News Reports That EPA Rule Would Require a Huge 49% Cut In NJ Emission Rate
Actual Rate Cut is Just 13%
How Did They Get Such An Important Story So Wrong?
[Update: 8/6/15 – Jim O’Neill at the Bergen Record corrected his story – he reduced the originally reported 49% emissions rate reduction to just 26%. I think it is even less due to overestimates of baseline emissions and emissions rate.
The error was based on incomplete and misleading EPA data. I made a similar error in deriving the 13%, which was based on a baseline of EPA’s phase I interim emission rate for NJ, not the 2012 rate. ~~~ end update]
Last night, it was so hot I couldn’t sleep, so I went on line to read the news.
I was shocked to read a story by Jim O’Neill of the Bergen Record that reported that the Obama EPA Clean Energy Rule would require a huge 49% cut in NJ’s greenhouse gas emission rate. O’Neill wrote:
New Jersey’s 45 power plants emitted a combined 14.5 million metric tons of greenhouse gases in 2013. By comparison, neighboring Pennsylvania’s 62 plants emitted 105 million metric tons and Ohio’s 45 plants emitted 99 million metric tons.
The new rule would require New Jersey to cut its 2012 carbon emissions rate 49 percent by 2030. Some big coal-burning states must reduce their rates by smaller percentages, but their actual amount of emissions cut would be larger.
I immediately knew that could not be right, so I got a copy of the actual EPA Final Rule that EPA released yesterday to check the facts. I suspected The Record story was wrong in 3 ways: 1) the baseline emissions for purposes of the EPA rule (2013); 2) the emissions regulated (45 plants, 14.5 MT); and 3) the emission rate reduction required by the EPA rule (49%).
According to the EPA Final Rule, the actual emission rate reduction for New Jersey is just 13.4% – from 937 pounds of CO2 per Net MWh to 812 pounds.
See
Final Rule, Table 12 on page 842 “Statewide Rate-Based CO2 Emission Performance Goals (Adjusted Output-Weighted-Average Pounds of CO2 Per Net MWh From All Affected Fossil Fuel-Fired EGUs)
The EPA rule also provides data on mass reductions (in tons), based on the emission rates.
According to EPA, existing NJ emissions are 18,241,502 tons – The EPA emission reduction goal is 16,599,745 – that’s just a 9% reduction.
For tons of emissions reduced,
see also page 844 “Table 13. Statewide Mass-Based CO2 Emission Performance Goals (Adjusted Output-Weighted-Average Tons of CO2 from All Affected Fossil Fuel-Fired EGUs)”
BTW, and this is of no regulatory significance, if O’Neill’s emissions data is right (14.5 million tons), then NJ has already met the EPA’s overall emission reduction goal of 16.599,745 tons (but the EPA rule works on an emissions rate, not a mass, or tonnage).
The public and the press don’t understand the difference between an emission rate and mass (tons) of emissions. The EPA rule does not cap or limit total emissions. The EPA rule is based on lowering the emission rate, so actual emission can INCREASE if coal plants switch to gas, which has a lower CO2 emission rate per MW electric generation (and that potential increase in emission from fuel switching allowed by the EPA rule is only based on the power plant combustion level – it doesn’t count all the fugitive emissions and lifecycle emissions from fracking, which show that gas is as bad or worse than coal). The same thing happened with cars: although fuel efficiency increase (miles per galling) the increase in vehicle miles travelled wiped out the efficiency gains.
Jevons paradox.
I checked other parts of the Final Rule and confirmed these numbers -Table 2 to Subpart UUUU of Part 60—Statewide Rate-based CO2 Emission Goals (Pounds of CO2 per Net MWh) shows an even lower emission rate reduction for NJ, just 8.2%.
I then check the
EPA’s Regulatory Impact Analysis, which quantifies the economic impacts of the rule, and found similar information on emission rate and tonnage reductions for NJ.
see Table 3.1 for state by state data:, The data as consistent, but the numbers were not the same as in the EPA Final Rule
The RIA states that NJ emissions are 17,426,381 and the emissions reduction goal is 16,599,745 tons, just a 4.7% reduction.
I could not verify anything even close to a 49% emission rate reduction, so I assumed O’Neill was fed bad information.
The EPA’s so-called Clean Power Plan identifies specific steps that New Jersey has to take to reach its target, including cutting carbon pollution generated power plants from 1035 pounds per megawatt hour in 2012 to 531 pounds by 2030.
Tom recently reported a PJM analysis that showed that the EPA rule would have little impact on NJ, just the opposite of this huge 49% cut, see:
So, where did these reporters get their information? They were spun badly.
I suspect that the Christie Governor’s Office and/or DEP is lying about this rule for political reasons – a new low for politicizing science at DEP. (see:
Gov. Christie just confirmed by suspicions in The Record’s story:
Governor Christie, a candidate for the Republican presidential nomination, was quick to attack the plan. “I’m totally opposed to it,” he said Monday on Fox News’ “America’s Newsroom.”
“Last year they issued 81,000 pages of new federal regulation in one year. This is the greatest regulating administration in the history of the United States and it is going to kill American businesses and jobs, as it has.”
Asked by The Record on Monday if he planned not to comply with the rule, Christie said, “We already put a letter out on that a long time ago saying we didn’t want to do it.”
Last November, the Christie administration sent a letter to the EPA opposing adoption of the rule, saying it was “fundamentally flawed” and “broken.” The letter, from Bob Martin, the state Department of Environmental Protection commissioner, argued the rule “would punish our state” by failing to provide credit for emissions reductions the state has already achieved.
There real story, if you read the text of the EPA Final Rule, is how often NJ is cited in legal decisions as a leader on clean air – while Christie is a laggard.
Our press corps needs to start reading the official documents, not the press releases.