Blog Post

The proposed repeal of the Clean Power Plan shortchanges the benefits of energy efficiency

October 13, 2017

The Environmental Protection Agency, in its proposal this week to repeal the Clean Power Plan, ignores the full benefits of energy efficiency — a key strategy for cutting greenhouse gas emissions. Much of the repeal language focuses on a legal interpretation of the Clean Air Act that, if upheld, would likely take some of the best options for reducing emissions off the table.

The EPA also changes the calculus for determining the costs and benefits of the Clean Power Plan, an Obama administration effort to limit emissions from power plants. Many of the changes are nuanced, but overall, the new analysis would increase the plan’s estimated costs and reduce its benefits—notably, the health benefits.

The new EPA analysis overlooks the fact that by reducing energy waste, we cut not only carbon but also dangerous particulate emissions, soot, and mercury. These pollutants cause and worsen a variety of diseases affecting the heart, lungs, and brain. Reducing these pollutants protects public health and saves lives, but the EPA analysis turns a blind eye to many of those benefits.

Environmental groups and several states are expected to challenge the repeal proposal in court. In spite of a previous court decision requiring the EPA to regulate greenhouse gas emissions, it’s unclear whether the EPA will issue an alternative rule any time soon to address them.

The good news: Despite the EPA’s latest attempt to roll back environmental protections, the United States is moving to protect public health and address climate change. Coal plants are being retired and replaced with cleaner sources of electricity. More than 380 mayors have pledged to uphold the goals of the Paris Climate Agreement. Many states and cities are taking action to limit carbon emissions, and are incorporating energy efficiency into their efforts:

  • California’s cap and trade program was recently extended through 2030. It cites the statewide doubling of energy efficiency as a central part of its plan to reduce greenhouse gas emissions.
  • In the Northeast, states are working together to limit emissions as part of the Regional Greenhouse Gas Initiative. RGGI targets were also recently extended through 2030. These states recognize that energy efficiency is critical to meeting RGGI goals. Six of the nine RGGI states ranked in the top 10 in our most recent State Scorecard.
  • New York City, a “We’re Still In” city, has already delivered a plan to meet the goals of the Paris Climate Agreement. The plan accelerates the city’s reduction of emissions in line with the agreement. It relies heavily on increasing energy efficiency in buildings and transportation.
  • Boston mayor Martin Walsh, as part of his city’s efforts to be carbon neutral by 2050, committed to adhering to the Paris Climate Agreement. Energy efficiency remains a leading strategy to meet these goals.

As communities struggle with unprecedented flooding and fire, we will increasingly need solutions that improve electric reliability, reduce pollution, and eliminate health and safety risks. City and state leaders recognize that they can’t afford to wait while the EPA tinkers with its math. Recognizing the inevitability of regulations that limit greenhouse gas emissions, Ted J. Thomas, chairman of the Arkansas Public Service Commission, might have put it best: “You can either be prepared or unprepared,” he added, “and that’s a pretty simple choice.”

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Healthy Buildings


Sara Hayes
Director and In-House Counsel, Health and Environment
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