support of dramatic reductions in US carbon emissions. I encourage you to submit a comment similar to mine, supporting the rules, and calling for even stronger action. (Links and instructions for commenting are below.)

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The EPA has a 1-page fact sheet that is an introduction to the hundreds of pages of the actual plan. That sheet cites the number that is at the center of the proposal: "Nationwide, the Clean Power Plan will help cut carbon pollution from the power sector by 30 percent from 2005 levels."

The proposal actually has two targets -- to get 26% below 2005 emissions by 2020 and 30% by 2030. The juggling of numbers in all of this is enough to give accountants or statisticians a headache, but it looks to me like the proposal: (1) does important things, (2) does not do as much as it initially appears, and (3) could do considerably more.

Let me try an analogy that taps into a more everyday experience to help us relate to these figures.

Imagine that you are enticed to go shopping when you see big ads proclaiming a sale with 30% off. Wow! What a deal! But when you get to the store, you discover the small print which says that that the sale price is based on the highest marked price, and you find out that the ordinary price has been 12% below that marked price for quite a while. So the sale, effectively, "only" knocks about 18% off what you would have paid.

Is that still a good deal for you? Probably. Are you disappointed about not getting the bigger discounts? Sure. Is it honest to talk about a 30% sale based on old prices? Perhaps, but it is more informative to give figures based on current prices.

The EPA's big numbers for reductions are in relation to 2005, the highest years for US carbon emissions. Ben Adler, writing on Grist and referring to a Wall Street Journal article, tells us that "emissions fell 12 percent between 2005 and 2012. The recession of 2008 significantly reduced emissions by slowing economic activity, and the fracking boom has since decreased CO2 emissions further by replacing coal with less carbon-intensive natural gas." So, without any influence from the new rules, we're already a long way toward the target.

The numbers look less impressive if we measure changes by the current (2012) emission levels. An analysis by the NRDC says that the EPA proposal gives reductions of 13% below 2012 emissions by 2020 and 17% by 2030. That's a pretty good drop in the next few years, and not a lot more in the whole decade of the '20s.

Can more be done? The Union of Concerned Scientists says that "a carbon standard combined with strong complementary renewable energy and energy efficiency policies could yield 992 million MWh of renewable energy generation by 2030 and reduce power sector carbon emissions by approximately 60 percent below 2005 levels."

The NRDC has proposed an approach which "would cut CO2 pollution from America's power plants by 21 to 31 percent from 2012 levels by 2020, and 25 to 36 percent by 2025."

So, yes, there are reputable -- if very challenging -- proposals that could lead to much bigger cuts. A much more robust turn toward renewable energy is key to getting us there.

The EPA has an informative 3-minute video about the plan (in the "whiteboard" style that is sort of amusing). According to that presentation, under the new rules, by 2030 coal would still provide over 30% of electrical power in the US -- about the same percentage is it provides now.

With the urgent need to dramatically cut carbon emissions, I do hope that the amount of energy coming from fossil fuels, especially coal, is much less than it is now. The EPA needs to be pushed toward a move vigorous transition to clean energy sources in these rules. That is what I told the EPA representatives at Wednesday night's hearing in Denver.

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How can you submit a comment on the EPA's proposed rules?

If you are highly motivated and well-informed, you can create your own statement, and file it by email or through The EPA gives instructions on all the details for how to do this.

If you'd like a simpler approach that is just as official, there are several websites that will let you edit a sample statement, and then submit it properly for you. Two organizations have strong statements that affirm the need for strong rules, and call for a greater role for renewable energy.

As the UCS points out, "Please make your letter personal by adding in your own thoughts and concerns. Every letter makes a difference, but customized letters have the greatest effect!"

The Environmental Protection Agency is to be commended for acknowledging the reality of climate change, detailing the climate impacts that are happening right now, and proposing strategies for reducing the carbon emissions from power plants. Especially in the face of strong resistance from fossil fuel industries, the EPA needs to be pushed toward much stronger standards.

Please take a few moments today to file your statement.


Peter Sawtell
Executive Director
Eco-Justice Ministries

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