I’ve never seen anything like this: an academic study that assumes that a privately held power company will continuously violate state and federal environmental laws.

That’s just one of several surprising flaws in a recent paper by researchers from Duke University and the University of Calgary. The study purports to show that, under certain assumptions, exporting coal to Korea will reduce the amount of CO2 emitted per megawatt-hour of power produced globally. Yet the study is based on premises so absurd that they render the authors’ conclusions meaningless.

Wrongheaded Assumptions

The study, titled “Environmental Implications of United States Coal Exports: A Comparative Life Cycle Assessment of Future Power System Scenarios”, compares two alternative scenarios for coal consumption and exports in the Pacific Northwest.

  • A “business as usual” scenario, in which two aging coal-fired power plants in Washington and Oregon would be retrofitted to comply with state and federal air pollution laws, and then continue to burn coal from the Powder River Basin (PRB) long into the future.
  • An “export” scenario, in which the two Northwest coal-fired plants would be promptly shut down and replaced by natural gas-fired power plants, while the PRB coal that would have been burned in the Northwest instead would be shipped to South Korea.

But designing the scenarios this way is literally absurd, for at least 3 separate reasons.

  1. The authors’ “business as usual” scenario is flat-out illegal.

The study describes its baseline scenario—under which retrofitted coal plants in Centralia and Boardman continue to burn coal indefinitely—as “business as usual.”

Yet this “business as usual” scenario violates both state and federal law. There is no room here for interpretation or nuance; no ifs, ands, or buts. According to SB 5769, signed by Washington’s governor in 2011, one of Centralia’s two generating units must emit no more greenhouse gases per megawatt-hour than a modern natural gas-fired power plant by 2020. By 2025, the second boiler must follow suit. Soon after the law was passed, the state revised its federal Clean Air Act State Implementation Plan (SIP) to reflect the change in emissions. The EPA approved the SIP, so the Centralia closure plan now has the force of federal law.

The case is similar for Boardman: Oregon’s Department of Environmental Quality, as well as federal regulators, have approved Portland General Electric’s (PGE) decision to close the Boardman coal plant by 2020. It’s literally preposterous to assume that illegally retrofitting Centralia and Boardman to burn coal indefinitely represents “business as usual.”

  1. The “business as usual” scenario makes absolutely no economic sense.

PGE has stated time and again that retrofitting Boardman, and continuing to operate the plant past 2020, would be uneconomic. As The Oregonian reported, the utility lobbied to close the plant early:

Based on its analysis of carbon and natural gas prices…PGE maintains that a 2020 shutdown would be the low-cost, least-risk plan for utility ratepayers and shareholders.

The Oregonian later described cost savings from early closure of the plant:

It allows PGE to install $60 million to $90 million of pollution controls instead of the $500 million that would have been required for PGE to operate the plant through at least 2040. Given that cost differential, PGE concluded that closing the plant early was less expensive.

So not only is the “business as usual” scenario illegal, it is actually a crazy business proposition that was explicitly repudiated by Boardman’s owner.

  1. There is no logical connection whatsoever between the two scenarios.

Out of the huge range of possibilities the authors could have studied, the authors happened to choose two in which the exact same amount of coal, from the exact same mines, will be shipped to the Northwest. Yet there’s literally no reason, either logical or economic, that this core assumption should have guided both scenarios. In addition, there’s literally no reason to link the closure of Boardman and Centralia with coal exports. None. They’re just not linked.

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  • So, the authors settled on an illegal and uneconomic “business as usual” scenario, and designed a second scenario that arbitrarily linked coal exports with the closure of the coal plants at Centralia and Boardman. Those core assumptions—illegal, uneconomic, and illogical as they are—rig the entire study in favor of exports.

    What benefits, again?

    What’s more, the purported “benefits” of coal exports largely vanish under scrutiny. For example, the study found that low-energy PRB coal would actually produce slightly more CO2 per megawatt-hour than the typical mix of coal that is currently burned in Korea. It also found that shipping coal from Northwest ports to Korea could boost emissions from ocean-going vessels. So when the authors looked at the impact of shipping a ton of coal overseas, they found that coal exports significantly boost emissions:

    If instead of estimating emissions per MWh we had chosen to look at emissions per tonne of PRB coal combusted, the MPP export scenario would not be advantageous…In this case, combusting a tonne of PRB coal in South Korea creates 29%−36% more CO2e emissions than burning the same tonne in the U.S…As the U.S. substitutes coal for shale gas in its electricity generation, the best choice to reduce air emissions would of course be to leave the unused U.S. coal in the ground.

    Given these findings, the only way to find a climate “benefit” from coal exports is by assuming that US mining is inevitable and that exports would somehow be linked with the closure of coal plants at Boardman and Centralia—a linkage that, as we’ve seen, doesn’t even pass the laugh test.

    The Verdict: Unnecessary Errors

    There are a number of other factual and logical flaws in the study. But they pale in comparison to the deep and troubling problems with the core assumptions that inform their scenarios and guide their analysis.

    What’s so disappointing is that the authors easily could have avoided these errors. With just a few minutes on Google, or a brief conversation with literally anyone who’s familiar with the legal or economic issues of coal power in the Northwest, the authors could have designed a “business as usual” scenario that wasn’t preposterous. But instead of choosing caution, accuracy, and relevance, the authors chose a flashy headline and meaningless results. It’s a disappointment; the issue is important, and it deserves more careful treatment.