Super emitters in the United States coal-fired electric utility industry: comparing disproportionate emissions across facilities and parent companies

ABSTRACT

Environmental disproportionality research shows extreme differences in the production of environmental harm by what would seem to be similar producers. Although researchers have studied disproportionality among individual facilities in a given place or within a given industry, few assess such patterns at the corporate level. We conduct a disproportionality analysis of the generation of CO₂ emissions in the United States coal-fired electric utility industry between 2010 and 2015, comparing emissions distributions across two levels: individual facilities and groups of facilities owned by distinct parent companies. Although facility-based disproportionality patterns are largely attributable to the amount of electricity a power plant generates, this proxy for size does less to explain disproportionality patterns at the parent company level: we find that a small group of parent companies generates a disproportionate share of the industry’s total emissions, even when accounting for each company’s relative contribution to the electric grid. We find that disproportionality patterns are temporally stable within both groups. These findings suggest that researchers should consider how disproportionality among pollution producers may differ depending on the unit of analysis.

KEYWORDS:

• Disproportionality
• coal
• coal-fired power
• electric utilities
• parent companies
• environmental inequality

Acknowledgments

The authors would like to thank the anonymous reviewers whose careful reviews led to a much stronger presentation of our findings. We also wish to thank the reviewers from the Early Career Workshop of the 2017 Energy Impacts Symposium for their thoughtful input on earlier drafts of this manuscript.

Disclosure statement

No potential conflict of interest was reported by the authors.

Notes

1. In September of 2010, EPA finalized an amendment to subpart A of the, ‘Final Mandatory Reporting of Greenhouse Gases Rule: Reporting of Corporate Parent Information, NAICS Codes and Cogeneration.’ This amendment required facilities to provide several new items in their reporting to the Greenhouse Gas Reporting Program (GHGRP). Per this amendment, facilities subject to GHGRP reporting began including name and location information about all related U.S. parent companies, including respective ownership percentages. We use the parent company information contained within GHGRP, aggregating all data to include subsidiaries under their corporate owners when appropriate as determined by external verification – see details in a later section.

2. For the purposes of this study and in alignment with the data used for the analyses that follow, we use the term ‘parent company’ to refer to the entities that own facilities in the electric utility industry, or ‘the highest-level U.S. company(s) with an ownership interest in the reporting entity.’ This category is not limited to the private sector and captures a variety of types of owners including investor-owned companies, municipal, state, and federal governments, and rural cooperatives, among others. See https://ccdsupport.com/confluence/display/help/Standardization+of+Parent+Company+Names+-+Style+Guide (accessed 24 February 2018).

3. In total, 41 categories of industrial facilities are required to submit data to the GHGRP under 40 CFR Part 98. The majority of these facilities generate in excess of 25,000 metric tons of CO₂ GHG emissions per year. In addition, the rule requires reporting by facilities that have the potential to release this amount of CO₂ through combustion, oxidation, or accidental releases. Agricultural and land-use industries are not required to report. https://www.epa.gov/ghgreporting/greenhouse-gas-reporting-program-and-us-inventory-greenhouse-gas-emissions-and-sinks.

4. Fuel combustion emissions from power plants are measured using continuous emission monitoring systems (CEMS). The most common type of CEMS technology extracts a continuous supply of gas from the processing point. This gas is then processed and delivered to a gas analysis system, which records gas concentrations at predetermined intervals. Although some facilities use site-specific fuel composition data to calculate emissions, coal-fired units are generally required to use CEMS. The EPA considers CEMS to be the most accurate method of measuring the quantity of emissions for most fuel types. Technical and analytical requirements for CEMS technologies are included in 40 CFR Part 60 and Part 75.

5. See https://www.epa.gov/ghgreporting/greenhouse-gas-reporting-program-and-us-inventory-greenhouse-gas-emissions-and-sinks for a comparison of the U.S. Greenhouse Gas Inventory program and the U.S. GHGRP.

6. Such reports are mandated under Title 40, U.S. Code of Federal Regulations (40 CFR), Protection of the Environment, Part 98 – an EPA rule published in 2009 following a Congressional mandate to provide a comprehensive record of GHG sources for use in the development of emissions reduction policies and programs. The program ensures accuracy and consistency of data through a multi-step process involving automated reviews, manual reviews, and pre-/post-submittal data checks.

7. https://www.epa.gov/enviro/greenhouse-gas-customized-search accessed 5 January 2018.

8. https://www.gpo.gov/fdsys/pkg/FR-2010-09-22/pdf/2010-23674.pdf accessed 15 March 2018.

9. The amendment to the Mandatory Reporting of Greenhouse Gasses rule states: ‘although in some cases, the owner or operator is also the highest-level U.S. parent company, the information currently collected under the majority of CAA programs is not designed to specifically identify the highest-level U.S. parent company, because that information is not necessary to determine compliance with particular regulatory requirements.’ https://www.gpo.gov/fdsys/pkg/FR-2010-09-22/pdf/2010-23674.pdf accessed 15 March 2018.

10. Industrial facilities are required to report to the EIA under a variety of Federal initiatives, including the Federal Energy Administration Act of 1974, the Energy Policy Act of 1992, and the Energy Policy Act of 2005. For more information, see https://www.eia.gov/about/legislative_timeline.php.

11. Crosswalk file is available for download from the EPA website at https://www.epa.gov/sites/production/…/oris-ghgrp_crosswalk_public_ry14_final.xls (accessed 15 June 2018).

12. Annual net generation, or the amount of electricity generated after electricity consumed at the facility is subtracted, is calculated in MWH. Annual net generation as reported in the EIA-923 form is subject to non-sampling error as a result of nonresponse, response errors, or data collection issues. The EIA estimates that there is a 68% chance that the true total or mean is within one relative standard error (RSE – calculated as the square root of the estimated variance, divided by the variable of interest) of the estimated total or mean and a 95% chance that it is within two RSEs of the estimate. In cases where net generation for coal-fired power generation is not available, it is estimated using a fixed ratio of 0.97× gross generation. https://www.eia.gov/electricity/monthly/pdf/technotes.pdf.

13. The Political Economy Research Institute’s Green House Gas 100 also shows these three companies as top producers of CO₂ emissions across all industrial industries in 2015 (2018).

Additional information

Funding

Early stages of work were supported by the University of Maryland and National Science Foundation under award number DBI-1052875 to the National Socio-Environmental Synthesis Center (SESYNC).

Notes on contributors

Anya M. Galli Robertson

Anya M. Galli Robertson is an Assistant Professor of Sociology at the University of Dayton. She specializes in environmental sociology and social movement studies, with a particular focus on the politics and discourse of debates over energy and natural resources. Galli Robertson recieved her Ph.D. in Sociology from the University of Maryland in 2018.

Mary B. Collins

Mary B. Collins is an Assistant Professor of Environmental Health in the Department of Environmental Studies at the State University of New York College of Environmental Science and Forestry. Her research focuses on the interdependence of social and ecological systems, disproportionalities in pollution production, and issues of equity and justice in the context of human health. Collins received her Ph.D. in Environmental Science and Management from the University of California, Santa Barbara in 2012.