The Skywriter

The bad grandfather: Lessons from the Clean Air Act


The bad grandfather: Lessons from the Clean Air Act


The Clean Air Act (CAA) was signed into law in 1963 and has since been amended several times. This law requires that all new power plants use the best available technology to reduce pollutants that are a threat to human health. The power industry argued that there was no need to regulate old power plants, since they would be replaced over time with new plants that meet the CAA requirements. The fact that this didn’t happen is both a lesson for how we need to regulate greenhouse gas emissions in the future and an opportunity to quickly begin reducing our emissions in the present.

Soon after passage of the CAA, it was clear that these old plants weren’t going away. To the contrary: Old plants were being “upgraded”, without meeting the requirements of the CAA. That’s why New Source Review was added to the CAA in 1977. If an existing plant was modified such that there were significant increases in emission, then the plant would need to be brought up to the CAA standards and the best available technology for controlling emissions would need to be installed. Routine maintenance is allowed under new source review. During the Clinton administration, a battle royal was waged about the definition of “significant” and “routine”. For the most part power plants have only performed “routine maintenance” since 1977. Still, power from these old plants has increased by operating them more hours each year.

In the 1980s, acid rain was killing lakes and streams in the Northwest; Congress amended the CAA again in 1990 to address this problem. This time their approach included the old plants, forcing them to either clean up their emissions or buy permits. The number of permits would drop over time, driving their cost up until the demand dropped, which happens when a power plant installs sulfur dioxide (SO2) scrubbers or is shut down.

This is a market-based approach, sometimes called cap-and-trade, that the Republicans brought forward and has been very successful in reducing SO2 emissions at a much lower cost than was predicted (which is almost always the case for environmental and safety regulations). The pro-market folks are now deriding the same basic concept for carbon dioxide (CO2).

Now it’s time to take stock on how well the CAA has done in cleaning up power plants. We’ve had almost 50 years of federal regulation, so one would expect that almost all coal-fired power plants would to be using some form of emission control at this point. I’m not talking about cutting edge IGCC plants or carbon sequestration. I’m talking about sulfur dioxide scrubbers that have been around for eighty years.

Well, an interesting report called Dirty Kilowatts by the Environmental Integrity Project explored that question, and I found the results shocking. They used data from 2005 and 2006 to find the dirtiest large coal-fired power plants in the country. My expectation was that there would be a few plants that had managed to survive for decades without installing emission controls.

Boy, was I wrong.

A coal power plant with state-of-the-art, best available technology can reduce emissions of SO2 down to about one pound per MegaWatt hour (MWh) of electricity. The dirtiest 50 large power plants averaged over 20 times that much. These dirtiest plants emitted 40% of the SO2, while producing 13% of the electricity produced by coal-fired power plants. This data is a bit old and some of these plants may have been cleaned up or shut down recently; the emissions permitting system is finally putting pressure on the operators to clean them up.

What is happening on the Navaho reservation is instructive of what can happen. A coal plant in Laughlin, Nevada shut down rather than spend 1.2 billion dollars installing pollution controls. This led to the shutting down of the coal mine on the reservation that supplied that power plant with fuel. This in turn led many on the reservation to question their long relationship with coal mining; that it isn’t consistent with their values and that rather than pierce the skin of the earth, they should harvest their abundant wind and sunlight.

The interesting thing here is that the shutting down of this coal plant was driven by regulations on SO2 and NO2, but resulted in a decrease in CO2 emissions as well. There are scores of power plants like this one and I don’t want them cleaned up: I want them shut down.

Shutting them down is a three-for-one: we reduce traditional pollutants that cause smog and asthma; we reduce CO2 emissions that cause climate change; we create a market for wind, solar and other renewable by reducing the amount of electricity on the market generated by coal. It jump-starts the changes we need without there being any carbon regulation on the books, though fear of a carbon cost does drive the decision not to upgrade these old plants.

An important lesson from the history of the CAA is that if you don’t explicitly require something to happen, you can guarantee it won’t happen (unless it’s bad, then you can guarantee that it will happen). The pollutants that the CAA didn’t address (e.g. mercury and CO2) have either remained constant or increased. The old power plants that weren’t required to clean up their act, didn’t. As we craft policy for CO2, we must explicitly cover old plants or they will continue to pollute the atmosphere and disrupt the climate. That doesn’t necessarily mean to need to shut them all down tomorrow, but some system that creates an increasing amount of economic pain on business as usual must be part of the solution. Whether that’s cap-and-trade, cap-and-dividend or a carbon tax is much less important than the fact that it must put pressure on the old coal plants.

Andy Silber is a astrophysicist, engineer, project manager, husband, father, and energy activist living in Seattle. Visit Andy's blog on Sustainable West Seattle. The author's opinions do not necessarily reflect those of the 1Sky campaign.
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