Must Virginia Play the Victim of EPA’s Clean Power Plan Rule?


    Dominion, and the Virginia politicians who worship it, have an explanation for their support of the utility’s bill to deregulate itself.  Our state, they say, is being unfairly targeted by EPA’s proposed Clean Power Plan rule because Virginia was assigned higher carbon dioxide reduction targets than some neighboring states.  

    It’s one of those claims that, while superficially true, conceals many more important truths – like the following three:

    1) The EPA rule is still only a proposal.  Legally speaking, there is no EPA rule yet, so why on Earth would we need to defend ourselves against something the details of which are almost certain to change?  

    The way Federal regulatory processes work, the proposal goes out for comment, EPA has to review and respond to every comment and revise the final rule accordingly.  And considering that EPA received over 2 million comments, nobody knows what the heck the final rule will look like.  Much of the current bellyaching, then, is really about working the referee – to get EPA to change the final rule, rather than responding in any serious way to it.  

    2) Numerous states have more aggressive proposed goals than Virginia – yet the ones with the lowest goals are complaining the most. The Georgetown Climate Center has superb resources on EPA’s Clean Power Plan, including a factsheet showing all the state CO2 goals and how they were derived.  Bottom line per this analysis of the proposal is that 15 states have percentage CO2 reductions that are either more stringent than or equal to Virginia’s.  So no, we are not the scapegoat here.

    But here’s the funny part – some of the states with the toughest goals proposed by EPA, like Oregon, Washington and California, are among those who’ve written letters to EPA in support of the plan. Meanwhile, some of the states with the weakest proposed goals, like Alabama, Wyoming and Kentucky, are among those suing EPA to stop the rule.

    Why the role reversal?  EPA computes goals for states based on estimates of the extent to which states can reduce their carbon emissions feasibly and cost-effectively.  Some of the poorer, most coal-dependent states thus got off with easier goals – but, as many of these states are governed by Republicans receiving millions from fossil fuel barons, they are also the most likely to howl about any regulations that might hurt their donors.  

    Meanwhile, it’s largely the states that have done the most to reduce their greenhouse gas emissions that understand the value of doing so, not just for the sake of future generations, but for their state’s economic health and competitiveness as well.  They want a piece of the clean energy industry and jobs that would otherwise disappear to places like Germany and China, while the rest of us remain stuck on 19th century fuels like coal.

    Ultimately, Virginia needs to decide – do we want to be more like Oregon or Alabama?

    3) EPA’s rule represents an opportunity, not a burden: Ever since EPA was formed 45 years ago, industries have been whining that environmental regulations would bankrupt them and destroy the country.  Instead, we have a U.S. economy that continues to grow even as we boast some of the cleanest environmental conditions in the world.

    With the latest proposed rule, the bitching and moaning continues – but in this case, even more unfairly than usual.  This proposal provides incredible flexibility to states to choose the strategies that make the most sense to them.  

    The proposal is built around four “building blocks” for states to apply:

    1) Improving the efficiency of power plants;

    2) Switching coal-fired plants to natural gas;

    3) Adding more renewable and/or nuclear generation; and

    4) Increasing end user energy efficiency.

    All of these approaches will make Virginia more economically efficient and better equipped to (finally) enter the 21st century.  We can put together the strategy that best meets our goals and capabilities.  Instead of fighting a defensive action against the EPA, why not seize the moment to start building our future?

    It would be unfair to say that Dominion has done nothing to date.  The Georgetown Climate Center analysis for Virginia shows that we have significantly outpaced the national average for retooling coal-fired power plants to use natural gas, and are also above average in our use of nuclear energy.  

    But when it comes to developing solar and wind resources, we are massively far behind – 34th out of the 50 states by some rankings.  The same is true on energy efficiency policies, for which we have been ranked a dismal 35th.

    So many opportunities, if we only had more leaders with a little vision, insight and courage. Virginia doesn’t need to play EPA’s victim – why not play the climate and energy hero instead?

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