The Clean Power Plan and Environmental Justice: Part One

Though directed at greenhouse gases, the Clean Power Plan, by controlling existing fossil-fuel power plants, will have important implications for associated co-pollutants, many of which continue to be emitted at unhealthy levels notwithstanding decades of control. The degree to which the Clean Power Plan will lead to reductions in traditional pollutants - the extent of its "co-pollutant benefits" - is an especially important issue for communities experiencing the highest pollution levels, communities that are disproportionately of-color and low-income. Hence, the Clean Power Plan presents an opportunity for the federal government and the states to further environmental justice. So, how does the Plan measure up? And how should the states maximize the opportunity to achieve environmental justice? In The Clean Power Plan: Issues to Watch, I wrote a short essay identifying and explaining a number of environmental justice issues raised by the proposal. The final Clean Power Plan's preamble recognizes the importance of this issue, devoting a major section to "Community and Environmental Justice Considerations." EPA has also created a Clean Power Plan Community Page devoted to addressing the impacts of the rule on overburdened communities. A first key issue is the degree to which the plan achieves large aggregate reductions in co-pollutants, a function of the plan's stringency. A second key issue concerns classic environmental justice: the degree to which the plan distributes reductions where they are most needed and provides vulnerable communities with meaningful participatory opportunities. A third key issue is the degree to which low-income and disadvantaged communities avoid the costs and reap the benefits from a clean energy transition. In this post, I'll take a look at the first of these issues, and tackle the other two and draw some conclusions in subsequent posts tomorrow and Monday.