The Obama administration’s Clean Power Plan is a dangerously flawed proposal that opens the door to a proliferation of new natural gas power plants, while doing little to nothing to close the door on natural gas production in states like Pennsylvania. Although the problems with the plan do not stop there, the focus of this letter is the plan’s reliance on natural gas. The need for a truly Clean Power Plan has never been greater. The current plan isn’t the plan we need and that’s why the undersigned organizations are calling on you to go beyond what the plan, as proposed, allows. We are calling on you to develop a compliance plan for Pennsylvania that includes a commitment to no new natural gas wells, no new natural gas infrastructure, and no new natural gas power plants.
The intent to place natural gas at the center of the PA Clean Power Plan has been revealed. In a recent op-ed in The Morning Call, J. Winston Porter, a national energy and environment consultant and a former EPA assistant administrator wrote, “Also, keep in mind that President Obama's proposed Clean Power Plan requires a 32 per cent reduction of carbon emissions from the nation's power plants by 2030. To have any chance to meet this goal America will need to depend primarily on natural gas, much of which is produced in Pennsylvania by hydraulic fracturing, or fracking.”[i]
The Pennsylvania PUC’s Electric Power Outlook from 2015 says, “Proposed new generating plants and increased capacity of existing plants in Pennsylvania total 14,015 MW.. . . Natural gas projects make up more than 10,307 MW of this queued capacity. This additional capacity may be used to serve Pennsylvania or out-of-state customers.”[ii]
Both statements make clear that natural gas is considered to be central to the success of the Clean Power Plan and is firmly rooted in state planning. Both suggest that Pennsylvania could provide electric capacity beyond its borders, capacity achieved by continued fracking. Choosing that path will have devastating consequences for Pennsylvania and for the planet.
The Clean Power Plan is seriously flawed in its reliance on natural gas; specifically two loopholes undermine its stated intent to create clean energy. Any plant approved after January 2014 may be exempt from the Plan (meaning exempt from Clean Air Act revisions.). More than forty plants have already been approved by the Department of Environmental Protection since January 2014, meaning that they can be exempt at the state’s discretion. Another loophole automatically exempts small power plants of 25 megawatts or less . More than a dozen of such small plants are among those approved.
Natural gas is a dirty fossil fuel, not clean energy. More natural gas power plants means more drilling, more pipelines, and more gas processing. A transition from one climate-killer, such as coal, to another will profoundly impact communities that already are being harmed by drilling and infrastructure. However, the Clean Power Plan also fails to limit fossil fuel development such as coal mining and gas extraction for other purposes, like export. That means the devastation caused by coal, oil, and gas development here in Pennsylvania will continue regardless of the Clean Power Plan. Fossil fuel production, and especially natural gas, will define Pennsylvania’s energy future.
The Clean Power Plan does not address the role of methane in warming the atmosphere. The role methane plays was misunderstood for a long time, but that has changed in recent years as the Intergovernmental Panel on Climate Change has dramatically raised the Global Warming Potential of methane in relation to that of Carbon Dioxide in the all-important twenty year time scale necessary to avert the worst of climate impacts from global warming. Technologies for very accurately measuring methane leakage rates have emerged and we now know that natural gas is dirtier than coal and oil, not because of how it burns as a fuel, but because of just how much methane is making it into our atmosphere, causing the climate to warm at a greater pace.
Published this spring, the EPA’s report on the greenhouse gas inventory found that methane pollution is 34% higher than previously reported and that oil & gas is the single largest source of methane pollution in the U.S., not the largest industrial source, as it had been classified other years, but the largest source. Period. However, this is a very conservative estimate because the hundreds of thousands of leaking orphaned and abandoned wells are not included in the inventory, according to the report.[iii]
Governor Wolf, we are now in what is being referred to as ‘decade zero’, the last chance we’ve got to get a handle on climate change. It is encouraging that the Obama administration took the unprecedented step of developing a Clean Power Plan, but, at its best, it isn’t nearly aggressive enough. At its worst, it is a death sentence for the planet. If it is implemented as written, then we can only rely on you to be the climate leader you must be at this critical juncture and do better, much better, than the plan requires. Your actions will determine Pennsylvania’s future and the planet’s, and will be your legacy.
Respectfully,Pennsylvanians Against Fracking
[i] http://www.mcall.com/opinion/yourview/mc-fracking-benefits-porter-yv--20160725-story.html[ii] http://www.puc.state.pa.us/General/publications_reports/pdf/EPO_2015.pdf[iii] https://www3.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2016-Main-Text.pdf