Is the US Ready for a Carbon Tax?

• While the Trump administration seeks to undo CO2 regulations, a group of former Republican officials has proposed a new, market-based emissions plan.
• This "carbon tax" looks simpler than EPA's Clean Power Plan or previous cap-and-trade legislation, but not simpler than the pre-Obama status quo.

The idea of taxing the carbon content of energy--and presumably the goods and services produced with it--is back in the news. A group of Republican "wise men" has floated it as an alternative to the regulation-based approach to emissions that the Obama administration pursued after its preferred "cap & trade" legislation died in the Congress.

Reduced to its basics, a carbon tax is a focused version of a consumption tax, based on usage rather than income or valuation. The level of the tax would be set by law, either as a fixed amount per ton of emissions or at an initial rate with preset future increases. What can't be known with certainty in advance is just how much a given level of carbon tax would reduce actual emissions.

This contrasts with the method of setting a price on carbon preferred by many other economists and environmental groups, called "cap & trade." In this approach, the government sets a cap, or maximum level, on emissions for a designated sector or the economy as a whole, while parties subject to the cap are allowed to trade emission allowances and credits with each other under that cap. Thus policy makers set the level of emission reductions, and allow the market to find the resulting price on carbon. In principal, that ought to be more efficient than the simpler carbon tax, because market forces should drive participants with low costs of cutting emissions to make the deepest reductions and then sell their excess cuts to others, for less than it would cost the latter to reduce by that amount.

From the late 1990s until 2009 or '10 I was convinced that cap & trade was the better approach to pricing emissions. However, the experience of watching the US Congress attempt to design a cap-and-trade system for the US economy cured my certainty. As I have described at length, the inclination of legislators to help favored companies, industries and sectors, combined with the extraordinary temptations created by the sheer scale of the revenue such a system would channel through the government's hands, revealed practical problems that look insurmountable in the real world, at least under our political system.

In fairness, cap-and-trade is currently used to promote emissions reductions in various jurisdictions, including California, the mainly northeastern states participating in the Regional Greenhouse Gas Initiative, and the European Union. From what I have observed, all of them have experienced technical difficulties involving the allocation of free allowances, inadequate liquidity, and other issues. The biggest practical problem is that the carbon prices these systems have tended to deliver might be characterized as the opposite of a Goldilocks price; i.e., they are typically high enough to generate substantial revenue, creating strong constituencies for their continuation, but too low to influence behavior very much.

For example, California's emissions credits currently trade at around $13 per metric ton of CO2, equivalent to $0.10 per gallon of gasoline containing ethanol. Would an extra $1 per fill-up make much of a difference in how much you drive, which car to buy when you replace your current car, or whether to sell your car (or forgo buying one) and take public transportation?

Moreover, California's emissions have been essentially flat since the state implemented cap-and-trade in 2012. However, since 2002 the state's electric utilities--historically the highest emitting sector--have operated and invested under a Renewable Portfolio Standard requiring them to increase the share of renewable energy in their generation mix to 20% by 2010, 33% by 2020, and now 50% by 2030. I suspect that accounts for most of the 7% drop in emissions since 2002, while the impact of a carbon price equivalent to 0.6 cents per kilowatt-hour (kWh) is likely lost in the noise. Of course a carbon tax would create its own political and practical complications.

First, consider how a carbon tax would affect different energy sources. As with cap & trade, a carbon tax should have its biggest impact on the highest-emitting forms of energy. In practice that would compound the current disadvantages for coal compared to abundant, low-priced natural gas and rapidly growing, essentially zero-emitting renewables like wind and solar power. At least on the surface, that seems at odds with the stated goal of the Trump administration to attempt to rescue the US coal industry and the communities that depend on it.

Like cap & trade, a carbon tax would also require a significant amount of new bookkeeping to track the path of "embedded emissions"--the CO2 and other greenhouse gases emitted at each step of a product or service's supply chain--through the economy. Some of this is already done voluntarily by companies participating in various sustainability reporting efforts, but it would be new for many others. The EPA, Department of Energy, and numerous non-governmental agencies have done much work to quantify such emissions, but a carbon tax would require a level of rigor and audit trail consistent with the creation of what amounts to a shadow currency within the economy.

A carbon tax also raises similar questions of how to spend the resulting revenue that have bedeviled cap & trade. At the current US emissions and assuming few sources were exempted, the proposed $40 per metric ton initial carbon tax would raise around $275 billion per year. That's 8% of this year's federal budget. It doesn't take a cynic to guess that the first inclination of any Congress enacting such a tax would be to hang onto this money to fund new programs, reduce the federal deficit, or some combination, rather than returning it to taxpayers as former Secretaries Baker and Schultz and the economists who back them suggest.

Their proposal would require that the proceeds of the carbon tax be rebated to essentially the same people who would be paying it at the gas pump or in their gas and electric bills. This sounds similar to the "Cap and Dividend" approach to cap & trade proposed by Senators Cantwell (D) and Collins (R) a few years ago. Their bill had the great advantage of simplicity, requiring just a fraction of the 1,427 pages of the 2009 Waxman-Markey cap & trade bill, the main purpose of which seemed to be to redistribute vast sums of money outside the tax code. But like W-M, it went absolutely nowhere.

Like it or not, that's my best guess of the fate of the current carbon tax idea, too. The biggest challenge facing a carbon tax today is that it would not be running as a simpler, more market-oriented alternative to prescriptive legislation or complex EPA regulations. After all, the administration's intention appears to be to eliminate the EPA's main emissions-reduction regulation, the Clean Power Plan, not to replace it.

And although the new US Secretary of State, Mr. Tillerson, is on record numerous times in support of a carbon tax, that position seems to have been put forward mainly in preference to cap & trade, rather than on its own merits in the absence of any other strict climate policy.

A carbon tax would raise the effective price of energy commodities in which we appear to have a global competitive advantage, at least for now. The current proposal may rebate the carbon tax on exports, but most economic activity starts and ends within this country. And as noted in the NY Times op-ed by Dr. Feldstein and the other economists backing this measure, the revenue recycling to consumers would be on an equal basis, rather than proportional to usage, so there would be winners and losers as with any redistributive taxation. Lower-income Americans driving older cars seem likelier to come out on the short end of that than wealthier consumers driving new cars that meet rising fuel economy standards.

Ultimately, we must ask why President Trump or his team would want to impose a new tax on US consumers and businesses to address a problem that has probably just become an even lower priority for them than it was. Notwithstanding Mr. Trump's demonstrated unpredictability, the simplest answer seems to be that he wouldn't.

US Energy Under Trump

• President-Elect Trump and his appointees plan a major policy and regulatory shift for energy, focusing more on economic benefits and less on environmental impacts.
• Obama-era regulations most at risk of roll-back are those justified mainly on climate concerns not shared by Mr. Trump and his team.
• Emissions are still likely to fall in the next four years as shale and renewable energy output grow. 

Next week's presidential inauguration will trigger the biggest policy and regulatory shift for the US energy industry in at least ten years. That's how long it has been since energy policy was set by a Republican president and Congress. Donald Trump is a different kind of Republican, though, and his goal does not seem to be a return to scarcity and high energy prices. What should we expect, instead?

To gauge how sharply the energy polices of the incoming Trump administration will diverge from those of the last eight years, we need to understand what motivates both leaders. The Obama administration's approach was driven by a deep, shared conviction that climate change is the most important challenge the US--and world--faces. The cost of energy and its impact on the economy became secondary concerns, subordinated by the belief that the added cost of climate policies would be offset in whole or part by the benefits of the green investment they unleashed--remember "green jobs"?

We saw this in President Obama's first year in office. Amid a deep recession he worked with Congress to attempt to limit greenhouse gas emissions by means of an economy-wide cap-and-trade system, on which he had campaigned. The House of Representatives passed the Waxman-Markey bill (HR.2454), a veritable dog's breakfast of economic distortions. Yet despite a filibuster-proof majority in the Senate in 2009, Waxman-Markey and every subsequent cap-and-trade bill died there.

That failure set in motion the agenda that the Obama administration has pursued ever since, to achieve via regulations the emissions reductions it could not deliver through comprehensive climate legislation. Last year's publication of the EPA's final Clean Power Plan was a key component of an effort that seems set to continue until just before Inauguration Day.

The transformation of energy regulations under President Obama was dramatic enough that a transition to any Republican administration would be a big change. The transition now in prospect will be even more jarring. Mr. Trump's rhetoric and his choices for key administration positions point to a concerted effort to unravel as many of the Obama-era regulations affecting energy as possible. That isn't just based on philosophical differences over regulation and markets. For President-Elect Trump the economy and jobs are paramount, so the Obama energy regulations must look like an unjustifiable threat to the fossil fuel supplies that still meet 81% of the nation's energy needs.

Despite that, it is unlikely the new administration will go out of its way to target renewable energy or the tax credits that have driven its growth to date. Renewables are becoming increasingly popular with conservatives. However, because Mr. Trump sees climate change as, at best, a secondary issue that may not be amenable to human intervention, his administration's won't put renewables on a pedestal as the Obama administration has done.

The biggest challenge for renewable energy may come from tax reform intended to make US companies and factories more competitive globally and shrink the incentive for them to relocate to lower-tax countries. This appears to be a high priority for the new White House and Congress, and one on which they broadly agree. If corporate tax rates drop, the value of the tax credits renewables enjoy is likely to fall, too, making wind, solar and other such projects less attractive and less competitive.

It remains to be seen how many of the Obama energy regulations can be rolled back. The most recent regulations might be averted through legislation like the Midnight Rules Relief Act, or the REINS Act, both of which would update the Congressional Review Act, a rarely used 1990s law intended to limit what presidents could impose by last-minute executive actions. Other regulations may eventually stand or fall as the courts rule. The stakes are high, particularly for regulations affecting the production of oil and gas from shale by means of hydraulic fracturing and horizontal drilling.

Energy independence was a touchstone of Mr. Trump's candidacy. Despite his campaign's focus on coal, it is fracking, as hydraulic fracturing is more commonly known, that holds the key to achieving that goal in the foreseeable future. It has been the main driver of the growth in US energy production since 2010.

The latest long-term forecast from the US Energy Information Administration (EIA) puts energy independence within reach--in the sense of the US becoming a net exporter of energy--by 2026 or sooner. However, the recent flurry of regulations affecting such things as drilling on federal land, and putting large portions of US waters off-limits for offshore drilling would not have been part of that projection. As EIA Administrator Adam Sieminski remarked at a briefing on the forecast, "If you had policy that changed relative to hydraulic fracturing, it would make a big, big difference to everything that's in here."

That's a key point, because most past notions of energy independence assumed that energy prices would have to be very high to promote lots of efficiency and conservation and stimulate large amounts of expensive new supply. The shale revolution changed that.

However, the global context is also changing. OPEC is attempting to reassert its control over the oil market, with help from non-OPEC countries like Russia. Two years of low oil prices shrank global oil and gas investment budgets by around a trillion dollars, and the International Energy Agency has warned of coming oil price spikes as a result. Forestalling tighter US regulations on fracking and offshore drilling increases the chances that US supplies could grow by enough to balance shortfalls elsewhere and avert much higher prices at the gas pump.

Energy infrastructure is likely to be another focus of the new administration, because the economic and competitive benefits of abundant energy will be diluted if, for example, Marcellus and Utica shale gas or Bakken and Permian Basin shale oil have to be exported because domestic customers don't have access to them.

That suggests an early effort to reverse decisions by the current administration to block the construction of various pipelines, starting with the Keystone XL pipeline and more recently the Dakota Access Pipeline. That will force new confrontations with activists and environmental organizations that have raised their game to a new level in the last eight years.

Such opposition would likely intensify if the new administration sought to withdraw the US from the Paris climate agreement, which recently went into effect, or submitted it for review by the US Senate as a treaty. But it's not clear that a big change in direction would require leaving Paris.

The US commitments at Paris, like those of the other signatories, were voluntary and non-binding. For that matter, recent shifts in US energy consumption and especially electricity generation have put the US in a good position to meet its initial Paris goals with little or no additional effort, as noted by outgoing Energy Secretary Moniz. The Paris Agreement will only become a major point of contention if President Trump chooses to make it one.

In his list of the top energy stories of 2016, fellow blogger Robert Rapier rated the election of Donald Trump ahead of the OPEC deal and many other important events of the year, based on its likely impact on "every segment of the US energy industry." In retrospect that was equally true of Barack Obama's election in 2008. The shift we are about to experience on energy will be that much sharper, because President Obama and President-Elect Trump both set out to make big changes to the status quo for energy, in opposite directions. We shouldn't miss one important difference, however.

The course that Barack Obama's administration followed on energy was largely predictable from the start, because it was based on openly and deeply held beliefs about energy and the environment. Donald Trump's well-known preference for deals over dogma sets up the prospect of some big surprises, in addition to what we can already anticipate.

Don't Book Your Solar-Powered Flight Yet

• An around-the-world flight by a solar-powered airplane is a remarkable achievement, but it does not signal that solar passenger planes are the next big thing.
• Compared to other options, solar's low energy density makes it an especially challenging pathway for pursuing large cuts in the emissions from aircraft.

Earlier this week the pioneering solar-powered airplane, Solar Impulse 2, completed its record-setting circumnavigation of the Earth, returning to Abu Dhabi. Just a few hours earlier, the US Environmental Protection Agency announced its intention to regulate greenhouse gas emissions from aircraft engines under the Clean Air Act. Over the last dozen years I have written numerous posts linking stories like these together, but this is one case in which I sincerely hope these events were entirely unrelated. That requires a bit of explanation.

Let's start by acknowledging the engineering talent and sheer courage involved in the flight of the Solar Impulse 2 (Si2). The aircrew and designers deserve all the kudos they will receive; they have earned a place in aviation history. However, notwithstanding the prediction of pilot Bertrand Piccard that, "within 10 years, electric aircraft could be carrying up to 50 passengers on short to medium-haul flights," I am skeptical that this project will be the forerunner of solar-powered commercial flight in the way that Charles Lindbergh's transatlantic flight in 1927 led to the first non-stop commercial flight across the Atlantic in 1938.

There's no anti-solar bias involved in that statement, just an appreciation of the constraints that physics and geometry (e.g., the "square-cube law") impose on the amount of solar energy an aircraft can harvest during flight with anything like current technology. Energy density is an essential factor in the economics of commercial air travel.

According to the website for the Si2, the aircraft is approximately "the size of a 747 with the weight of a car." That should be our first hint that scaling up to the performance and capacity of today's jets would be an even bigger challenge than the one these folks have just completed. During the course of its journey, which entailed over 500 hours of flight spread across 17 months, the Si2 collected and consumed electrical energy equivalent to a little over 300 gallons of kerosene-based jet fuel. By comparison, a Boeing 777, which is capable of carrying up to 400 people, burns an average of around 2,000 gallons of jet fuel per hour.

If you covered a 777's wings with the same 22%-efficient SunPower solar cells used by the Si2, they would generate the fuel-equivalent of less than 3 gallons per hour at noon on a cloudless day. Even allowing for the higher efficiency of electric motors compared to gas turbines, that is still orders of magnitude less than the energy necessary to push a fully-loaded jetliner through the sky at 550 miles per hour. (The Si2 averaged 47 mph.)

As the Financial Times reported, the near-term applications of solar-powered flight are likely limited to surveillance drones and other specialized platforms for which long-range fuel-free flight confers a big advantage. I could also envision lightweight, high-efficiency solar cells being used on next-generation commercial aircraft to provide auxiliary (non-motive) power, saving both fuel and emissions.

That brings me back to the EPA. The agency's stated rationale for targeting aircraft engines now is that they expect these emissions to increase in the future, and that reductions would lead to climate and health benefits. There's no mention of solar-powered aircraft, and I must trust that had nothing to do with their announcement.

The EPA's latest greenhouse gas inventory reported that in 2014 commercial and other aircraft accounted for 8% of US transportation-related emissions, and about 2% of all US emissions of CO2 and other greenhouse gases. It also showed that aviation emissions have fallen 22% since 2005.

Perhaps the growth they are worried about is proportional, rather than absolute, as emissions from electricity generation and other sources decline faster. However, compared to cars and light trucks that account for over 60% of emissions from transportation, and for which many emission-reduction options are available, aviation is a small and rather challenging focus for further reductions.  Those will likely rely on advanced biofuels, along with additional gains in turbine efficiency and airframe weight reduction. 

The website for Solar Impulse 2 acknowledges that its flight was intended to highlight the earth-bound applications of renewable energy: "Behind Solar Impulse’s achievements, there is always the same goal: show that if an airplane can fly several days and nights in a row with no fuel, then clean technologies can be used on the ground to reduce our energy consumption, and create profit and jobs." Solar-powered air travel for the masses seems pretty far off, and certainly not something we can count on for cutting our emissions. 

Out of Reach Without Nuclear and Shale

• US emissions reduction goals for 2025 could not be achieved without nuclear power and the fracking technology necessary to extract shale gas. 
• Recent revisions by the EPA in its estimates of methane leaks from natural gas production and use do not negate the benefits of gas in reducing emissions.

In its lead editorial yesterday, the Washington Post took presidential candidate Bernie Sanders to task for his attacks on nuclear power and natural gas. The Post focused its critique on greenhouse gas emissions and the emissions trade-offs involved in substituting one form of energy for another. That speaks directly to one of the main reasons that Mr. Sanders' argument resonates with his supporters, but it ignores an even more basic problem. The energy contribution from shale and nuclear power is so large that if our goal is a reliable, low-emission energy mix that meets the future energy needs of the US economy, we simply cannot get there without them, at least not in any reasonable timeframe.

The pie chart below shows the current sources of US electricity in terms of the energy they generate, rather than their rated capacity. This is an important distinction, because the renewable electricity technologies that have been growing so rapidly--wind and solar--are variable and/or cyclical, generating only a fraction of their rated output over the course of any week, month, or year.

For example, replacing the output of a 2,000 megawatt (MW) nuclear power plant such as the Indian Point facility just north of New York City would require, not 2,000 MW of wind and solar power, but between 7,600 MW and 9,400 MW, based on the applicable capacity factors for such installations. Now scale that up to the whole country. With 99 nuclear reactors in operation, rated at a combined 98,700 MW, it would take at least 375,000 MW of new wind and solar power to displace them. As the Post's editorial points out, money spent replacing already zero-emission energy is money not spent replacing high-emitting sources.

At the rates at which wind and solar capacity were added last year, that build-out would require 24 years. That's in addition to the 36 years it would take to replace the current contribution of coal-fired power generation. It also ignores the fact that intermittent renewables require either expensive energy storage or fast-reacting backup generation to provide 24/7 reliability.

That brings us to natural gas, the main provider of back-up power for renewables, and the "fracking" (hydraulic fracturing) technology that accounts for half of US natural gas production. Fracking has transformed the US energy industry so dramatically that it is very hard to gauge the consequences of a national ban on it, even if such a policy could be enacted. Would natural gas production fall by a third to its level in 2005, when shale gas made up only around 5% of US supply, and would imports of LNG and pipeline gas from Canada ramp back up, correspondingly?

Or would production fall even farther? After all, one of the main factors behind the rapid growth of shale gas in the previous decade is that US conventional gas opportunities in places like the Gulf of Mexico were becoming scarcer and more expensive to develop than shale, which was higher-cost then than today. Either way, the constrained supply of affordable natural gas under a fracking ban would not support generating a third of US electricity from gas, vs. 20% in 2006. So we would either need even more renewables and storage--in addition to those displacing nuclear power--or, as Germany has found in pursuit of its phase-out of nuclear power, a substantial contribution from coal.

One of the primary reasons cited by Mr. Sanders and others for their opposition to shale gas, aside from overstated claims about water impacts, is the risk to the climate from associated methane leaks. Here he would seem to have some support from the US Environmental Protection Agency, which recently raised its estimates of methane leakage from natural gas systems.

Methane is a much more powerful greenhouse gas than carbon dioxide (CO2), so this is a source of serious concern. However, a detailed look at the updated EPA data does not support the contention of shale's critics that natural gas is ultimately as bad or worse for the climate than coal, a notion that has been strongly refuted by other studies.

The oil and gas industry has questioned the basis of the EPA's revisions, but for purposes of discussion let's assume that their new figures are more accurate than last year's EPA estimate, which showed US methane emissions from natural gas systems having fallen by 11% since 2005. On the new basis, the EPA estimates that in 2014 gas-related methane emissions were 20 million CO2-equivalent metric tons higher than their 2013 level on the old basis, for a year-on-year increase of more than 12%. This upward revision is nearly offset by the 15 million ton drop in methane emissions from coal mining since 2009, which was largely attributable to gas displacing coal in power generation.

In any case, the new data shows gas-related emissions essentially unchanged since 2005, despite the 44% increase in US natural gas production over that period. The key comparison is that the EPA's entire, updated estimate of methane emissions from natural gas in 2014, on a CO2-equivalent basis, is just 2.5% of total US greenhouse gas emission that year. In particular, it equates to less than half of the 360 million ton per year reduction in emissions from fossil fuel combustion in electric power generation since 2005--a reduction well over half of which the US Energy Information Administration attributed to the shift from gas to coal.

In other words, from the perspective of the greenhouse gas emissions of the entire US economy, our increased reliance on natural gas for power generation cannot be making matters worse, rather than better. That's a good thing, because as I've shown above, we simply can't install enough renewables, fast enough, to replace coal, nuclear power and shale gas at the same time.

What does all this tell us? Fundamentally, Mr. Sanders and others advocating that the US abandon both nuclear power and shale gas are mistaken or misinformed. We are many years away from being able to rely entirely on renewable energy sources and energy efficiency to run our economy. In the meantime, nuclear and shale are essential for the continuing decarbonization of US electricity, which is the linchpin of the plans behind the administration's pledge at last December's Paris Climate Conference to reduce US greenhouse gas emissions by 26-28% by 2025. That goal would be out of reach without them.

The Fallout from Volkswagen's "Defeat Device"

• The repercussions from VW's error in judgment seem likely to extend beyond the hit to their reputation and stock price, and the unnecessary extra pollution from these cars.
• This incident will make a useful, fuel-saving alternative to gasoline cars less attractive, at least for now, resulting in higher future oil consumption and CO2 emissions.

I find the revelations concerning Volkswagen's reported efforts to circumvent vehicle emissions rules disturbing, especially as a VW owner and someone who has advocated diesel technology as a tool for reducing oil consumption and greenhouse gas emissions. VW has apparently admitted its colossal error. However, I haven't seen anyone attempt to explore the implicit emissions tradeoffs involved. As bad as this decision was, did it at least, on balance, help the environment?

The details that have emerged so far have focused on a software routine that manipulated diesel engine performance to produce one level of emissions in regulatory testing, presumably on a dynamometer, and different, much less acceptable results in real-world driving. Aside from the obvious questions about ethics and compliance, what did this mean for actual emissions?

For many years regulators have been tightening restrictions on allowable emissions of so-called criteria pollutants from cars. These include oxides of sulfur and nitrogen, particulates, and hydrocarbons, but not CO2. A whole gamut of technology was developed to tackle these pollutants, starting with catalytic converters on cars and deep desulfurization of fuels in refineries. Today's cars are much cleaner than those of a generation ago.

Oxides of nitrogen, referred to as NOx, are combustion byproducts that don't originate in a car's fuel, but from the nitrogen and oxygen in the air in which it is burned. NOx emissions from diesel engines have always been challenging, because they operate at higher temperatures and compression ratios than gasoline engines. Manufacturers that produce diesel vehicles have deployed different technologies to control NOx. As far as I know the VW Group uses at least two, depending on model.

Larger (and more expensive) vehicles appear to use a process called Selective Catalytic Reduction (SCR), in which small amounts of a liquid chemical such as urea chemically react with the NOx. The liquid must be refilled at service intervals. The technical manual for VW's 2-liter diesel engine involved in the current fiasco indicates it uses EGR, or exhaust-gas recirculation, which reduces the oxygen in the engine available to form NOx .

If controlling emissions from diesels is so challenging, why bother with them? Well, a typical diesel car uses up to a third less fuel than a comparably equipped gasoline model. After adjusting for the carbon content of the fuels, the lifecycle CO2 emissions are around 20% lower than for gasoline. Given the shortcomings of similarly priced electric vehicles in range and convenience, diesel provides a useful option. That helps explain why roughly half of European cars today are diesels, in many cases promoted by national fuel- and/or engine-tax policies.

That leads us to the question of whether such a reduction in CO2 might be worthwhile, even if it came at a penalty in NOx emissions, which act locally, rather than globally. To arrive at a ballpark answer let's assume that the 482,000 affected diesel cars couldn't have been sold at all if their engine software didn't fool emissions testers, and that the buyers would have otherwise chosen a comparable gasoline car. For comparison, the EPA rated the 2015 Jetta diesel at 36 miles per gallon (mpg) overall, while the 1.8 L turbo gasoline Jetta gets 30 mpg. At an average of 12,000 miles per year each, the collective annual fuel savings of the cars involved would be 32 million gallons, resulting in avoided CO2 emissions of about 300,000 metric tons per year, or 0.005% of US annual CO2 emissions.

If the tradeoff in extra NOx emissions is based on the reported maximum estimate of 40 times the EPA's allowed level of 0.07 grams per mile, then the affected cars would collectively emit an extra 16,000 metric tons of NOx per year. That's roughly 1% of the annual US NOx emissions tracked under the Clean Air Interstate and Acid Rain Program cap-and-trade markets in 2012. Even recognizing that those programs don't count all US NOx pollution, and that NOx and CO2 are very much apples and oranges in their environmental and health impacts, the relative proportions I calculated don't make this seem like a tradeoff worth making.

Whoever made the decision to circumvent the pollution controls on these cars did enormous damage to VW's brand and reputation. Unfortunately, the response in Europe and Asia suggests that this event has also raised questions about the emissions testing and compliance of the entire car fleet. Resolving them will take time and money, and if they are not seen to be dealt with properly, the impact on the public's trust of these processes on both sides--manufacturers and regulators--could be long-lasting.

Unlike in Europe, diesels made up just under 1% of new cars sold in the US last year. However, the technology was finally shedding the poor reputation that low-quality diesel cars earned in the 1980s, and the "take rate" was growing, along with the number of models offered.  VW's diesels are among the most affordable in the market. The NOx reduction technologies they use have been proven to work, when they are not circumvented, but that is not the message that this debacle will leave with the average consumer. Carmakers will have to work harder to convince buyers that this driver-friendly alternative to gasoline cars is worth a look, and that has implications for future oil consumption and CO2 emissions.

EPA's Blown Call on Ethanol

• EPA's proposed revision to renewable fuel quotas achieves the appearance of compromise by cutting non-existent volumes, while still attempting to force more ethanol into the market than consumers seem to want.

Last Friday the US Environmental Protection Agency released its long-awaited proposal for untangling a broken federal Renewable Fuels Standard (RFS). Although it provides all parties with greater certainty, it fails to resolve the regulation's fundamental flaws. This is all the more disappointing for the duration of the wait involved, finalizing 2014's quotas 18 months late and leaving refiners and fuel blenders to operate for the first five months of this year on hints and guesswork about how much ethanol and biodiesel they would be required to sell in 2015.

The proposal meets at least one definition of a compromise, with most affected constituencies apparently disappointed or irate about the result. To someone unfamiliar with the situation, it might even seem that, as ethanol groups claim, the agency has leaned far in the direction of assuaging the concerns of the petroleum refining industry by cutting a total of 11 billion gallons from the 2014-16 quotas for ethanol and other biofuels. However, as EPA's accompanying analysis makes clear, the omitted volumes were unlikely ever to be purchased by end-users, given the decline in US motor fuels consumption since the statutes imposing the RFS were passed in 2005 and 2007. Nor do the facilities yet exist to produce the quantities of cellulosic biofuels that account for the lion's share of the proposed cuts.

EPA's documentation repeatedly cites the "intent of Congress." This seems to refer to the Congressional sessions that bequeathed us this policy, rather than to the current Congress, which is waking up to the fact that the program has largely been superseded by reality. The RFS was designed to address two problems: US fuel scarcity and transportation-sector emissions of greenhouse gases. The former has been overcome mainly thanks to the shale revolution, transforming the US from a net importer of refined petroleum products to the world's largest exporter.

As for automobile-related emissions, they are being managed more effectively by fuel economy improvements and new vehicle technology. The RFS may even be counterproductive in its overall emissions impacts, as noted in a press release from the Environmental Working Group. Nor are emissions the only issue for which crop-based ethanol may be doing more harm than good. Evidence points to periodic impacts on global food prices. It's hard to conclude we could divert 38% of the US corn crop without causing unintended consequences somewhere.

EPA's analysis of the snarl at the core of the existing RFS is perplexing. First it describes how ethanol has effectively reached its maximum possible penetration of the US market for ordinary gasoline containing up to 10% ethanol (E10)--the so-called "blend wall." It goes on to acknowledge that sales of gasoline blends containing up to 15% or 85% ethanol, respectively, remain minuscule relative to total gasoline sales. However, it then ignores these facts and persists in the hope that by continuing to increase its ethanol quota, albeit more slowly, it can convince consumers to embrace fuels for which they had little appetite even when gasoline cost $1 more per gallon than it does today.

As the Washington Post noted, most car manufacturers still warn automobile owners that using gasoline containing more than 10% ethanol could result in engine damage not covered by their warranties. Although I was pleased to see that the car I recently purchased is warranted up to 15% ethanol, I cannot envision buying a single gallon of E15 unless it was priced at a discount to E10 gasoline, reflecting its inherently lower fuel economy and range. As for E85, in only a handful of states does the market discount meet or exceed the fuel's 27% calculated deficit in delivered energy, compared to E10. Is it any wonder that for a decade E85 has failed to take off as envisioned by the EPA and previous Congresses?

The EPA does not have a free hand to rewrite this regulation in any manner it would like, to fit the greatly altered circumstances in which the US now finds itself. The agency may well believe it has gone as far in that direction as it could, although I suspect it could have justified freezing ethanol from all sources at current levels, and allowing cellulosic ethanol gradually to displace corn-based fuel as new facilities come online. However, no adjustments that EPA seems prepared to make can repair a biofuels policy that was fundamentally broken at its inception, due to its inherent contradictions with other policies and consumer preferences.

We have reached the point at which conflicting federal biofuel quotas, emissions regulations, and  chronically weak GDP growth have rendered the original goals of the RFS not just ambitious but unattainable. The EPA has taken its best shot at addressing this and come up short. It is now up to the US Congress and the Administration to work together to fix this mess, before the consequences of inaction put a damper on one of the few bright spots of the current economy.

2014 in Review: Shale Energy's First Price Cycle

2014 was an extraordinary year in energy, vividly illustrating both sides of the Chinese proverb about interesting times. Oil market volatility was the big story for much of the year, with the dominance of geopolitical risks finally yielding to surging supplies. Of the two energy revolutions underway, shale wields the bigger stick for now, while the growth of renewables gathers momentum. All of this has implications for 2015 and beyond.

The US remained the epicenter of the shale revolution this year, with development elsewhere still subject to uncertainties about economic production potential, infrastructure, and the rules of the road. A comparison of oil-equivalent additions to US energy supplies from oil, gas and non-hydro renewables for the first nine months of the year highlights both the significance of shale and the differences in relative scale that impede a rapid shift to renewables.

US shale drilling added over a million barrels per day of "light tight oil" (LTO) production, compared to 2013, based on US Energy Information Administration data for the first nine months of the year. That brings cumulative gains since 2011 to nearly 3 million bbl/day. This hasn't just upended the global oil market; it has also revolutionized the way oil moves across North America. Over a million bbl/day now moves by rail, a figure recently projected to peak at 1.5 million by 2016. Nor is that entirely the result of delays to pipeline projects like Keystone XL. One proposed pipeline for Bakken LTO was reportedly canceled due to a lack of interest from shippers. Rail is expensive but provides producers and refiners with greater flexibility in both volume and destinations than fixed pipelines.

The collapse of oil prices has prompted many producers to reassess drilling plans, although it has been a boon for refiners and consumers.  Refining margins look relatively healthy, at least based on the proxy of "crack spreads", the difference between the wholesale prices of gasoline and diesel and the oil from which they are made. Some refiners also anticipate that low prices will spur demand growth, as described in a fascinating Wall St. Journal interview with Tom O'Malley, who has turned a succession of castoff refineries into profitable businesses. 

We may already be seeing the demand response to lower prices. November US volumes were at a 7-year high, according to API. This is unlikely to be replicated quickly elsewhere, however, for the same reasons that global oil demand was slow to moderate when prices rose over the last several years: In many countries the influence of oil prices on consumer behavior is overwhelmed by fuel taxes or subsidies. With prices now falling, some developing countries are capitalizing on the opportunity to unwind billions of dollars in consumption subsidies, offsetting market drops. That could have important implications for future oil demand and greenhouse gas emissions.

Meanwhile US consumers have watched retail gasoline prices fall by $1.39 per gallon since July and by over a dollar compared to a year ago. If sustained, the effective stimulus could exceed $100 billion annually, ignoring the effect of lower prices for jet fuel, diesel and other products. It's not surprising that half of respondents in last month's Wall St. Journal/NBC poll indicated this was important for their families.

While oil has been making headlines, shale gas without much fanfare added the equivalent of another half-million bbl/day to US production. That explains why despite enormous drawdowns of gas during last winter's "Polar Vortex", gas inventories began this winter much closer to normal levels than was widely expected in the  spring. Gas has lost a little ground in electricity generation to coal in the last two years, but few reading the EPA's proposed Clean Power Plan regulation would expect that trend to continue.

Shale gas remains controversial in some areas due to perceived environmental and community impacts. New York state is apparently making its temporary ban on hydraulic fracturing ("fracking") permanent, preferring to rely on shale gas supplies from neighboring Pennsylvania. Yet while shale drilling in North Dakota has led to an increase in gas flaring--burning off gas that can't economically reach a market--the latest findings from the University of Texas and Environmental Defense Fund measured methane leakage from gas wells at an average of 0.43%. That shrinks gas's emissions footprint and enhances its potential role in climate change mitigation.

Turning to renewables, wind energy now provides a little over 4% of US electricity. However, its growth has slowed due to uncertainty about continued federal subsidies. The wind production tax credit, or PTC, had previously been extended through 2013 in a way that allowed projects brought online later to benefit from the extension. It was just extended again through the end of 2014, along with a broad package of other expiring tax benefits. This late revival might be a gift to a few projects already under construction, but it seems unlikely to spur additional projects without further legislative action in the new Congress.

Solar power has also made great strides, with costs falling rapidly and US additions in 2014 expected to reach 6,500 MW, likely outpacing wind additions. This is happening despite the ongoing trade dispute between the US and China over imported solar modules. Utilities are already experiencing solar's impact on their traditional business model. Yet as important as wind and solar power are likely to be in the future energy mix, their impact in 2014, at least in the US, was still dwarfed by the growth of shale resources. Drilling is already slowing down, however, so renewables could take the lead in 2015 as shale is expected to post smaller gains.

Looking ahead, the global focus on greenhouse gas emissions will increase in the run-up to the Paris climate conference in December.  It remains to be seen whether enough progress was made in the recently completed talks in Lima, Peru, to resolve the significant remaining obstacles to a new global climate agreement. And while oil supply gains trumped geopolitics in 2014, a list of risk hot-spots from the Council on Foreign Relations includes several scenarios with major implications for oil and/or natural gas prices. Meanwhile we can expect the new Congress to take up Keystone XL, oil exports, EPA regulations, and other energy-related issues. I'd bet on another lively year.

A different version of this posting was previously published on the website of Pacific Energy Development Corporation.

How Good Is The New Emissions Deal with China?

• President Obama's emissions deal with China sets an ambitious target for US CO2 cuts while leaving substantial headroom for emissions growth in China. 
• It will likely compound his problems, domestically, but could have significant influence on upcoming international climate negotiations.

Only an event like Tuesday's agreement between President Obama and his Chinese counterpart to limit greenhouse gas emissions (GHG) from the two countries could top the unexpected scramble in the US Senate to pass a Keystone XL pipeline bill as the big energy story of the week. The significance of the climate deal is open to interpretation, from both international and US political perspectives. Before exploring those, we should examine its consequences.

The White House announced that in exchange for the US agreeing to reduce "net greenhouse gas emissions 26-28 percent below 2005 levels by 2025", China would undertake to cap its GHG emissions by "around 2030." It also announced plans to step up a number of cooperative efforts with China in this area, including joint R&D and a jointly funded public/private carbon capture and sequestration (CCS) project in China. What does all this mean in terms of US emissions?

We need to start with the 2012 baseline in which net US emissions were already nearly 11% below 2005 levels. The current Annual Energy Outlook of the US Energy Information Administration (EIA), assuming the laws and regulations in force at the time it was produced, projects that US energy-related CO2 emissions will increase by 236 million metric tons (MT) by 2025, compared to 2012, leaving us at roughly 7% under 2005. Emissions from transportation would shrink, while those from industry would rise as the US economy grows by an expected 2.4% per year.

As I understand it that EIA forecast doesn't include the emissions that the EPA's "Clean Power Plan" for existing power plants would be expected to save if fully implemented. EPA targets reducing CO2 emissions from the US electricity sector--accounting for 39% of net emissions in 2005--by 25% by 2020 and 30% by 2030, compared to 2005. That would shave around 460 million MT from the EIA figure for 2025, getting us to nearly 15% below 2005. The additional savings to reach 26% below 2005 are thus in the neighborhood of 700 million MT per year by 2025. To put that in perspective, it's equivalent to the 2012 CO2 emissions from combustion in the entire US industrial sector, and exceeds total emissions of methane from all sectors, including agriculture, oil & gas, and landfills.

So unless I've done my sums wrong, or misinterpreted the government's data, the US/China deal commits to reducing US emissions by as much again as we've cut since 2005--largely as a result of a weaker economy and the shale gas revolution--after banking the expected savings from the 2011 fuel economy regulations, energy efficiency programs and renewable energy incentives, and an EPA plan for the power sector that is certain to run into strong opposition in the new Congress. That seems pretty ambitious to me, although it falls short of the 40% reduction recently agreed by the EU for 2030.

It's harder to assess what China's side of the deal means in practical terms. Its 2012 emissions were estimated at nearly 10 billion MT/yr, having grown by 8%/yr since 2004 and by 6%/yr since 2009. At that rate, even if its emissions peaked in 2030, they could double before starting to decline. If China's emissions growth declined to just 2% per year, consistent with the lower rates of growth in coal consumption observed recently, by 2030 it could still add nearly 4 billion MT/yr--equivalent to the current emissions of the entire EU, and 5 times the incremental US cuts to which President Obama just agreed. The most recent projection of China's emissions from the EIA had them growing by 5 billion MT by 2030 but essentially plateauing thereafter.

This falls substantially short of what would be required to keep global emissions within the range that climate models predict would limit average global temperature increases to 2°C, compared to pre-industrial levels. However, it goes well beyond China's previous commitment on emissions intensity at Copenhagen in 2009.

Now consider how this deal looks from the standpoint of US politics. Voters just resoundingly handed undivided control of the legislative branch of government to the President's opposition. Republican office-holders and those who just voted for them are likely to regard it as an unwelcome commitment of the US by a lame-duck President to a promise that only his successors could fulfill. In the process, it hands China and other countries a point with which to prod future US administrations should they fall short of its goals. In exchange, he got President Xi Jinping to admit that China can't emit CO2 limitlessly, but can still do more or less what it may have been planning, anyway. It's hard to see this making things easier in Congress for the President's existing environmental agenda.

The deal looks better from the perspective of international environmental and climate policy circles in the lead-up to the Paris climate conference, "COP21", at the end of 2015. One lesson from the Kyoto Protocol is that to be meaningful a global climate agreement must have a strong commitment from the world's largest emitters of CO2 and other GHGs. China and the US are the two biggest emitters, and the EU at #3 is effectively pre-committed. Together these three blocs account for over half of all emissions today. Having them on-side at the start raises the chances of reaching a  big agreement.

As others have observed, this deal makes it harder to argue against a global CO2 agreement based on China's relative inaction, while increasing pressure on other developing countries to agree to limit their own emissions. It also signals that despite political weakness at home, the White House will likely push for aggressive targets at COP21, setting up further conflict with Congress in the next election year. Finally, its timing is early enough to influence the negotiations but not so early as to permit close scrutiny of Chinese or US follow-through on its goals before the Paris talks begin.

EPA's CO2 Rule and the Back Door to Cap & Trade

• Significant differences in EPA's proposed state CO2 targets for the power sector are reviving interest in cap & trade as a way to reduce compliance costs.
• This compounds the EPA plan's controversy and raises serious concerns about how the resulting revenue would be used.

Earlier this month the US Environmental Protection Agency released for comment its proposal for regulating the CO2 emissions from existing power plants. It follows EPA’s emissions rule for new power plants published late last year but takes a different, more expansive approach.  If implemented, the “Clean Power Plan” would reduce US emissions in the utility sector by around 25% by 2020 and 30% by 2030.

One of its most surprising features is that instead of setting emissions standards for each type of power plant or mandating a single, across-the-board emissions-reduction percentage, it imposes distinct emissions targets on each state. Based on analysis by Bloomberg New Energy Finance, some states could actually increase emissions, while others would be required to make deep cuts. The resulting disparities have apparently triggered new interest in state and regional emissions trading as a means of managing the rule’s cost.

Although emissions trading has become more controversial in recent years, it proved its worth in holding down the cost of implementing previous environmental regulations, such as the effort to reduce sulfur pollution associated with acid rain. It works by enabling facilities or companies with lower-than-average abatement costs to profit from maximizing their reductions and then selling their excess reductions to others with higher costs. The desired overall reductions are thus achieved at a lower cost to the economy than if each company or facility were required to reduce its emissions by the same amount.

Although the Clean Power Plan doesn’t require that states establish such emissions trading markets, its lengthy preamble includes a discussion of existing state greenhouse gas “cap-and-trade” markets in California and the Northeast. It also points out that measures to comply with the new rule may generate benefits in the markets for conventional pollutants, including those for the recent cross-state pollution rule. Administrator McCarthy also mentioned the benefits of multi-state markets in her speech announcing the new rule.

A patchwork of cap and trade markets across the US, including the addition of new states to mechanisms like the Regional Greenhouse Gas Initiative (RGGI), might help mitigate some of the cost of complying with 50 different CO2 targets. However, it would still be a far cry from the kind of economy-wide, comprehensive CO2 cap-and-trade system once contemplated by the US Congress.

Cap and trade was an idea that had gained significant momentum and even begun to appear inevitable, prior to the onset of the financial crisis in 2008. To supporters, it looked like a better way to limit and eventually cut greenhouse gas emissions than through command-and-control regulations. And the price it would establish for emissions would be based on the cost of achieving a desired level of reductions, rather than being set arbitrarily, as a carbon tax would be, without any guarantee of actual emissions reductions. Opponents viewed it as an unnecessary or unnecessarily complicated drag on the economy and a tax by another name, coining the pejorative term “cap-and-tax”.

Although early US cap-and-trade bills were bipartisan, including one co-sponsored by Senator McCain, the 2008 Republican Presidential nominee, the debate over cap and trade took on an increasingly partisan tone in a period of widening polarization on most major issues. The Waxman-Markey climate bill, with cap and trade as a major provision, was narrowly passed when Democrats controlled the House of Representatives in 2009, but various Senate versions failed to attract sufficient support, even when Democrats held a filibuster-proof supermajority in that body. The chances of enacting cap and trade legislation effectively died when a Republican won the vacant Senate seat for Massachusetts in January 2010. However, viewing this as a purely partisan divide is simplistic, at best.

Aside from opposition by key Senate Democrats, including one whose campaign included a vivid demonstration of his stand against Waxman-Markey, the versions of “cap and trade” debated in 2009 and 2010 bore little resemblance to the original idea. Waxman-Markey was a 1400-page monstrosity, laden with extraneous provisions and pork. Its embedded allocation of free allowances strongly favored the same electricity sector now being targeted by EPA’s Clean Power Plan, at the expense of transportation energy, for which low-carbon options remain fewer and more costly. It would have created a de facto gasoline tax, while yielding fewer net emissions reductions than a system with a level playing field. Subsequent bills, such as the Kerry-Lieberman bill in 2010, took this a step farther, removing transportation fuels from cap and trade and effectively taxing them at a rate based on the price of emissions credits.

Along the way, national CO2 cap-and-trade legislation evolved from a fairly straightforward way to harness market forces to deliver the cheapest emissions cuts available, to a mechanism for raising and redistributing large sums of money outside the tax code. In some cases that would have been done directly, such as in the gratifyingly brief Cantwell-Collins “cap-and-dividend” bill, or as indirectly and inefficiently as in Waxman-Markey. It’s no wonder the whole idea became toxic at the federal level.

Although emissions trading for greenhouse gas reduction came up short in the US Congress, it took hold elsewhere. The EU’s Emissions Trading System (ETS) is an outgrowth of the Kyoto Protocol’s emissions trading mechanism, which was included largely at the urging of the US delegation to the Kyoto climate conference in 1997. The ETS is focused on the industrial and power sectors and covers 43% of EU emissions. It has experienced significant ups and downs over the sale and allocation of emissions credits.

Cap and trade also emerged as a preferred approach for some US states seeking to reduce their emissions. California’s emissions market was established via a provision of the 2006 Climate Solutions Act (A.B. 32), and RGGI currently facilitates trading among 9 mostly northeastern states. The relatively low prices of emissions allowances in these systems–particularly in RGGI, which has traded in the range of $3-$5/ton of CO2–suggests that they may still be capturing low-hanging fruit in the early phases of steadily declining emissions caps. Their effectiveness at facilitating future low-cost emissions cuts is hard to gauge, because they also don’t exist in a vacuum.

Except for Vermont, all of the states involved have renewable electricity mandates that by their nature deliver more prescriptive emissions cuts. These markets have also been implemented in a generally weak US economy, which has constrained energy demand, and against the backdrop of the shale revolution, which has yielded significant non-mandated emissions reductions. Nor have these state and regional approaches to cap and trade entirely avoided the debates over how to spend their substantial proceeds that plagued federal cap-and-trade legislation.

For many years my view of cap and trade was that if we needed to put a price on GHG emissions, this was a better, more efficient option than an arbitrary carbon tax, or other top-down method. My experience analyzing more recent “cap-and-trade” legislation left me with serious doubts about our ability to implement a fair and effective national cap-and-trade market for CO2 and other greenhouse gases within the current political environment. Whether on a unified basis or in aggregate across many smaller systems, the enormous sums it could eventually generate are simply too tempting to expect our legislators and government agencies to administer even-handedly.

Whatever its potential benefits and pitfalls, I can’t help seeing cap and trade as a distraction in the context of the EPA’s proposed Clean Power Plan. Even at its most efficient, cap and trade couldn’t render painless the wide disparities of a plan that would require Arizona to cut emissions per megawatt-hour by more than half, and states like Texas and Oklahoma to cut by 36-38%, while Kansas, Kentucky, Missouri, Montana and even California cut by less than a quarter–and under some scenarios might even increase their overall emissions. Cap and trade would merely be a footnote on the scale of transformation the EPA’s plan envisions for the US electricity sector.

A different version of this posting was previously published on Energy Trends Insider.

EPA's New CO2 Rules Create Opportunities for Natural Gas, for Now

• EPA's proposed rule for reducing CO2 emissions from power plants could increase natural gas demand in the utility sector by as much as 50%, at the expense of coal.
• Cutting emissions by regulation rather than legislation entails legal and political uncertainties that could hamper the investment necessary to meet EPA's targets.

Earlier this month the Environmental Protection Agency announced its proposal for regulating the greenhouse gas emissions from all currently operating US power plants. Unsurprisingly, initial assessments suggested it favors the renewable energy, energy efficiency and nuclear power industries--and especially natural gas--all at the expense of coal. However, the longer-term outcome is subject to significant uncertainties, because of the way this policy is being implemented.

EPA's proposed "Clean Power Plan" regulation would reduce CO2 emissions from the US electric power sector by 25% by 2020 and 30% by 2030, compared to 2005. Although it does not specify that the annual reduction of over 700 million metric tons of CO2--half of which had already been achieved by 2012--must all come from coal-burning power plants, such plants accounted for 75% of 2012 emissions from power generation.

It's worth recalling how we got here. In the last decade the US Congress made several attempts to enact comprehensive climate legislation, based on an economy-wide cap on CO2 and a system of trading emissions allowances: "cap and trade." In 2009 the House of Representatives passed the Waxman-Markey bill, with its rather distorted version of cap and trade. It died in the US Senate, where the President's party briefly held a filibuster-proof supermajority.

The Clean Power Plan is the culmination of the administration's efforts to regulate the major CO2 sources in the US economy, in the absence of comprehensive climate legislation. Although Administrator McCarthy touted the flexibility of the plan in her enthusiastic rollout speech and suggested that its implementation might include state or regional cap and trade markets for emissions, the net result will look very different than an economy-wide approach.

For starters, there won't be a cap on overall emissions, but rather a set of state-level performance targets for emissions per megawatt-hour generated in 2020 and 2030. If electricity demand grew 29% by 2040, as recently forecast by the Energy Information Administration of the US Department of Energy, the CO2 savings in the EPA plan might even be largely negated. EPA is banking on the widespread adoption of energy efficiency measures to avoid such an outcome.

Since we have many technologies for generating electricity, with varying emissions all the way down to nearly zero, many different future generating mixes could achieve the plan's goals, though not at equal cost or reliability. Ironically, since coal's share of power generation has declined from 50%  in 2005 to 39% as of last year, it could be done by replacing all the older coal-fired power plants in the US with state of the art plants using either ultra-supercritical pulverized coal combustion (USC ) or integrated gasification combined cycle (IGCC). 

That won't happen for a variety of reasons, not least of which is EPA's "New Source Performance Standards" published last November. That rule effectively requires new coal-fired power plants to emit around a third less CO2 than today's most efficient coal plant designs. That's only possibly if they capture and sequester (CCS) at least some of their emissions, a feature found in only a couple of power plants now under construction globally.

It's also questionable how the capital required to upgrade the entire US coal generating fleet could be raised. Returns on such facilities have fallen, due to competition from shale gas and from renewables like wind power with very low marginal costs--sometimes negative after factoring in tax credits. Some are interpreting EPA's aggressive CO2 target for 2020 and relatively milder 2030 step as an indication that the latter target could be made much more stringent, later.

So while coal is likely to remain an important  part of the US power mix in 2030, as the EPA's administrator noted, meeting these goals in the real world will likely entail a significant shift from coal to gas and renewable energy sources, while preserving roughly the current nuclear generating fleet, including those units now under construction.

If the entire burden of the shift fell to gas, it would entail increasing the utilization of existing natural gas combined cycle power plants (NGCC) and likely building new units in some states. In the documentation of its draft rules, EPA cited average 2012 NGCC utilization of 46%. Increasing utilization up to 75% would deliver over 600 million additional MWh from gas annually--a 56% increase over total 2013 gas-fired generation, exceeding the output of all US renewables last year--at an emissions reduction of around 340 million metric tons vs. coal. That would be just sufficient to meet the 30% emissions reduction target for the electricity demand and generating mix we had in 2013.

The incremental natural gas required to produce this extra power works out to about 4.4 trillion cubic feet (TCF) per year. That would increase gas consumption in the power sector by just over half, compared to 2013, and boost total US gas demand by 17%. To put that in perspective, US dry natural gas production has grown by 4.1 TCF/y since 2008.

EPA apparently anticipates power sector gas consumption increasing by just 1.2 TCF/y by 2020, and falling thereafter as end-use efficiency improves.  Fuel-switching is only one of the four Best System of Emission Reduction "building blocks" EPA envisions states using, including efficiency improvements at existing power plants, increased penetration of renewable generation, and demand-side efficiency measures. The ultimate mix will vary by state and be influenced by changes in gas, coal and power prices.

I mentioned uncertainties at the beginning of this post. Aside from the inevitable legal challenges to EPA's regulation of power plant CO2 under the 1990 Clean Air Act, its imposition by executive authority, rather than legislation, leaves future administrations free to strengthen, weaken, or even abandon this approach.

Since EPA's planned emission reductions from the power sector are large on a national scale (10% of total US 2005 emissions) but still small on a global scale (2% of 2013 world emissions) their long-term political sustainability may depend on the extent to which they succeed in prompting the large developing countries to follow suit in reducing their growing emissions.

A different version of this posting was previously published on the website of Pacific Energy Development Corporation.