NRDC and EDF endorse the weak, coal-friendly, rip-offset-heavy USCAP climate plan

UDPATE:  For how the bipartisan climate bill — while still wholly inadequate for putting us on the path to stabilizing at 2°C warming — turned out better than I thought, and why it would drive more clean energy solutions than I realized, see:

The U.S. Climate Action Partnership — a coalition of businesses and enviros once though to be important — have released their wimpy Blueprint for Legislative Action.

I can sort of understand why, say, Duke Energy, signed on to this, but NRDC and EDF and WRI have a lot of explaining to do. As we will see, this proposal would be wholly inadequate as a final piece of legislation. As a starting point it is unilateral disarmament to the conservative politicians and big fossil fuel companies who will be working hard to gut any bill. Kudos to the National Wildlife Federation for withdrawing from USCAP rather than signing on.

I think it is absurd for any serious environmental group to support permitting new coal plants that don’t capture and store the vast majority of their emissions. Yet as the WashPost reports:

The plan would also require any coal plant permitted after Jan. 1, 2015, to emit no more than half the carbon dioxide emissions now considered normal and require any newly permitted plant today to have the ability to be retrofitted to meet that standard.

These are bogus provisions. Nobody really knows what a capture-ready plant design is — this is the climate equivalent of “the check is in the mail.” Any significant number of such new coal plants will simply make it much harder to meet the 2020 target, at a time when we have more than enough low carbon technologies today to meet any such target affordably (see “Is 450 ppm possible? Part 5: Old coal’s out, can’t wait for new nukes, so what do we do NOW?” and below).

But it is the 2020 target and the issue of rip-offsets that make this proposal truly untenable. The Blueprint calls for requiring that U.S. greenhouse gases (GHGs) return to “80%”86% of 2005 levels by 2020.” That is essentially returning to 1990 levels, which the science clearly says is inadequate to stabilizing at 450 ppm, let alone the 350 ppm target that environmental groups should be seriously considering (see “Is 450 ppm politically possible? Part 8: The U.S. needs a tougher 2020 GHG emissions target“).

Worse, the science makes clear that you need a target below 1990 levels without allowing fossil fuel companies to offset their emissions — i.e. continue releasing CO2 into the atmosphere where it will linger with a mean atmospheric lifetime of 30,000 years.

But the already-lame USCAP proposal shoots itself in the (other) foot with its embrace of a staggering amount of rip-offsets.

Since USCAP is recommending a stringent emission target, we also recommend generous limits on the use of offsets to help moderate compliance costs, especially during the period when low carbon technologies are still achieving the economies of scale and commercial maturity that many currently lack.

Shame on my NRDC and EDF and WRI friends for signing on to such nonsense. The emission target is most certainly not “stringent” as I have discussed at length here. It doesn’t even match the target recommended in the 2007 Intergovernmental Panel on Climate Change Fourth Assessment Report — and that report certainly underestimated the speed and scale of climate impacts.

The final clause is both wrong and irrelevant — energy efficiency is a fully mature technology, as is biomass cofiring in coal plants as is cogeneration. Wind is ramping up at an astonishing pace, and solar thermal baseload can deliver large amount of affordable power by 2020. For a full discussion, see “An introduction to the core climate solutions.”

Note to NRDC and EDF and WRI: Obama has committed that “We will double the production of alternative energy in the next three years.” If the President thinks alternative energy is ready to ramp up rapidly starting now, why don’t you? You are supposed to be pushing the administration to do more than they plan to, not less!

But the unconscionable amount of rip-offsets USCAP embraces guts the entire effort:

Congress should set an overall upper level limit on the use of offsets for compliance in any year of 1.5 billion metric tons domestic and 1.5 billion metric tons international offsets.
“¢ Congress should establish a Carbon Market Board (CMB) and give it the authority to set annual limits on the level of domestic and international offsets within the range of 2-3 billion metric tons total….
“¢ Congress should specify that the initial annual limit on offsets will be 2 billion metric tons. CMB should have the authority to increase the annual limit to avoid undue economic harm from excessively high allowance prices….

You cannot be serious.

Remember, total U.S. GHGs in 2005 were about 7.2 billion tons (see “Bush policies cause U.S. GHG emissions to soar 1.4% in 2007“).

The USCAP plan would call for a reduction of 1.0 to 1.4 billion tons of U.S. GHGs in 2020, while allowing 2 billion or more tons of offsets, at least half of which don’t even have to be in this country. When would US carbon dioxide emissions see serious reductions under this plan? Who knows? It’s d©ja vu all over again (see “Boxer-Lieberman-Warner bill update: Probably no U.S. CO2 emissions cut until after 2025“).

Let me repeat once more, as a major 2008 analysis from Stanford found

“between a third and two thirds” of emission offsets under the Clean Development Mechanism (CDM) — set up under the Kyoto treaty to encourage emissions reductions in developing nations — do not represent actual emission cuts.

And this led to the study’s stark conclusion:

any offset market of sufficient scale to provide substantial cost-control for a cap-and-trade program will involve substantial issuance of credits that do not represent real emissions reductions.

The Government Accountability Office recently ripped rip-offsets: “The use of carbon offsets in a cap-and-trade system can undermine the system’s integrity.”

Also, the CDM is filled with fraud (see “You can call a rip-offset a CDM project, but it’s still a rip-offset“). Let’s remember that the West got suckered into giving China some $6 billion to destroy greenhouse gas refrigerants that probably cost Chinese companies $100 million to capture and destroy (for more details, see “Kyoto’s Great Carbon Offset Swindle“). Let’s remember that

U.N. regulators are also concerned that some independent auditors of these projects, who are responsible for vetting their environmental legitimacy, have been letting project developers push through ventures of questionable environmental value….

In a presentation to U.N. officials last fall, the head of T¼v S¼d’s carbon business told U.N. officials that the quality of projects the auditors are receiving from carbon brokers is “going down,” according to the U.N. panel’s Mr. Schmidt, who was at the meeting….

“There is a high incentive” for companies to put together environmentally questionable carbon-credit projects, “because there is a lot of money that can be earned,” he said. “People are getting more inventive, so it’s getting harder to detect the black sheep.”

Let’s remember that instead of using the money to fund the transition to a sustainable economy, the World Bank “has loaned $1.5 billion to fossil-fuel companies to make minor greenhouse-gas reductions,” and “then sells carbon credits for those reductions,” and “takes its 13 percent cut”?

Let’s remember that “The vast majority of schemes that sell carbon credits to offset pollution are delivering 30% less than they promise“?

No serious environmental group — no person or group serious about keeping total global warming as close as possible to 2°C, no one who endorses a target of 450 ppm or lower, should endorse a final climate bill with more than, say, 5% very high quality offsets allowed.

The USCAP proposal has other features that are problematic. For instance, “USCAP recommends that a significant portion of allowances should be initially distributed free to capped entities….” Again, Obama himself has called for a 100% auction. As the Friends of the Earth response to USCAP says:

Put simply, the proposal would reward corporate polluters with hundreds of billions of dollars of giveaways, and its near-term pollution reduction targets are far weaker than what scientists have called for. The proposal is further weakened by its massive carbon offset loopholes. Were such a proposal to be enacted into law, it would fail to achieve the emission reductions we need in the U.S. and would undermine our ability to meaningfully and credibly engage in international climate negotiations. This is a dead-end approach that policymakers should reject.


This proposal is a dead end — and an even deader starting point. Shame on NRDC, EDF, and WRI for backing it.

With this proposal, the U.S. Climate Action Partnership has officially made itself obsolete and irrelevant.

18 Responses to NRDC and EDF endorse the weak, coal-friendly, rip-offset-heavy USCAP climate plan

  1. danl says:

    It seems that USCAP found essentially everything wrong with the EU-ETS and wrote it into their proposal: overreliance on the CDM & grandfathering of polluters. Why don’t they let the states form their own allocation plans too? That way, everyone wins (except the notable exception of the environment.)

    Just wondering, Joe: do you favor some other kind of policy to encourage smaller-scale (home, automobile) GHG reductions?

    [JR: Homes and cars really need to be done using efficiency standards for buildings, appliances, and vehicles. A low-carbon fuel standard would also help on the vehicle side, but if we dawdle for much longer, we may simply need mandates for plug ins. Hard to have such mandates, though, until multiple automakers have multiple models of plug ins.]

  2. Modesty says:


    1. Good. Offset target: Max 5%. Only very high quality offsets need apply.

    As you point out, the offset market planned by USCAP is instead larger than the reductions USCAP calls for. If all the scheme is supposed to do is fund (questionable) projects not covered by the cap, surely there’s a simpler, more straightforward way to do that? Obsolete and irrelevant, indeed.

    2. These analyses of yours are tremendously helpful in terms of reducing the noise level and clearing a path toward meaningful negotiation.

    Do you keep a list of players (individuals, organizations, corporations, governments) who have rendered themselves obsolete and irrelevant? There is no time to waste, and yet so much of it is still wasted on placebo policy prescriptions. It would help to have a no-need-to-read list easily accessible.


  3. Dan says:

    Joe and Danl,

    An upstream carbon tax, such as the revenue-neutral carbon tax proposed by the Carbon Tax Center, would send a price signal that would supplement the efficiency standards and low-carbon fuel standards Joe recommends. Standards are not enough on their own and neither is a carbon tax.

  4. Kojiro Vance says:

    I will give Joe the benefit of the doubt. He is just ignorant of the facts:

    [JR: No. You are ignorant of what I wrote. I didn’t say their weren’t plants that can capture. I just said that what is called “capture ready” is bogus.]

    ‘Nobody really knows what a capture-ready plant design is — this is the climate equivalent of “the check is in the mail.” ‘

    Reality – there are a number of examples of capture ready plants.

    How about this one that has operated for over 20 years and has been injecting its CO2 for 10 years:

    Or there is this plant:

    Or here is another one:

    Here is another one:

    Now before the anti-coal crowd goes nuts. None of these plants use mountaintop coal, gasification doesn’t make fly ash, yes it is more expensive than pulverized coal, but IGCC captures 50-90% of the CO2 at less than 1/2 the cost of post combustion capture. If carbon is properly priced, these plants will be competitive again.

    So yes, it is possible. Not like the goal of 100% renewables in 10 years plan that some has-been politician is promoting.

  5. Peter Black says:

    Joe, This map includes EDF’s projections regarding co2 emissions reductions through 2050:



  6. Peter Black says:

    BTW, let us know if you have any comments, or suggestions!

  7. Joe,
    It seems you read part of the USCAP Blueprint but you clearly did not read the coal provisions. The Blueprint does not call for “capture-ready” plants, a meaningless concept.
    What the Blueprint calls for is a mandatory minimum national CO2 emissions performance standard for every new coal plant that receives a permit after January 1, 2009. Plants receiving permits after January 1, 2015 have to meet the emissions standard immediately. Plants receiving a permit between 2009 and the end of 2014 have to meet the emission standard within four years after a modest amount of CCS capacity is operating in the U.S. or globally.
    This means that any new coal proposal that does not already have a permit will have to meet a CO2 emission standard that requires the use of CCS either at the start of its operating life or within a few years of starting operation. To get financing for a pre-2105 project it won’t be good enough for the coal plant developer to talk vaguely about being “ready” to capture carbon; investors will insist on real, engineered commitments to CCS and identification of real places to put the CO2 because they will understand that the retrofit obligation is very likely to be triggered within a few years after these projects begin operations.
    If enacted, this proposal would end the armwaving about capturing someday and require developers to incorporate CCS into all plants going forward.

    [JR: David, I read the full proposal. I just don’t believe the coal provisions have any real meaning and will be easily gamed or some vague language will appear in the final bill that vitiates it. There is no place to put the CO2. And it is much more expensive to build a genuine “capture ready” plant. The proposal is too clever by half. You think you have snuckered the coal guys — and vice versa. Why not just say no to new coal plants that don’t capture most of their carbon and sequester in a certified repository? You think that is what you are saying, anyway. Other signatories, I imagine, think otherwise.

    NRDC should just start by calling for a 5-year ban, rather than getting involved with messy language that ultimately will not be written by you.]

  8. Check out my report, “USCAP “Blueprint” Chorus Sings Complex Tune to Half-Empty Caucus Room” at

    As Claussen said, “all the components of the plan are linked.”
    And so are the players. All betting on a piece of the revenue “pie”. From what I can tell, (transparency isn’t a word associated with cap-and-trade) “dessert” is expected to be served through free allowances, offsets, and subsidies funded by a hidden, regressive, volatile tax, called a “cap.”

    As they say, “That dog won’t hunt.” That give-away plan was Lieberman-Warner and Senator Corker didn’t sit quietly for it. He’s reportedly drafting a carbon tax bill. The world has moved on. Let’s talk about a simple, gradually-increasing revenue-neutral carbon tax. And let’s talk about a bi-partisan bill.

  9. David B. Benson says:

    Lets talk about an ‘excess carbon dioxide removal fee’.

  10. Jill B says:

    There is another Blueprint developed by local governments and Climate Communities, which sidesteps the issue of coal altogether. But the purpose is more for making sure that local governments get funded for the projects they need to do. If you haven’t seen it, it’s at:

  11. Jill B says:

    oops, I thought that would make the link work:

  12. Kojiro Vance says:

    OK, then call them “storage ready”.

    IGCCs and coal to natural gas plants must capture a portion of the CO2. In the case of IGCCs the SO2 has to be removed before sending it to the gas turbine, usually by amine treating or an absorbtion process. A portion of the CO2 comes out with the SO2. Until there is a price signal for CO2 and regulations are in place allowing permanent storage, the CO2 will be vented to the atmosphere.

    Gasification plants must remove essentially all the CO2 in order to produce a natural gas that meets the minimum heating specification for pipeline quality gas.

    What USCAP is essentially saying is that there will be no more pulverized coal combustion plants built. IGCC or gasification with carbon storage produces electric power at the same CO2 per MWh or less than natural gas combined cycle. It can be done.

  13. Kojiro Vance says:

    Handley wants a carbon tax. I would agree, tax and rebate would be the way to go, with the money grubbing politicians in Washington never getting their hands on the money.

    But such a plan would have been DOA with Duke and NRG and others in USCAP. It also is a non-starter with politicians from West Virginia, Ohio, Pennsylvannia, Illinois, Maryland, and a bunch of states who depend on 75% or more of their power from coal.

    USCAP has been at it for 2 years. The fact that you got 30 or so companies and environmental groups to agree on this much is major achievment. You are unlikely to get a better deal, they are agreeing to capture and sequestration even before they know the rules of the game.

  14. Joe,
    You say–
    “You think you have snuckered the coal guys — and vice versa. Why not just say no to new coal plants that don’t capture most of their carbon and sequester in a certified repository?”

    I don’t think we have snookered the coal guys. The proposal is clear and the USCAP members understand it. As for your question why NRDC does not just say no to new coal plants that don’t capture most of their carbon, NRDC can say anything we want. Our responsibility is to do more than say what we’d like though; it is to actually achieve policy change. We think forging a recommendation that will require new coal plants to use CCS after a few years, structured in a way that a broad group of businesses are supporting, is the way to make that policy change happen. If you think you have a way to achieve a better outcome sooner, go for it. But just saying what you want is not a strategy.

    You go on to say–
    “NRDC should just start by calling for a 5-year ban, rather than getting involved with messy language that ultimately will not be written by you.”

    I know you are smart enough to recognize the inconsistency in this advice; you must have been typing too fast. Congress will ultimately write the language for any proposal. Making a proposal in more absolutist terms doesn’t increase our ability to control its fate.
    Our judgment is that “yes we can” achieve an outcome that changes the kind of coal plants that get built if the proposal has broad support. Attack it as not good enough if you like but please be equally rigorous in demanding a real strategy to enact what you would advocate instead.

    [JR: I think you missed my point. I think you should pull the plug on USCAP. All I think you have done with this effort (with the help of EDF and Pew Center) is move the center to the right and vitiate the results of the election and Obama’s terrific cabinet picks. You aren’t negotiating with Congress, just a bunch of companies, most of which don’t matter.

    You have basically announced to the world with this proposal that NRDC thinks this is the best we can do. I hope to God you are wrong. Your efforts have convinced me that Obama shouldn’t push a climate bill for passage in 2009. He needs to move the needle significantly.]

  15. carolann says:

    What a disappointment NRDC. Frankly, I don’t expect much from a group that continues to pretend that “carbon sequestration” will work, that it will EVER be commercially viable, or that it represents anything other than a massive waste of time and effort.

    NRDC is the poster child for corporate environmentalism.

    We have a number of failures here, with the largest, of course, being politcal will. But the most distressing is the lack of political will from our largest and most powerful environmental institutions.

    Citizens want change, are willing to pay more for clean energy; the independent power producers are ready, willing and able to build new renewable power plants, but the rules — and groups like NRDC — are stacked against them.

    The NRDC is a “big player.” But they are on the wrong side of the game.

    Bummer dude. Sorry grandkids.

  16. carolann says:

    Earth to NRDC: CCS will triple the cost of coal, and you know that good and well.

    It will never happen. You know that good and well also.

    It’s a ruse. It’s a way for the coal industry to keep burning toxic coal and dumping the CO2, the mercury, the toxic coal waste etc. on all of us.

    You know that too.

    Where is NRDC when it comes to monetizing externalities, fighting for better rules on coal waste, fighting for more renewables, working at the state level to force utilities to build more RE?

    There’s so much a group like NRDC could do, but they don’t. There are so many ways a large powerful group could work at the state level to promote small-scale RE and show citizens that it works, it’s cheaper, it’s cleaner.

    But instead, they work like a coporation, doing as little as possible but making a big deal about the little they do.

    What do you call greenwashing by an environmental group?

  17. carolann says:

    Kojiro: The people who read this blog know good and well that CCS doesn’t work; that the amount of CO2 that would need to be “sequestered” is staggering, that if only a tiny percentage leaks out over the 100 or so years the CO2 would need to stay buried is absolutely crazy — and terribly, terribly expensive to boot.

    As the TVA spill has taught us, matter is not created or destroyed, only CHANGED. The filters and baghouses and other pollution-capturing equipment simply diverts what would have gone into the atmosphere into another waste stream — like the huge coal ash pit.

    Every pound of coal burned creates 3 pounds of CO2.

    There are about 3 plants that CREATE ELECTRICITY in the world that are currently capturing and storing CO2. Each plant captures about 1 million tons/year. 1 million tons/year x 3 plants = 3 million tons/year — but the problem is that the U.S. alone emits about 2-3 BILLION tons of CO2 per year.

    One million tons of CO2 is about one-tenth to one-third the average emissions from a SINGLE coal plant.

    Big deal. WOW!

    This is NOT a solution, it’s a time-waster.

    And the cost? $17/ton just to COMPRESS the CO2. And what about the infrastructure required to capture the CO2? It takes 20% of the plant’s output just to run the capture equipment.

    It goes on and on.

    But you know all that.

    Joe Romm has shown me what one well-informed, fomer insider who now answers to NO ONE, and can write and has an a sense of humor can do.

    As a colleague said, we need people with integrity now MORE than we need more money thrown at our problems.

    I am stunned that NRDC — or anyone — would think that a “solution” that allows new coal plants to continue to be built is viable fi we want a liveable planet.

    Runaway climate change has kicked in during our past in as little as 10 years. There’s evidence that the thermhaline cycle is changing, that our oceans are becoming acidified, and that an acid ocean could bring about the death of 90 percent of all species, as has happened in the past.

    Surely our friends at NRDC know this. Surely they know that people want change, that more and more citizens are waking up.

    I can understand that coal companies being so backwards — but the largest enviro’s in the world?

    Profoundly disappointing.

  18. West Coast Observer says:

    Can I just note the arrogance of David Hawkins tone. BTW…you’re not just campaigning for yourself and for a meager victory…. you’re supposed to be “defending the Earth.” So what business do you have representing the interests of future generations of non-white non-corporate environmentalists – absolutely zero. And where the hell is edf on this blog. cant you speak up and defend yourself for your wrongdoings? im sure fred krupp’s probably to busy gettin a handjob under the table at some corporate board meeting. mrs. beinecke seems like a nice lady, but hawkins sounds like a jerk to me.