Document 3Jme41XL7RLoZzEdpa45ekZbn

To: Pruitt, Scott[Pruitt.Scott@epa.gov] Cc: Flynn, Mike[Flynn.Mike@epa.gov]; Reeder, John[Reeder.John@epa.gov]; Dravis, Samantha[dravis.samantha@epa.gov]; Dunham, Sarah[Dunham.Sarah@epa.gov]; Gunning, Paul[Gunning.Paul@epa.gov]; Page, Steve[Page.Steve@epa.gov]; Kavlock, Robert[Kavlock.Robert@epa.gov]; Harvey, Reid[Harvey.Reid@epa.gov]; Sonich-Muliin, Cynthia[Sonich- Muliin.Cynthia@epa.gov] From: Frank Princiotta Sent: Sat 4/22/2017 9:50:42 PM Subject: My paper: We are losing the climate change challenge; can we recover? We Are Losing the Climate Change Challenge pre-pub.docx Mr. Pruitt, EPA Administrator I am a recent EPA retiree who had the privilege of working for the agency for 42 years. While at the agency, I managed research programs in the areas of air pollution control, stratospheric ozone protection, acid rain control, indoor air quality and in recent years, global climate change. In the climate area, I have edited a book on climate change mitigation, authored several papers and have given presentations to a number of universities and technical societies on this subject. Of all the environmental issues I have been associated with over the years, this is easily the most important and the most challenging, and time is not on our side. Most recently I have authored the attached paper: We are losing the climate change challenge; can we recover? The paper has been peer reviewed and will soon be published (as an invited paper) by the Materials Research Society-Energy and Sustainability Journal. I believe this paper clearly documents that humanity has dug itself a very deep hole, and that Earth's habitability for our children, grandchildren and subsequent generations is seriously threatened. The paper quantifies the mitigation challenge and lays out concrete steps that need to be taken to reduce the potentially catastrophic impacts that are only a few decades away. I respectfully request that you review this manuscript and would welcome the opportunity to discuss this issue with you or anyone on your staff. Sincerely Yours, Frank Princiotta 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008172-00001 Retired, EPA Senior Executive 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008172-00002 We Are Losing the Climate Change Mitigation Challenge: Is it Too Late to Recover? Frank Princiotta. Retired. EPA Research Director Abstract The status of the climate change mitigation challenge is analyzed and summarized. Pressures spawned by industrialization and population growth have driven unsustainable growth in greenhouse gas (GHG) emissions, yielding global warming. Such warming has accelerated over the last three years and for 2016 was 1.3C over pre-industrial levels. Serious climate change induced impacts have already occurred and more serious ones are projected. The recent UN Paris COP agreement is only a small step toward meaningful mitigation. It will only slow emission growth and will not lead to near term aggressive annual emission decreases, which are needed to avoid warming of 2C or more. We are losing the battle to protect the planet from unacceptable climate change impacts. In order to minimize the impacts, the following is needed: more aggressive communication of the seriousness of the problem to national accelerate the development of low cost low C technologies, with a focus on potentially transformational technologies, and a serious commitment to peak global emissions as soon as possible and drastically reduce such emissions annually from that point on. A global agreement to set a price on carbon (C) could be effective in helping to achieve such an aggressive emission reduction trajectory. Highlights We are losing the climate change mitigation challenge. The task now before us: minimize the impacts. Discussion -Is there a credible path to limit warming to no more than 2 degrees C? -What role can material recycling play in mitigating C02 emissions? -How can we communicate the threat of potentially catastrophic climate change impacts to society more effectively? Global warming has accelerated in recent years; we are approaching 1.5 C warming froml l 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00001 the pre-industrial era The planet continues to warm. Over the last three years, global warming has accelerated. 2016 was the third consecutive year of record warming increases. Figure I1, summarizes the temperature history relative to the 1881-1910 period. As can be seen, global temperatures increased by about 0.3Cover the last three years to a projected overall warming of ~1,3C, from pre-industrial levels. It should be noted that this extraordinary recent acceleration in warming was likely influenced by a strong El Nino meteorological event, which has the characteristic of moving heat from the ocean to the atmosphere. Since this periodic event has faded, it appears unlikely that we will see such dramatic warming increases in the next several years. Nevertheless, these recent data debunk climate skeptics who have argued that in recent years there has been a major "slow down" in global warming, which, they argued, means near term action is not necessary. Global average temperature Changeover industrial era 1880 1900 1920 1940 1960 1980 2000 2016 Source: Copernicus Climate Change Service, ECMWF, for data from 1979: Met Office Hadley Centre, NASA & NOAA for blended data prior to 1979. Reprinted with permission It is important to note that the recent United Nations Framework Convention on Climate Change (UNFCCC)2, has set a goal for maximum global warming by "Holding the increase in the global average 2 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00002 temperature to well below 2 C above pre-industrial levels and to pursue efforts to limit the temperature increase to 1.5 C above pre-industrial levels, recognizing that this would significantly reduce the risks and impacts of climate change" Given the UNFCCC goal, Figure 2 projects warming from the pre-industriai era, and compares it to actual warming including the recent 2016 warming. The model used was the on-line MAGICC Live3 (default assumptions) and assumed the IPCC fossil fuel intensive emission scenario (A1FI). As can be seen, actual warming matches the model projected warming quite well. Such a close correlation suggests that if we continue on a business as usual fossil energy intensive path, we could see warming of 1.5C by 2030 and 2.0C by 2046. This does not allow much time for humanity to make fundamental changes in how we generate and use energy, which will be needed if we are to avoid the potentially catastrophic consequences of climate change. Figure 2. Actual versus projected warming, 1800 to 2100, C It is important to recognize the uncertainties inherent in such projections. Figure 3, again generated using 3 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00003 the MAGICC Live model3, depicts projected warming from 2000 to 2100 including ranges of uncertainty generated via a multi-model ensemble of warming projections. Such projections suggests that at the upper band of the uncertainty range, 1,5C warming could occur as soon as 2028 and 2C warming as soon as 2040. Greenhouse Gas (GHG) emissions are the primary driver for the observed Warming Although it is dear that the planetiswarmingjwnaf are theanversresponside for such warming? The IPCC4 has conducted analysis concluding that emissions of GHGs are the primary driver for such warming. Figure 4 summarizes the results of this analysis. The bottom graphic compares model projections accounting for the only two factors that can influence planetary warming in decadai time frames, other than GHGs: soiar radiation variations and volcanic eruptions. Major eruptions throw reflective particles in the upper atmosphere which have a near term cooling impact and a longer term warming impact as the particulates deposit and the reflective cooling diminishes. As can be seen, eruptions and solar radiation changes do not correlate well with the observed warming. However, when GHG emissions are included, there is an excellent correlation. Figure 2, discussed earlier, reinforces this conclusion, since model projections incorporating GHG emissions alone, also correlate well with actual warming. It is clear, that the planet is warming and that anthropogenic emissions of GHGs are the driver. 4 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00004 ure 9.5 from Climate Change 2007: The Physical Science Basis. Working Group I Contribution to the Fourth ;essment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. Reprinted with permission. Climate Impacts are here and now; much more to come EPA has recently published "Climate Change Indicators in the United States"5. This report documents the many significant impacts that climate change has already had in the U.S. They include deleterious impacts on weather, oceans, snow and ice patterns, human and ecosystem health. Figure 56 illustrates the most significant of these impacts. 5 17cv1906 Sierra Club v. EPA 6/22 Production ED 001523 00008173-00005 I I I i I Ml %* '%m0 b i b gw mi ,w '%t w # mi '%&& e i %# e 1 74 / v Changing and Snow Patterns Changes in Animal r/u---r-.-jsi.ife Cycles Figure 5. Depiction of current climate change impacts Stronger Higher Temperatures and More Heat Wax >ughts lliiill 'tgBBid ipl^jij 1111 g Thawing Permafrost Damaged Rising Changes in Plant life Cycles Table 1 (derived from Stem7* projects potential climate impacts as a function of 2100 temperature rise, from pre-industriai levels for water, food, health, land and ecosystems categories. As can be seen, as warming exceeds 2.5C, serious impacts are projected in the agricultural sector, with large areas of cropland becoming unsuitable for cultivation. Also likely are large losses in biodiversity, forests, and wetlands. Desertification would be widespread, with large numbers of people experiencing increased water stress. Human and natural systems would be subject to increasing levels of agricultural pests and diseases with increases in the frequency and intensity of extreme weather events exacerbated by substantial seawater rise. Millions of people would be at risk for premature death due to malnutrition and exposure to tropical diseases. Note, not depicted in the table are risks associated with potential large scale and abrupt impacts such as Greenland ice melting and changes to atmospheric circulation. These could lead to catastrophic sea level rise and collapse of Atlantic Thermohaline Circulation (often referred 6 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00006 to as "Ocean Conveyer Belt).Such impacts could dramatically increase coastal flooding and yield unprecedented cooling in Western Europe and Western North America and heating in Eastern North and South America, drastically changing the climate in those regions. Note that the first column in the table indicates the level of GHG mitigation (if any) associated with the temperature rise range. As can be seen, serious emission reductions beyond that agreed to in the Paris COP agreement will be needed (see Figure 9) if impacts are to be seriously moderated. 7 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00007 Table 1: Potential Climate Impacts as a function of 2100 warming Warming, C 0.5 to 1.5C (current situation) Water Small glaciers in Andes melt, threatening water supplies for 50 million people 1.5 to 2.5C (Likely in 20-50 years, could be maximum if humanity peaks GHG emissions in near term & dramatically reduces them annually) 2.5 to 3.5C (Could be maximum warming if humanity strengthens Paris Climate Accord) 3.5 to 4.5C (Likely warming by 2100 if humanity continues on current fossil fuel intensive path) Greater than 4.5C (Possible warming post 2100 if humanity continues on current fossil fuel intensive path) Potentially 20 30% decrease in water availability in vulnerable regions, e.g. Southern Africa, Mediterranean -Serious droughts in Southern Europe occur every 10 year| -1 to 4 billion more people suffer water shortages 50% decrease in water availability in Southern Africa, Mediterranean and Western North America in Himalayas yielding shortages to ha! of China's population and hundreds of millions in India Food -Modest increases in cereal yields in temperate regions -Modest yield decreases in arid regions Sharp declines in crop yield in trcpicai region; (5-10% in Africa} Health -At least 300,000 people die annually from ciimatereiated diseases (diarrhea, malaria & malnutrition) -Reduction in winter mortality in higher latitudes 40-80 million more people exposed to Malaria Land -Event specific damage due to increased storm intensity -Buildings & roads damaged in Canada & Russia due to permafrost thawing Up lo 10 million more people, affected by coastal flooding each year -150-550 additional millions at risk of hunger people die annually from malnutrition Up to 170 million -- people affected by coastal flooding each year yields in high latitudes likely to peak Jig 15-35% in Africa & some vulnerable regions out of production altogether HHPHPBHIilli .MexinpioosnesdmtoorMe adliaeria due to starvation & diseases by coastal flooding each year -potential large scale migration with serious societal impacts in ocean acidification seriously disrupting marine ecosystems & fish stocks hundreds of millions with catastrophic societal impacts Environment ~10% of land species facing extinction (per one estimate) ~80% bleaching of coral reefs causing serious coral weakening Extinction of 15 40% of all species per one estimate -20 to 50% of all species facing extinction -Potential collapse of Amazon rainforest -Loss of about half of Arctic Tundra -Half of world's nature reserves failing -Many of Earth's ecosystems seriously damaged for centuries Humanity's growing population and increasing demand for resource intensive goods and services have driven the dramatic growth in GHG emissions over the Last 50 years 8 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00008 Figure 68 illustrates the rapid growth of C02 emissions from fossil fuels and cement production from 1990 to 2014 and identifies the key countries responsible. The industrialization of China and other developing countries such as India have been responsible for much of the recent emission growth. 1000 million tonnes C02 Internattonaliransport Other countries Other large countries Figure 6. Emissions China Other non-OECDiggo European countries Russian Federation of C02 from energy & cement, 1990 2014 Other OECD1990 countries Japan European Union {EU28} o-- I , 1990 1995 1 2000 1 2005 I 2010 y 111111111 I 2015 United States Reprinted with permission from PBL Netherlands Environmental Assessment Agency Figure 79 illustrates the key driving forces responsible for this dramatic growth in greenhouse gas emissions in recent decades. Figure 7. Macro view of the drivers yielding GHG emissions and the two key mitigation approaches 9 17cv1906 Sierra Club v. EPA 6/22 Production ED 001523 00008173-00009 Challenges to Long Term Sustainability -- GHG emissions are a product of meeting human "needs" via energy intensive technologies and practices. Over time, developed nations have expanded their list of "needs" to include personal transportation, residences with energy-intensive heating, cooling, and lighting, a diet heavily oriented toward meat production, and a growing array of consumer goods. Developing countries such as China and India, with large populations, are moving in the same direction. For the period 2000 to 2010 CO2 global emissions have grown at ~3% annually based on a GDP per capita growth rate of 2.5%, a population growth rate of 1.1%, compensated to a modest extent by a negative 0.6 annual growth rate of energy use per GDP. The middle of the figure indicates that these human needs are met by means of a large array of industrial, agricultural, and energy technologies and practices. Although there are a multitude of inputs and outputs associated with these "technologies and practices", the major threats to long-term sustainability for an advanced level of civilization are shown in the figure. These threats include depletion of fossil fuels without adequate quantities of alternative forms of energy, depletion of mineral and fresh water supplies, and the various impacts associated with the emissions of 0O2 and other greenhouse gases. On the righthand side of the figure is a listing of key global impacts associated with current technology and practices. As indicated by the red return arrows, climate change has the potential to exacerbate global impacts associated with non-energy-related technologies and practices. Ocean and forest degradation are examples of such amplification. The bottom of the figure indicates that there are two classes of mitigation10 10 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00010 opportunities. The most commonly considered approach is repiacing/upgrading current technologies and practices. Another, less discussed, but potentially important if we are serious about dramatically decreasing GHG emissions, would be to modify social and cultural behavior toward a less energy and resource-intensive lifestyle. Global efforts have had a minimal Impact on mitigating the problem to date Climate change has been the subject of international discourse for many years. The first paper to attempt to quantify projected anthropogenic global warming, dates back to 197510. Figure 8 illustrates that despite ail the meetings, the formation of the IPCC and its Assessment reports, and the Kyoto Protocol, there has been no significant CO2 emission or atmospheric concentration slowdown. 35 Hur^dn GO.? ss:n:; 30 \ * Atmospne' c CO** Co^ce^f-aGoi Hurncin CQJ enf'SS/on$ {b'ur, left y ax-%, iourte 1 } ngh! v anj. Soane 1 ' atmasphe'n. C02 co'itent-ation (>ed, <` } Ou 25 o S IPCC' Fossil Intensive limission Scenario: A IF! ^ RCPH 5 1! 1 ; 15 t National Climate Program Act Kyoto Protocol Creating IPCC UN Framework EU Cap &Trade 400 ' jf/'-1 39C 380 eT 3 TC | X 360 | its 1 350 Extreme 0 340 ~ &c 330 | Weather Events, u 2013 IPCC Report 3^0 2014 U.S. Climate Report,- 310 Figure 8. CO2 emissions & atmospheric concentrations continue to grow despite international discourse 1970 1975 2 OHO 1985 1990 1995 2000 2005 /(UC 301-i The Recent COP Paris Agreement: how significant is it toward constraining warming to 1.5C and 2C? The 2015 United Nations Climate Change Conference, COP 21, was held in Paris, France, from 30 November to 12 December 2015.The goal was to reach agreement on reducing emissions of GHGs to limit global warming to tolerable levels. The following was accomplished (derived from United Nations Treaty Collection2):11 11 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00011 196 countries, including the U.S., China, EU, Japan, and Russia agreed to work collaboratively toward the reduction of GHGs to protect the planet from the impacts of climate change. -As mentioned earlier, countries agreed they will aim to keep warming below 2C and for the first time agreed to pursue efforts to limit maximum temperature increase to 1,5C. -The agreement utilized a "bottoms up" approach whereby countries set their own goals. Each country that ratifies the agreement sets a target for emission reduction, called a "nationally determined contribution," or "NDC". The amount will be voluntary. There is neither a mechanism to force a country to set a target by a specific date nor enforcement measures if a set target is not met. However, countries are required to report on progress toward achieving their NDCs. -On 22 April 2016 (Earth Day), 174 countries signed the agreement in New York. The Paris COP agreement is clearly the most significant international climate agreement ever negotiated; but what is its potential impact? With the aim of quantifying this impact, Figure 9 was generated based on analysis conducted by Climate-Interactive and their spreadsheet data11. The figure illustrates, via the NDC Strict scenario, that if all current NDC commitments are met, emission growth will slow relative to a Business As Usual (BAU) case. However, 2100 warming is projected to be in the order of 3.5C. As indicated in Table 1, such warming will yield unacceptable climate impacts. The NDC Extended scenario assumes continuation of such emission reductions beyond 2025, yet still yields 2100 warming of 3.2C. The final two scenarios aim to limit warming to 2C and 1.5C, per the stated goal of the agreement. As can be seen, limiting warming to these levels will be a monumental challenge requiring a near term peak in reductions followed by major annual emission reductions for decades. Such a fundamental change from substantial emission growth averaging~2% annually over the last 20 years, would need to be turned around so that emissions peak in the next 5 to 15 years followed by 4 to 5% annual reductions for decades. This appears unattainable; and certainly impossible without a fundamental near term radical re-structuring of how the world generates and uses energy.12 12 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00012 160 140 | | 120 | 100 80 60 40 | 20 0 NDC=Nationally Determined Contributions 2100 temp = 4,5UC Figure 9. Global emissions (Billion tons C02(e) per year) for Business as Usual, and four mitigation scenarios, 2100 warming projections included Business as Usual i NDC Strict - All pledges honored & no changes after contribution pledge period I NDC extended - All pledges kept & reductions continue after pledges I end (2025 or 2030) I 2C Target Met - Extended pledges plus all countries peak before 2030 I and then globally reduce ~4% per year 1.5C Target Met - Extended pledges + global emissions peak before 2020 & then globally reduce ~5% per year It is instructive to examine the U.S. NDC and its relationship to an emission trajectory consistent with limiting warming to ~2C. Figure 10 illustrates the U.S. NDC which is committed to reducing emissions nationally by 26-28% by 2025 relative to 2005. Also shown are the emission/per capita emission targets consistent with the IPCC12 1a3nalysis that global 2050 C02 per capita emissions need to be no higher than ~1.3 t/person to limit warming to 2C. It is difficult to construct a credible scenario that would allow the U.S. to decrease its per capita C02 emissions from 13 to 1.3 in just 25 years. 13 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00013 20 Figure 10. U.S. Commitment to mitigate C02 by 2025 versus what reductions will be required by 2050 to be compatible with global emission requirements to limit warming to 2C What are the technology Implications of drastically reducing emissions in the near term? In order to grasp the complexity of the climate mitigation challenge, it is instructive to understand the relationships between the sectors, end uses ("needs") and the four main GHGs of concern. Figure II13 challenges is that the emission of GHGs results--directly or indirectly--from almost every major industry and activity. This chart shows key industries and activities, and the type and volume of greenhouse gases that result from them. Such critical activities include road travel, residential and commercial building cooling, heating and lighting and the production of chemicals, cement, and iron & steel needed for production of goods. The net result of these operations are huge emissions of C02, most of which are associated with the combustion of coal, oil and natural gas. Also in the energy sector, oil, gas and refining activities generate large quantities of methane, the second most important GHG.. Non-energy activities, such as Industrial Processes, e.g., Cement Production, and Land Use Changes, i.e., deforestation, also increase concentrations of C02in the atmosphere. Agricultural practices are particularly important in terms of the methane and N20 emissions they generate. Note that globally in 2005, 77% of the anthropogenic warming that year is associated with C02, with methane and N20 contributing 15 and 7% respectively. Note that the term C02 equivalent (C02(e)) emissions, is the amount of C02 which would have the equivalent global warming impact, when accounting for the other GHG gases. For 2005 that14 14 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00014 number globally is 44 Gt(e). It should be noted that every country has a unique sector/C02(e) flow sheet. For example for the U.S.14 in 2005 the energy sector contributes 87% of its C02(e) emissions, with Industrial Processing and Agriculture contributing 4.5 and 6.2%, respectively. Also for the U.S., C02 contributes 85% of its C02(e) emissions, with methane and N20 contributing 8 and 5% respectively. Figure 11. World Emissions Greenhouse Gas Emissions in 2005 by sector, end use and gas (Total=44, GtCOz (e)) i miw2 ei;. Sector End Use/Activity Gas > 0 tr I LU z 14 /< WORLD RESOURCES INSTITUTE Given the need for early and dramatic emission reduction in the energy sector above and beyond the current modest NDC commitments, Figure 11 suggests that given their major contributions to C02 emissions, Transportation, Electricity generation and Industrial production are sectors requiring 15 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00015 fundamental changes in the near term if dramatic emission reductions are to be achieved. On the end use side, transportation vehicles and buildings are very high energy users which must dramatically improve their energy efficiency. Figure 12 illustrates the quantities of C02 avoidance by technology for the International Energy Agency's (IEA)9 50% C02 by 2050 reduction scenario, referred to as the Blue Scenario. Such reductions when accompanied by aggressive methane and N20 emission reductions, can limit warming to close to 2C. The sum of all the bars yields 43 Gt avoided in 2050, versus baseline projections. The results suggest that a diverse array of low carbon technologies and practices in ail energy sectors will be needed if these reduction goals are to be met. Of particular importance are end-use technologies in the building, transport, and power-generation sectors, as well as carbon storage technologies in the power-generation and industrial sectors. Figure 12: Technologies needed to meet Blue Map scenarios avoidance goal of 43 Gt C02 mitigated by 2050 POWER GENERATION BUILDINGS TRANSPORT INDUSTRY A key question is how available are these technologies and how fast can they be utilized. Again for the Blue Scenario, Figure 139 depicts these technologies and puts them in two categories: existing technology 16 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00016 or new/advanced technology. As can be seen, over half of the required reductions are associated with technologies that are not currently commercially available. Figure 13. Technologies needed to meet a 50% reduction by 2050 mitigation scenario; new/advanced versus existing 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Electric & Plug-in advanced Geothermal .2nd-gen biofuels Solar advanced Nuclear power advanced CCST*ower Generation Cleaner high eff. Coal advam CCS Industrial .Cleaner high eff. Coal Other end use efficiency vehicles electric & plug-in .-Wind-Rower advanced Natural gas combined cycle .Solar power wind power nuclear power Smart grids Enhance industrial efficiency Enhance vehicle efficiency 43 % of GT of CD2 Mitigated in 2050 "Enhance building efficiency CH4, H2 & fuel cell Table 2 has been generated to summarize the many remaining issues that need resolution via an expanded R,D&D program if these technologies are to play a major role in reducing C02 emissions in a time frame consistent with the need to limit warming to 2C or below. 17 17cv1906 Sierra Club v. EPA 6/22 Production ED 001523 00008173-00017 Table 2. Low C technology R,D&D priorities for key sectors Sector Power Generatio n & Industrial Sources Power Generatio n Power Generatio n Power Generatio n Power Generatio n Power Generatio n Mobile Sources Mobile Sources Technoloav Carbon Capture and Storage Nuclear Poweradvanced & next generation SolarPhotovoltaic and Concentratin g (renewable) Smart Grids Wind Power (renewable) Fuel Switching coal to gas Electric & Hybrid Gasoline and Diesel Hydrogen Fuel Cell Blue 2050 Impact , Gt 9 3.1 2.5 1.5 1.4 1 1.8 1.5 Current State of the Art Early commercialization for coal with many demos having cost overrun & operating issues Commercial BWR,PWR; Developmental: Generation 111+ and IV: e.g. Pebble Bed Modular Reactor First generation commercial Early Commercial, with active research focused on next generation technologies Commercial (on shore) Commercial (w/o CCS) Early commercial First generation vehicles recently introduced Issues High capital costs, 20-30% conversion efficiency degradation, complexity and potential reliability concerns; Underground Storage: Cost, safety, efficacy and permanency Deployment targeted by 2030 with a focus on lower cost, minimal waste, enhanced safety and resistance to proliferation. Solar resource intermittent and variable, although costs have been reduced further efficiency/cost reductions needed Telecommunications cost high, security concerns and questions regarding consumer acceptance/participation Costs very dependent on strength of wind source, large turbines visually obtrusive, intermittent power source Effectiveness of CCS on natural gas generators; environmental issues re. hydro fracturing For electric plugs-in, mileage (battery) limitations; charging durations and high purchase prices High fuel cell vehicle costs, H2 transport, storage & safety issues, requires massive hydrogen fueling infrastructure Technoloav R.D&D Needs High, : Demos on next generation technology on a variety of coals, hot gas cleanup research; enhanced Underground Storage program with long term demos evaluating large number of geological formations High, Demonstrations of key advanced technologies with complimentary research on important issues; commercialization of fusion technology could be transformational, might be possible, late to mid century High: research needed to develop & demo cells with higher efficiency, & lower capital costs; develop/commercialize affordable storage technology High, Enhanced smart grid modeling, reduce telecommunication cost component, demonstrate effectiveness in maximizing solar and wind power production in overall mix Medium, higher efficiencies, off shore demonstrations. Affordable storage technology High, hydro fracturing environmental mgt., CCS demos, needed, especially in the U.S. High, battery improvements in storage capability, cost and lifetimes important High, fuel cell improvements in costs, efficiency and reliability needed. Analysis of fuel cell environmental &cost benefits needed to justify massive H2 infrastructure required One technology warrants particular attention. Carbon Capture and storage (CCS) is a critically important technology that was expected to be widely applied to existing and new coal-fired generators and major industrial sources. In the U.S, it has the potential to be applied to modern natural gas fired generators as well. There are several variations of this technology, but they all are designed to capture C02 from flue or 18 17cv1906 Sierra Club v. EPA 6/22 Production ED 001523 00008173-00018 industrial gases, compress and transport the C02 for permanent storage, typically in underground saline aquifers or Enhanced Oil Recovery (EOR) operations. Such technology is particularly important for relatively new, efficient coal-fired power plants in China and India. Without retrofitting with CCS, such facilities will be super emitters of C02 over their 40 to 50 year life, since economic considerations suggest it is unlikely they will be shut down early given their projected lifetime. Starting about 10 years ago, a large number of CCS pilot and demonstration units were initiated. However, according to the MIT Carbon Capture and Sequestration Technologies database15, 43 of these projects have been terminated or are in an inactive status. Of the terminated/inactive projects, 15 were in the U.S,, and 21 in Europe. They ranged in size from small 50 MW(e) slipstream units to 1600 (MW(e) full scale facilities. Reasons for the terminations include: lack of regulatory or financial incentives, funding constraints, overruns, unexpected technical difficulties, and public resistance to C02 transport and storage operations. Fifteen projects are still active; two under construction and one, the Boundary Dam Plant of SaskPower a 160 MW unit, may be prohibitively expensive. The capture technology utilized for this project is post combustion Amine scrubbing. Although this is closest to the state of the art of the available capture technologies, it is inherently inefficient with parasitic losses in the 25-30% range. An example of a promising second generation CCS technology is the Net Power oxy-combustion supercritical process16. Such technology has the potential to eliminate the massive parasitic heat losses associated with current generation technologies. Net Power has a 25 MW(e) demonstration plant under construction in LaPorte Texas. The future of the current generation of CCS technology is uncertain, in light of cost, energy efficiency penalties, and concern with the safety and efficacy of underground storage. There is also a lack of incentives, such as a price for Carbon, to encourage utilization of such a high risk technology. Given the importance of next generation low carbon technologies and practices, is the global community funding research, development and demonstration at an appropriate level? Figure 1417 summarizes IEA 19 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00019 analysis of actual versus needed global energy technology RD&D funding for key technologies required achieving their Blue Map 50% reduction scenario. IEA concludes that actual funding is a small fraction of what they believe is required. The total annual required funding is estimated at $40-$90 billion, whereas actual spending for these key technologies is estimated to be only $10 billion per year. The author strongly agrees that low carbon mitigation technology development is woefully underfunded. 100 90 80 70 60 50 Figure 14. Current global annual 40 RD&D funding for key technologies 30 versus needed funding (high and low ranges), billions of dollars s Current public spending uCurrent public spending needed low end of range Current public spending needed high end of range In the U.S., by far the largest component of its annual R, D&D expenditures is for the military. It has been in the $60 billion range in recent years, about half of all such expenditures. Figure 1518 shows funding trends in the non-military categories. As can be seen, energy related research is in order of $3 billion in recent years; far short of what is needed if the U.S. wants to play a leadership role in developing the next generation low Carbon technologies capable of protecting the planet for future generations. Figure 15: Trends in U.S. nondefense R&D by function, billions constant FY2016 dollars 20 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00020  Health Space Energy n Other Mat. Res./Env, cGen. Science 1953 1958 1963 1968 1973 1978 1983 1988 1993 1998 2003 2008 2013 From AAAS: Historical Trends in Federal R&D (2016). Reprinted with permission from AAAS So where do we stand; is it too late to recover, i.e., limit warming to below 2C ? Humanity has dug itself a very deep hole. Driven by global industrialization and population growth vectors, humankind has emitted over 1.5 trillion tons of C02 in the atmosphere substantially changing the heat transfer characteristics of the atmosphere. Methane and Nitrogen Oxide emissions have been emitted in large quantities as well. On our current emission trajectory, we are approaching global warming of 1,5C and are only ~30 years away from the 2C warming level, which is considered a marginally acceptable maximum level by the scientific community. 4C warming looms as a real possibility, later this century. As Table 1 indicates, warming in the 3 to 4C range will lead to disastrous food, water availability and health impacts and widespread species extinctions. The recent UN COP agreement, if successfully implanted, would only modestly lower the growth rate of GHG emissions; and is only a small step in the right direction. Even assuming all countries meet their NPDs, 2100 warming is projected at a potentially catastrophic 3.5C. 21 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00021 It is noteworthy that Donald Trump, recently elected as President of the U.S., has said19 he would "cancel the agreement" because "it is bad for business". Given the reality of economic competition between nations, if the U.S., with the world's largest economy and the greatest per capita emissions, refuses to act responsibly, the probability that other countries would be willing to drastically alter their energy infrastructure, would be substantially lowered. This does not bode well for successful implementation of this or any other mitigation agreement. As the previous analysis indicated, time is not on humanity's side. In order to have a chance to limit warming to 2C or lower, global emissions must peak within about ten years followed by substantial annual reduction of emissions for decades. In order for this aggressive mitigation scenario to play out, the following conditions would need to be met: -the international community must agree to such a dramatic mitigation program, which would require near term low carbon restructuring of the energy global infrastructure with the aggressive phase-out of fossil fuels in the energy mix. -Affordable, practical low-C technologies and practices would need to be commercially available within the next ten years. Of particular importance would be CCS technologies, advanced nuclear generators, low cost renewable generation with energy storage capability, efficient buildings and low emission vehicles. See Table 1 for more details. -Given the importance of methane, N20 and HFC emissions (see Figure 11), the international community must agree on emission reductions for these pollutants as soon as possible. For methane, leakage from oil, gas and coal operations are particularly important. Agriculture operations are important sources for both methane and N20. Barring unexpected breakthroughs in technology and fundamental changes in current political realities, the probability of reducing global emissions in a time frame consistent with limiting warming between 1.5 and 2C appears very low. So in answer to the question "can humanity recover from decades of unconstrained emissions of greenhouse gases and keep warming in the 1.5 to 2C range." The answer is, 22 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00022 no; it appears unlikely. However we must move aggressively to limit warming to the lowest value practical. Current projections suggest we are heading toward 4C warming later this century, with potentially catastrophic impacts. Given that reality, the following appears to be the most rationale steps that can be taken to minimize the damage: What steps should be taken to minimize the damage? -The scientific community must upgrade its efforts in educating the public on the seriousness of this problem and the mitigation actions necessary to ensure the habitability of the planet for the 9 billion people who will call Earth their home later this century. Such education should be targeted at all levels, from national leaders down to individual citizens. Such education is needed, if we are to put the importance of this problem in perspective, relative to those much less critical issues receiving much more attention and funding. Graphics such as this one (Figure 16), supplemented by the message that the habitability of our planet is at risk, may be helpful. -Adaptation strategies need to be developed at the international and national levels. As indicated earlier, significant climate change impacts are already occurring and it is too iate to avoid even more serious23 23 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00023 impacts in the years ahead. Developing countries are iikeiy the first to be seriously affected, and need to be ready to minimize the damage. The U.N. COP provides a useful fact sheet20on the adaptation challenge. -Put a price on carbon at the national and international levels, as soon as possible. Given the serious impacts associated with climate change it clearly reasonable to put a price on the perpetrator of these impacts. This would provide the financial incentive for humanity to rapidly leave fossil fuels behind in favor of low C technologies and practices. An example of a potentially powerful carbon pricing concept is the Carbon Fee and Dividend Program proposed by the Citizen's Climate Lobby in the U.S.21 This concept involves a steadily increasing substantial "fee" on fossil fuels at the mine, well or port of entry. Then 100% of the fees, minus administrative costs, would be returned to households on a monthly basis. In order to discourage businesses from relocating, import fees will be imposed on products imported from countries without a carbon fee, along with rebates to US industries exporting to those countries. A Regional Economic Models Inc. study22 concluded that in the U.S., carbon fee-and-dividend could reduce C02 emissions 52% below 1990 levels in 20 years and that recycling of the revenue creates an economic stimulus that adds 2.8 million jobs to the economy with a $70-$85 billion annual increase in the GDP from 2020 on. Also, due to a decrease in fossil fuel combustion, reductions in air pollution levels could prevent 227,000 premature deaths over a 20 year period. -If we are to peak emissions in the near term and reduce them aggressively from that point on, new and upgraded low C technologies will be needed. Given the woefully inadequate funding of such technologies discussed earlier, a major increase in R,D,D&D is needed. As shown in Figure 14, the world spends about $10 billion annually on energy related research, $3 billion of which is by the U.S (Figure 15). As a point of reference, the world spends $1.7 trillion annually on military expenditures. Of this the U.S spends $600 billion23, equivalent to the sum of expenditures of the next eight most highly funded countries. As another point of reference, it has been estimated that the financial cost of the Iraq war (2003-2010) for the U.S., exclusive of cost to our allies and Iraq, was in the order of $3 trillion24. If we were willing to spend such an enormous sum on such an unproductive enterprise, shouldn't we be willing to make a 24 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00024 much more modest investment to develop and demonstrate the technologies needed to protect the planet for future generations? As indicated in Figure 14, IEA estimated required annual funding levels in the range of $40 to $90 billion for such a program. Table 2 summarized some of the issues and R,D&D needs for the power generation, industrial and mobile source sectors. Given the monumental mitigation challenge, I argue that a major focus of such a program should be on transformational technologies, i.e., those that could yield scientific/engineering breakthroughs that can yield new or dramatic improvements of affordable, effective low C technologies. A relevant program which is focusing on such transformational technologies is the U.S. Department of Energy's Advanced Research Projects Agency-Energy (ARPA-E)25 This program would greatly benefit from a major increase in funding, which was only $291 million in FY 2016. What else should be considered? Although this paper focuses on low-carbon technologies and practices, the mitigation challenge may go beyond what is feasible by low C technology alone. As illustrated in Figure 7 via social/cultural mitigation resource-intensive culture to a more sustainable model. Such societal changes could be encouraged by mandating material recycling programs, mass transit, and land practices that maximize vegetative sequestration of atmospheric C02. More difficult and controversial transitions involving population growth and dietary choices may also be necessary. Reducing resource demands not only has the potential to reduce GHGs; co-benefits will include improved air and water quality, improved ecosystem services (e.g., forest and ocean health), and reduced mineral resource depletion. It should be noted that geoengineering concepts are conceptual mitigative approaches that at least in theory, could buy humanity some time to dramatically reduce GHG emissions. Some see them as a delaying tactic or as a possible "last resort" action to limit catastrophic climate change. Geoengineering measures attempt to compensate for GHG emissions via two fundamentally distinct approaches: (1) intentionally changing Earth's solar radiation balance, or (2) removing C02 from the atmosphere. Figure 179describes potential geoengineering concepts. 25 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00025 Solar Radiation Management (SRM) 1 Lagrange pant solar I (flllWH I lowoitM solar minors i sixk;i,' oa'ticies Aerosol injection via airplanes, balloons, or artillery ; Marin cloud promotion via ; cloud condensation nuclei j injection by satellite-guided j autonomous ocean-going vessels . Paint urban roofs white Change land use patterns tram mm to NgN iptomm grasslands or change tree species) Aftorostation or reforestation Forestry: harvest and replant with genetically modified trees . Algae on Artificial trees Or capture4) Figure 17: Solar Radiation and Atmospheric CO2 Removal Geoengineering Concepts; Floating white {*Mfc Mis or other ourfec* setecton | * Fertilization: - via added iron, volcanic ash. Surfeoe fo tqrer with irtwwtiew churning boat* phosphate - using pfp<?1 to bring up nyfnt ,, jathefifig ling Hmeetora or mm ash. increasing ocean afMHntty and capacity to absorb c artxm In recent months there has been much discussion of the CO2 atmosphere removal option, which has been deemed necessary to meet warming targets since it is unlikely emissions will be reduced in time to limit temperature increases greater than 2C. This is sometimes referred to as the negative CO2 emissions option. However, this approach, as well as ail the options mentioned in Figure 16, is only at the conceptual stage with serious performance, impact and economic issues. However, given the magnitude of the mitigation challenge discussed, such approaches warrant serious feasibility evaluations, as soon as possible. Conclusions We are losing the climate change mitigation challenge. Since it appears unlikely that we can limit 26 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00026 warming to 1.5 to 2C, the task before us is to minimize the warming using the recent Paris COP agreement as a critical first step. The goal should be to put a ceiling on global emissions as soon as possible and then rapidly decrease emissions annually for decades. The following steps are deemed critical in the near term: put a price on Carbon, fund a dramatically expanded iow C technology R,D&D program and conduct serious adaptation efforts. Also, upgraded communication efforts are needed to educate the public, and their leaders, on the seriousness of this problem and the actions necessary to protect the habitability of the planet for the 9 billion people who will call Earth their home later this century. Finally, this literary perspective on this monumental challenge, describes a bargain we cannot accept: On the highway to hell, Faust met a devil who said to him: "Give me ail your tomorrows, all your children and all your children's children, and I will make today for you, a paradise." Derived from: https://robertscribbler.com/2014/03/05/a-faustian-barqain-on-the-short-road-to-hellI ivi nq-i n-a-wor Id-at-480-co2e/ REFERENCES 1. The European Earth Observation and Monitoring Programme (ECMWF), Copernicus, Earth on the edge: Record breaking 2016 was close to 1.5C warming. Available at: https://climate.copernicus.eu/news-and-media/press-room/press- releases/earth-edqe-record-breakinq-2016-was-close-t5%c2%B0c-warminq (accessed January 20, 2017) 2. United Nations Treaty Collection: Chapter XXVil Environment 7.d Paris Agreement (2015) Available at https://treaties.un.orq/paqes/ViewDetails.aspx?src=TREATY&mtdsq no=XXVH-7d&chapter=27&clanq= en (accessed October 1,2016) 3. M. Meinshausen. S. 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Citizens' Climate Lobby: The Basics of Carbon Fee and Dividend (2016) available at https://citizensclimatelobbv.org/basics-carbon-fee-dividend/ accessed on June 2, 2016 28 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008173-00028 22. REMI: The Economic, Climate, Fiscal, Power, and Demographic Impact of a National Fee- and-Dividend Carbon Tax (2015) http://citizensclimatelobbv.org/wp- content/uploads/2014/06/REMI-carbon-tax-report-62 accessed on June 1 2016 23. Wi ki ped ia: Annual Military Expenditures https://en.wikipedia.org/wiki/List of countries by military expenditures accessed June 1, 2016 24. Wikipedia: The Three Trillion Dollar War https://en.wikipedia.org/wiki/The Three Trillion Dollar War#References accessed November 1,2016 25. ARPA-E webpage: https://arpa-e.enerqv.gov/ accessed November 2, 2016 29 17cv1906 Sierra Club v. EPA 6/22 Production ED 001523 00008173-00029