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Direct Testimony of Jeremy Fisher, Ph.D. On Behalf of Sierra Club
Jeremy Fisher, Ph.D., testifying for the Sierra Club, argues that Kentucky Power Company's (KPCo) analysis erroneously favors retrofitting the Big Sandy 2 unit. He identifies significant flaws in the Strategist and Aurora models, including underestimated capital costs for the retrofit, overestimated costs for natural gas combined cycle (NGCC) replacements, and an unrealistically low carbon dioxide (CO2) price forecast. Fisher asserts that when these errors are corrected and off-system sales are properly allocated, alternatives such as NGCC replacement or market purchases are substantially more cost-effective than the FGD retrofit.
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Document type: Report
Fossilized Thinking: The World Bank, Eskom, and the Real Cost of Coal
The report analyzes a 3.75 billion dollar World Bank loan to Eskom Holding Limited for the Eskom Investment Support Project in South Africa, which included a 4,800 MW coal-fired power plant. It asserts that the World Bank violated its own Operational Policy 10.04 (OP 10.04) by failing to fully consider environmental and social externalities in the project's Economic Evaluation. The authors argue that this failure renders the evaluation inaccurate and suggests a broader pattern where the World Bank over-invests in large-scale centralized energy projects—including coal, oil, gas, nuclear, and large hydro—by overstating benefits and ignoring negative costs.
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Document type: Report
FOSSILIZED THINKING
The report examines the World Bank's 3.75 billion dollar loan to Eskom for the Medupi coal-fired power plant, asserting that the Bank's Economic Analysis ignored critical environmental and social costs. It highlights failures to assess transboundary impacts on Botswana, Zimbabwe, and Mozambique, as well as domestic risks regarding water scarcity, water quality, and air pollution. The authors argue that this pattern of under-valuing externalities leads to over-investment in large-scale centralized fossil fuel projects at the expense of decentralized renewables.
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Document type: Report
A Risky Proposition
The document outlines the financial hazards of investing in new or retrofitted coal plants in the U.S., citing competition from natural gas and renewables, rising fuel costs, and the likelihood of future carbon pricing. It highlights that coal is no longer the low-cost option it once was and that many existing plants are inefficient and ripe for retirement. The report suggests that the U.S. can replace most coal power with renewable energy, demand reduction, and natural gas within 15 to 20 years.
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Document type: Executive summary
A Risky Proposition
The report details the financial hazards of investing in coal power, highlighting that new coal plants are now more expensive than many cleaner options. It identifies several risk factors: eroding market share due to energy efficiency, renewables, and natural gas; volatile coal prices driven by global demand (especially from China and India); and high, unpredictable construction costs. Additionally, the document emphasizes the financial liabilities posed by EPA regulations regarding air toxins, coal ash, and cooling water, as well as the long-term risk of carbon pricing. It concludes that the traditional cost and baseload advantages of coal have disappeared, making it an unacceptably risky investment compared to a transition toward a diversified, sustainable energy system.
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Document type: Report
Rule consistency of grid emission factors published by CDM host country authorities
The report examines the consistency of grid emission factors (grid EFs) published by host country DNAs with CDM rules. It finds that most DNAs provide insufficient data for external verification and identifies overestimations of grid EFs and coal benchmarks in China and India. Specifically, it notes inconsistent sampling in China and the omission of non-CDM renewable plants in India's build margin calculations. The study estimates that these deficiencies led to an over-crediting of 11 million pre-2012 CERs for electricity-related projects in these two countries, representing approximately 2.5% of their total CER volume.
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Document type: Report
EPA’s Blind Spot: Hexavalent Chromium in Coal Ash
The report documents the presence of hexavalent chromium, a known carcinogen, in leachate from coal ash disposal sites and groundwater across the United States. It highlights a discrepancy between the EPA's recognition of the chemical's toxicity in drinking water and its failure to account for ingestion risks in its coal ash risk assessments. The document provides evidence from EPA, DOE, and EPRI studies showing that chromium leaching from coal ash is nearly 100% hexavalent and often exceeds safety standards by thousands of times. It concludes that the EPA must designate coal ash as a hazardous waste under the Resource Conservation and Recovery Act to protect public health.
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Document type: Report
Scientists’ Statement on the Clean Air Act
A statement from 2,505 scientists supporting the EPA's authority to regulate greenhouse gas emissions under the Clean Air Act to protect public health and address climate change.
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Document type: Statement
Cheering Long Awaited Rules
The author supports the EPA's plan to propose carbon performance standards for power plants by July 2011, arguing that such regulations are necessary in the absence of federal legislation to drive clean energy investment and reduce harmful emissions. The text emphasizes that while coal-fired plants are a major source of pollution and 40% of U.S. carbon emissions, phased-in regulation and the development of a robust carbon capture and storage (CCS) industry are the most effective paths toward climate stabilization.
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Document type: Statement
mobiliser, resister, transformer
This report highlights the achievements of Friends of the Earth International (FoEI) over four decades, detailing specific campaigns against extractive industries, pollution, and unsustainable development. It documents legal victories, such as the ban on open-pit mining in Costa Rica and the recognition of water as a human right in Uruguay, as well as grassroots successes in reforestation in Belgium and the protection of eucalyptus forests in Australia. The text emphasizes the role of international solidarity and legal action in challenging neoliberal globalization and protecting the rights of indigenous peoples and local communities.
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Document type: Report
mobilise, resist, transform and successes 40 years of struggles
The report documents various environmental and social justice campaigns led by Friends of the Earth (FoE) member groups across the globe. Key achievements include the 2008 UK Climate Change Act, a ban on open-pit metal mining in Costa Rica (2010), and the cessation of commercial whaling in Spain (1985). The document also details ongoing resistance against coal-fired power plants in Germany and Scotland, gas flaring in Nigeria, and the impact of large-scale dams in Mozambique, South Korea, and the Philippines. It emphasizes a strategy of combining grassroots mobilization, legal challenges, and international solidarity to combat corporate globalization and protect indigenous and community rights.
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Document type: Report
Sustainable energy solutions for South Africa
The report documents a 2010 conference of the South African Civil Society Energy Caucus, focusing on the lack of transparency and public participation in the development of the second Integrated Resource Plan (IRP2). It critiques the government's continued reliance on coal and nuclear power, highlighting the failures of the Pebble Bed Modular Reactor (PBMR) and the environmental risks of radioactive waste in the Witwatersrand goldfields. The document advocates for a 'just transition' toward renewable energy, specifically wind and solar, while calling for an independent system operator to resolve conflicts of interest within Eskom.
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Document type: Report
Development and Climate Change: Convergent or Divergent? A Look at South Africa's Coal Dependency and its Green Targets
South Africa faces a conflict between its development goals—focused on poverty alleviation and economic growth—and its climate targets, as 90% of its electricity is generated from coal. While the country has proposed ambitious emission cuts of 25% by 2020 and 42% by 2025, it continues to expand coal capacity through projects like the Medupi and Kusile plants to address electricity supply constraints. The document argues that development and climate mitigation can converge through an innovative economic agenda that exploits green market opportunities to create a new labour-absorbing industry.
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Document type: Research paper
The Toll From Coal
The report estimates that fine particle pollution from existing U.S. coal plants would cause nearly 13,200 deaths and over 20,000 heart attacks in 2010, with a total monetized health cost exceeding $100 billion per year. While emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx) have declined since 2004 due to the installation of over 130 scrubbers and regulations like the Clean Air Interstate Rule (CAIR), the burden remains high, particularly in the Midwest, South, and Mid-Atlantic regions. The authors argue for a stronger Transport Rule and national emission caps to further reduce these health risks.
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Document type: Report
EPA’S PROPOSAL FOR FEDERAL IMPLEMENTATION PLANS TO REDUCE INTERSTATE TRANSPORT OF FINE PARTICULATE MATTER AND OZONE
The Clean Air Task Force (CATF) supports the EPA's proposed Transport Rule to replace the judicially invalidated Clean Air Interstate Rule (CAIR) but argues it should be strengthened to further reduce sulfur dioxide (SO2) and nitrogen oxides (NOx). CATF specifically advocates for the passage of S. 2995, the Clean Air Act Amendments of 2010 (CAAA of 2010), asserting it would deliver greater emissions reductions, save more lives, and provide more regulatory certainty than the Transport Rule alone. The testimony details the severe health and environmental impacts of power plant emissions, including premature death from fine particulate matter, acid rain damage to eastern ecosystems, and ozone-related crop losses.
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Document type: Statement
The Carbon Capture and Storage Imperative
The report argues that carbon capture and storage (CCS) is essential to meeting mid-century climate goals because coal remains a dominant global energy source. It proposes a three-phase industry development model: a 'pioneer phase' to eliminate technical risks, a 'cost reduction phase' to scale deployment to 50 GW, and a 'mature industry phase' for deep emissions reductions. Key recommendations include a $20 billion investment for a diverse portfolio of pioneer projects by 2018, the implementation of GHG emissions performance standards for new and existing coal and gas plants, and the creation of Geologic Sequestration Utilities (GSUs) to manage CO2 storage. The report also emphasizes international collaboration with China and the use of reverse auctions to distribute financial incentives efficiently.
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Document type: Report
The Health Costs of Energy
The document outlines how transitioning away from fossil fuels reduces health costs via three primary channels: mitigating air and water pollution, reducing obesity through active transportation, and lowering climate change risks. It provides specific 2005 cost estimates for health damages from coal-fired plants ($62 billion), natural gas plants ($740 million), and vehicles ($56 billion). The text emphasizes that obesity currently represents a larger health cost burden in the United States than air quality impacts and suggests that energy policies should be evaluated based on total costs and benefits per unit of energy or distance.
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Document type: Briefing
Optimal Abandonment of Coal-Fired Stations in the EU
The study investigates the optimal abandonment of coal-fired power plants in the EU, considering uncertainties in coal, gas, and CO2 emission allowance prices. Using a three-dimensional binomial lattice, the authors find that abandonment is unlikely unless CO2 prices reach very high levels, particularly because plants can operate as peaking units. The decision is heavily influenced by the plant's remaining lifetime, thermal efficiency, and the volatility of carbon prices.
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Document type: Research paper
Using Reverse Auctions in a Carbon Capture and Sequestration (CCS) Deployment Program
The document proposes a reverse auction system for CCS deployment, where the government procures CO2 sequestration by awarding incentives to the lowest bidders. It suggests separate auctions for projects with and without enhanced oil recovery (EOR) access and a grant loan program to mitigate early development risks. The author argues that this market-based approach is more efficient than fixed-level incentives, potentially doubling the capacity deployed compared to mechanisms proposed in the Kerry-Boxer bill.
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Document type: Research paper
Burning Coal, Burning Cash
The report analyzes the financial burden on U.S. states that rely on imported coal, identifying those with the highest spending and per capita costs. It highlights a trend of increasing dependence on coal from Wyoming and international sources, particularly in the Southeast and Midwest. The authors argue that these states can redirect funds from coal imports toward energy efficiency and homegrown renewables to create local jobs and reduce carbon emissions.
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Document type: Executive summary