This month, the Environmental Protection Agency (EPA) published proposed new standards limiting Greenhouse Gas Emissions from new electricity generating power plants using coal or natural gas. Allegations of secrecy and political interference in science began to surface even before the proposal was released. So do these allegations have any merit?
This proposal was a revision of an earlier version from 2012 which contained a single standard for new power plants. But in the new rules, the EPA is proposing different standards for new natural gas and coal fired plants. And the new proposal only covers new plants that will supply more than 30% or their generated electricity to the grid. The rules rely on studies and currently designed projects to show that that new standard is achievable, and in fact can be exceeded with a range of existing technologies.
Even before this proposed rule was published, cries of alarm were sounded. A Wall Street Journal (WSJ) editorial, focusing only on the standard for new coal-fired plants , claims that the EPA used “secret, taxpayer funded research and bogus technological claims” concerning reductions in emissions via carbon capture and storage. In addition to flatly declaring the proposed standard technologically infeasible, the WSJ questioned the scientific integrity of EPA. Forbes repeats the same argument.
Scientific integrity policies are near and dear to the Center for Science and Democracy at UCS, and the EPA is one of the federal agencies that worked the hardest at putting such a policy in place. So I took a closer look at the editorial and its criticisms of the new rules. And mostly I found the WSJ’s claims either inaccurate or distorted. However, I can agree that, while the science underpinning the proposal appears to be peer-reviewed, the agency could have been clearer about the process and extent of that review of the information it used in the proposed rule.
There doesn’t appear to be anything “secret” about the research that shows that very few if any new coal-fired power plants are likely to be built in the foreseeable future because of the changing market conditions for natural gas and renewable energy versus coal. The forecasts of future energy needs and fuel sources come from the Energy Information Administration at Department of Energy (DOE), an authoritative source based on industry information. Only a handful of new plants are under construction or planned in the U.S., and at least five projects include carbon capture and storage according to MIT. In addition, MIT lists more than 20 power plant CCS projects in other countries and numerous non-power plant CCS projects under development, along with several commercially operating in the U.S. using CO2 for enhanced oil recovery.
The “secret” analyses of different methods for reducing emissions are freely available on the Internet and were peer reviewed according to the EPA and DOE guidelines. The model approach in the baseline analyses uses a well-developed and reviewed modeling method.
The WSJ and Forbes incorrectly state “the Energy Department revealed that some of the studies had been “peer reviewed” by the EPA itself over a period of just a few weeks and the rest never got an unbiased look.” Actually, the DOE report says that, “The initial results of this analysis were subjected to a significant peer review by industry experts, academia and government research and regulatory agencies. Based on the feedback from these experts, the report was updated both in terms of technical content and revised costs.” Among these, the regulatory agency that provided review was the EPA, because that is where the expertise is, but somehow WSJ and Forbes left out that industry, academic and research lab part of the review. And of course revision following review comments is exactly what should be expected.
The role of the Science Advisory Board
WSJ and Forbes criticisms focus heavily on the work of the EPA Science Advisory Board (SAB), the chartered panel for giving the EPA external science advice. Claiming that the EPA “steamrollered” the Board, they call into question the scientific integrity of the process. The SAB operates by creating work groups tasked with bringing issues to the full board for consideration. That is what happened in this case, and the WSJ correctly notes that the working group recommended additional peer review. But the full SAB asked the working group to do some additional fact-finding. Based on that effort, the working group recommended that SAB review was not warranted. But, the working group also recommended that EPA should be clearer about both the scientific basis and the peer-review conducted. I certainly agree that we are all better served by agencies providing that sort of information early in the rule-making process.
That recommendation was addressed by the full SAB in a meeting on January 21. I have participated on similar advisory boards, using a similar structure. And frankly, science panels do not take up every recommendation of their working groups. But the process, which is publicly available as indicated by the links above, is important. It is fact-finding and consideration by the group of experts in giving their best advice. That isn’t necessarily “political science” as labelled by the WSJ.
The SAB will now advise the EPA Administrator, that assuming that the rule deals only with capture, they are not moving forward with additional peer review. However, there is a great deal of concern around the non-capture portions (storage and transportation) of the process, the science behind them and and their potential effects on the full system. The SAB would like to explore ways that the board might interact on these issues going forward. They also strongly support careful and regular monitoring of how this rule is implemented. Their primary concern is the secondary outcome of sequestration on the environment and public health.
That sounds like the SAB doing its job to me. Considering the information, pushing for facts and expressing concerns as part of their advice.
What is clean coal anyway?
The American Coalition for Clean Coal Electricity (ACCCE) spokeswoman has declared the standards “unachievable.” The EPA chose not to apply this standard to existing plants in this rulemaking, even when they undergo major upgrades, and even then only to require a “partial” reduction in emissions. The coal industry has been claiming the new carbon rules will drive “the death of coal” because the required emissions cuts are too expensive or aren’t even technically feasible. As my colleague Rachel pointed out in a previous post, this is very ironic considering that these same folks have been touting the benefits of “clean coal” for years.
Performance-based rules are specifically intended to allow innovation and managing for cost effective solutions. While CCS certainly isn’t in use widely, the technology is at a stage where EPA can include its use in a rule because the Clean Air Act specifically allows regulations to spur the use of new technology. It is important to note here that most pollution control technologies (like catalytic converters, scrubbers, and alternatives to ozone-depleting chemicals) didn’t actually come into widespread commercial use until after a regulation was enacted. It is also worth noting that these technologies were developed and implemented at a fraction of the cost projected by some industry sources when the policies were under debate.
This is a proposed regulation, so if recent history is any guide, there will be a lot of public comment – as there should be. The process is important and part of that process is to bring science to the public’s attention. All federal agencies need to aggressively implement scientific integrity policies including use of external review in appropriate ways. And the review process should be made clear to the public. Wall Street Journal – please don’t dismiss both the rule and the science in the middle of that process.