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Comments are due one week from today on the EPA’s proposal to curb carbon pollution from existing power plants, the Clean Power Plan. I’m writing a series of blog posts to share some of what will go in our comments to the agency. We’ll start with an issue most people aren’t talking about: Switching from coal to natural gas, a major element of the EPA plan, is a colossal waste of money because we’ll need to switch from natural gas to renewables soon anyway. In its proposal, the EPA ignores this hidden cost of natural gas.

One of the main ways EPA envisions curbing carbon emissions is by replacing coal-fired electricity plants with ones that burn natural gas. The proposal relies heavily on this strategy, so much that it would spur a good deal of additional natural gas extraction, including hydraulic fracturing or “fracking.” That’s a great reason not to rely on natural gas to solve our climate problem. We shouldn’t have to create a new set of environmental disasters to stop climate change – and we don’t.

There are two other major problems with EPA’s plan to increase the use of natural gas. The first, which is getting a lot of attention, is that switching from coal to natural gas may have little to no climate benefit. Natural gas releases a good deal of methane throughout its life cycle, and methane is an extremely potent greenhouse gas. On a twenty-year time horizon, it is 87 times as climate-disrupting as carbon. In 100 years, it’s 36 times more potent. As Joe Romm put it over at ClimateProgress, “by the time natural gas has a net benefit you’ll likely be dead and the climate ruined.”

Even setting aside the methane issue, burning natural gas also emits carbon – less carbon than burning coal, to be sure, but that’s not good enough. We don’t just need to reduce carbon emissions. According to the International Energy Agency’s most recent analysis, we should cut them to zero by 2040. What’s the point of switching to natural gas between now and 2030, the end date of the EPA’s proposed rule, if we’ll need to phase out natural gas by 2040? Why not just skip straight to renewables? We’re making these points in our comments – without the rhetorical questions, at least in the current draft – as are many other groups.

Here’s the second, less recognized point, which stems from our consumer perspective. These changes cost a significant amount of money, much of which will ultimately be paid by consumers through electricity bills (or through higher prices for goods and services from companies who paid the costs on their electricity bills). Overall, the Plan will save consumers money because it includes efficiency measures that will reduce electricity use, but it could be even better. Switching twice rather than once – from coal to natural gas, then natural gas – needlessly compounds the cost of responding to climate change. The EPA’s proposal ignores the additional costs of this double-switch. In essence, we’re telling the agency that it needs to use a more comprehensive, more accurate accounting of the cost of natural gas. The real cost is the price of switching from coal to natural gas, which is expensive in its own right, plus the cost of switching to renewables almost immediately thereafter.

Relying on natural gas to reduce carbon emissions just doesn’t make sense. Not only is the climate benefit of natural gas doubtful; it’s exorbitantly expensive compared to improving energy efficiency and switching directly to generating electricity sustainably from renewable sources.

 

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Statement of Robert Weissman, President of Public Citizen

Today, the Commodity Futures Trading Commission (CFTC) is penalizing five of the world’s largest banks for concerted efforts to manipulate global foreign exchange markets – yet another reminder of the rampant criminality and wrongdoing on Wall Street.

Strikingly, as the CFTC notes in understated fashion in its release, “[S]ome of this [improper attempted manipulation of foreign exchange markets] conduct occurred during the same period that the Banks were on notice that the CFTC and other regulators were investigating attempts by certain banks to manipulate the London Interbank Offered Rate (LIBOR) and other interest rate benchmarks.”

In other words, the banks were on notice that they were under investigation for similar wrongdoing in another global financial market – and still continued with the attempted manipulation of the foreign exchange market!

For too long, U.S. law enforcement agencies have been far too soft on Wall Street lawbreakers. In recent years, the U.S. Department of Justice has entered into deferred prosecution or non-prosecution agreements with RBS, JPMorgan Chase, UBS and HSBC, choosing not to prosecute these firms for large-scale wrongdoing. The department has also agreed to high-profile civil settlements with JPMorgan and Citigroup.

Completely absent has been serious criminal enforcement against the Wall Street firms and Wall Street executives.

It’s past time to say: Enough is enough. It’s past time for the Justice Department to enforce the law and hold the powerful to account.

Numerous published reports indicate that the Department of Justice is considering criminal prosecutions of individuals responsible for the attempted foreign exchange manipulation schemes. It is vital that the department pursue these prosecutions, holding both top-level executives – not just lower-level functionaries – and the firms themselves criminally liable.

And, if bank regulators tell the department that criminal prosecution of large financial institutions would endanger the global financial system, then those same regulators should act immediately to break up firms whose size affords them immunity from criminal sanction.

Wall Street managed to escape criminal sanctions for wrongdoing that crashed the global economy, and threw millions of out of their homes and tens of millions out of work. If there is no criminal enforcement against Wall Street firms and executives for wrongdoing, there is no justice for Main Street, and we’re virtually certain to see epic-scale misdeeds and epic-scale devastation yet again.

The industry-funded 60 Plus Association is back with another bogus analysis attacking the EPA’s Clean Power Plan. This one focuses solely on Louisiana, presumably in an attempt to influence the state’s Dec. 6 run-off election for U.S. Senate. This report uses the same basic tricks as the last one: focus on electricity prices, not actual bills that consumers will pay, and focus more on the near term than the long term.

There’s a lot of fluff in the report, but its main charge against the Clean Power Plan is that the rule will increase retail electricity prices 4.5 percent to 11.7 percent by 2020 in the power regions that include Louisiana. As I discussed last time, the retail price of electricity is misleading. Here’s why: The Plan also projects that people will use less electricity due to increases in energy efficiency. That means electricity bills will decline even though the price of electricity goes up. Actual consumer costs don’t fit 60-Plus’s narrative, so it cites misleading figures on retail prices instead.

The 60 Plus study also focuses on the EPA’s projection for electricity prices in 2020 rather than 2025 or 2030 because the latter numbers are more favorable. (Clean Power Plan Regulatory Impact Analysis (RIA) Tables 3-21, 3-22, 3-23).

The report actually helps make the case for a stronger Clean Power Plan, though surely unintentionally. It cites multiple projections that electricity prices will rise steeply through 2040. (60 Plus Louisiana Report at 4). Rising prices are all the more reason to reduce the amount of electricity that consumers use by promoting aggressive energy efficiency measures.

A recent report by the American Council for and Energy Efficient Economy (ACEEE) found that Louisiana could invest in energy efficiency to

  • save 157,763 gigawatt-hours of electricity between 2016 and 2030 (ACEEE Change is in the Air Table C1);
  • save $6.2 billion between 2016 and 2030 by investing in energy efficiency (Table C6); and
  • create 11,500 additional jobs by 2030 (Table C7).

I haven’t attempted to calculate how much of Louisiana’s Clean Power Plan compliance this approach would take care of, but it’s probably very high. ACEEE estimates that the efficiency measures it outlines would curb carbon emissions nationwide by 26 percent from 2012 levels by 2030. That’s about 73 percent of what the Clean Power Plan seeks (a 30 percent cut from 2005 levels by 2030). By the way, ACEEE notes that its analysis is intentionally conservative. We can do even better.

Maybe reporters can ask 60 Plus whether it supports these robust efficiency measures. (In the unlikely even that it says yes, they can follow up by asking what it’s doing to support them.) They should also ask it why it doesn’t support the Clean Power Plan if it really cares about seniors’ expenses — and why it doesn’t support strengthening the Plan with more robust energy efficiency targets.

 

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The corporate accountability expert offers his thoughts on campaign finance reform.

Robert Weissman is an expert on issues related to financial accountability and corporate responsibility. As president of the nonprofit Public Citizen organization, he’s championed citizen interests before Congress, executive branch agencies and the courts on various policies, including healthcare, intellectual property and trade and globalization.

Advocates deliver 100,000 comments and petitions to the EPA

Advocates deliver 100,000 comments and petitions to the EPA

In comments and petition signatures delivered to the Environmental Protection Agency (EPA) this morning, more than 100,000 people urged the

agency to update the safety requirements for some of the country’s largest hazardous chemical processing facilities.

Comments and signatures were gathered by Public Citizen, Greenpeace, U.S. PIRG, the Sierra Club, BlueGreen Alliance, and many others.

The chemical processing facilities in question are places like fertilizer plants, oil refineries, and bleach manufacturers. Roughly 110 million Americans, or one-third of the country, live in a high-risk zone near a chemical processing facility.

The Center for Effective Government has put together a handy (or terrifying) map showing the locations these chemical plants, and their proximity to public schools.

The EPA is looking for ways to improve its Risk Management Program, a move prompted by an executive order from President Obama that was issued in the wake of the fertilizer plant explosion in West, Texas.

The fertilizer plant, which housed more than 270 tons of flammable chemicals but lacked a fire sprinkler system, exploded last April while emergency crews were responding to a fire. The blast killed 15 people, injured 226 more, and destroyed 150 homes.

The EPA’s new plan could prevent tragedies like the one in West, Texas by making new safety standards a requirement for facilities that manufacture and process hazardous chemicals.

The EPA’s new plan to manage these dangerous plants should include requirements for safer processing methods, reduced use of the most dangerous chemicals, and of course, commonsense safety measures like fire sprinklers.

With more than 110 million Americans at risk, it’s far past time for the EPA to act.

Kelly Ngo is the Online Advocacy Organizer for Public Citizen’s Congress Watch Division.

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