A Power Plan that’s Cleaner for All


Energy -who has access to it and what it is used for -- has never been race or class neutral.




Chicago, 1893. The Westinghouse Corporation beats out Edison’s General Electric Corporation for the contract to light the Columbian World Fair with electric power. The fair, which celebrated the 400th anniversary of Columbus's voyage, afforded Westinghouse an opportunity to prove to the world that his patented Alternating Current system of delivering electricity was safe, effective, and efficient. Using twelve 1,000 horsepower generators, Westinghouse illuminated a “White City” of marble intentionally built to rise above a darkened bazaar of world cultures. The spectacle worked for Westinghouse-- nearly all electricity in the United States is transmitted via AC current-- but the racism celebrated at the fair remains endemic to the country’s fossil fuel energy infrastructure.

 The United States is now at the verge of another energy transition. First released in June 2014, the EPA's Clean Power Plan (CPP) aims to reduce US carbon emissions to 30% of 2005 levels by 2030. Now, environmental justice advocates are working so that communities of color and/or low income share in the clean energy revolution, and are protected from a climate crisis they had little role in creating. 

 The CPP is an update of the Existing Source Performance Standards for Energy Generating Units, regulations under the Clean Air Act limiting the amount of greenhouse gas emissions from currently operating plants. It is the first national plan to limit carbon emissions and mitigate global warming. One of the plan's key strengths is that it sets strict national emissions limits, but allows the states flexibility in reaching those targets.

The federal plan has the support of many mainstream environmental organizations including the NRDC, EDF, and The League of Conservation Voters. It has also come under legal fire from Republicans and business interests looking to protect investments in fossil fuel related industries.

 While WE ACT and its allies in the EJ Forum back the overall objective of the CPP, they are also in the midst of a campaign to highlight and change aspects of the rule that shift the economic and health burden of the transition onto EJ communities. The coalition’s Clean Power, Clean Air, Cleaner Communities campaign has a two-tiered strategy: raise the visibility of EJ concerns and install protections in the rule at the federal level, and put EJ advocates at the table during the State Implementation Processes (SIPs)

 Specifically, here are a few of the measures that WE ACT and its EJ forum allies have been pushing for:

 1.     The EPA should issue guidance to states on integrating environmental justice concerns into their SIPs, and conduct a "proximity analysis" on affected factories


The first draft of the CPP included only a few qualitative descriptions of how the rule might increase co-pollutant burdens in EJ communities. However, on April 2nd, after several months of pushback and advocacy done by WE ACT and partnering Environmental and Climate Justice Groups, the EPA finally agreed to issue guidance on incorporating environmental justice into the clean power plan. Though it is not clear how robust of an EJ analysis this document will include--there is no standard on what constitutes EJ an analysis, and so the document may not quantitatively investigate possible risks introduced to fence line neighborhoods—but the announcement does represent the first time the agency has taken steps towards enshrining EJ protections in the CPP.

 2.     Integrate concerns about health, energy efficiency and economic justice into a meaningful transition


 In many EJ communities, poor pollution-related health outcomes are a result of expulsive zoning: historical, concentrated siting of multiple sources in a given neighborhood. While the CPP is primarily concerned with CO2 emissions, different kinds of energy sources—coal fired power plants and oil refineries, for example—produce different byproducts that are each considered separately under the National Ambient Air Quality Standards. Notably, while CO2 emissions disperse across the globe, many of the co-pollutants, including SO2 and NOx, settle near their origins. The EPA itself has acknowledged that as power plants improve efficiency with respect to CO2, they may release more of co-pollutants as they ramp up production. WE ACT and its allies are advocating for EJ representation during the SIP process so that lawmakers keep an eye on the big picture: reducing all emissions dangerous to community health and livelihoods.

EJ representation in the SIP process will also help ensure energy accessibility for low-income people. In New York, Cecil Corbin-Mark, WE ACT’s Deputy Director, has worked on the state’s reforming the Energy Vision (REV) to promote distributed generation localized energy grids. Other innovative solutions have included awarding emissions credits for energy efficient housing upgrades.


3.     Ensure that Best Systems of Emissions Reductions (BSERs) are best systems for all communities


The CPP is heavily slanted towards Cap and Trade as a state BSER. Under Cap and Trade, states set a maximum “cap” on the amount of emissions from the whole sector, and then sell allotments that firms can trade. In a cap and trade scenario, plants that are more efficient or easier to upgrade can sell their allotments to older, dirtier facilities. This arrangement tends to put the worst sites last on the list for cleanup, and can exacerbate hotspots in the interim.  In a University of Southern California report, Minding the Climate Gap: What’s at Stake if California’s Climate Law isn’t Done Right and Right Away, Dr. Manuel Pastor and colleagues demonstrated how a proposed cap and trade program would deprive California EJ communities of major opportunities for green jobs and improvements in public health.

 One of the reasons major green groups support cap and trade is that the Regional Greenhouse Gas Initiative (RGGI), a cap and trade program based here in the Northeast has been successful in cost-efficiently reducing emissions. These supporters argue that revenue generated from the program—which in New York State amounts to $760 million, can be used for infrastructure upgrades in those directly affected neighborhoods. However, without specific accountability measures in place, there is no guarantee that money will go to those most in need. Just this March, Governor Cuomo took $41 million dollars of RGGI revenue and rolled it into the general fund.

 Instead of Cap and Trade, WE ACT and allies are advocating for a Carbon Tax, a “polluter pays” measure charging firms directly for their missions. Other potential compromises have included restrictions on allotments to firms in overburdened communities, and a “Climate Gap Fund” in highly polluted areas. WE ACT and allies have also strongly resisted allowing biomass and waste burning and nuclear power to be counted as BSERs, as these processes tend to swap CO2 emissions for localized pollution of other types.

 The green energy transition affords a unique opportunity for EJ communities to shape, quite literally, the infrastructure of power in the United States.  WE ACT members are strongly encouraged to sign the petition and engage in advocacy this summer once the final rule is released.