Gradual Implementation of EPA Clean Power Plan Could Increase Texas Water Savings

ARLINGTON, Virginia—Texas could save significantly more water if the U.S. Environmental Protection Agency (EPA) incorporates comments from stakeholders and adopts a more gradual implementation schedule for its new proposed rule requiring lower carbon dioxide emissions (CO2) from existing power plants, according to a new report by the not-for-profit CNA Corporation. 

Released today, “The Impacts of EPA’s Clean Power Plan on Electricity Generation and Water Use in Texas,” ( shows that the Texas power sector could cut water consumption by as much as 35% if EPA would slow down implementation of new carbon emission standards, but still keep the interim target as planned. 

Currently, the proposed rule, known as the Clean Power Plan (CPP), calls for a steep initial reduction in carbon emissions in the early 2020’s, followed by a leveling off until the final target is reached in 2029. Adopting a slower rate of carbon reductions at first, followed by steady reductions throughout the 2020’s, hitting the interim target along the way, would increase water savings from about 20% under the current proposal to 35% with this more gradual approach.  However, removing the interim target completely would save significantly less water than the current CPP proposal. Both a slower implementation schedule and removing the interim target altogether have been suggested in comments filed with EPA as part of the rulemaking process.

“Both levels of water savings are significant and would greatly reduce Texas’ vulnerability to drought,” said Paul Faeth, director of CNA Corp.’s Energy, Water, and Climate Division. “However, under EPA’s original CPP proposal, carbon emissions and water savings would drop steeply at first and then decline slowly. If EPA would accept more gradual, sustained carbon reductions, while keeping the interim target, Texas could still hit the benchmarks proposed in the rule while saving more water and further reducing carbon emissions.  This is a win-win for Texas.”  

Putting the potential water savings for Texas in perspective, the water saved with a more gradual implementation plan could fill the Cowboys’ AT&T Stadium 62 times—compared with 37 times under the current proposed rule. Moreover, nitrogen oxide (NOx) emissions—a principal cause of poor air quality in Texas—would drop significantly, by 34%, if the rule were implemented more gradually. 

Water used for electricity production varies based on a number of factors, including the fuel used, how efficient the power plant is, and how it is cooled.  For a given cooling technology, nuclear generation uses more water than coal generation does. Coal, in turn, uses more water than natural gas. Wind power does not require any water for generation, and solar power uses water only for washing.  Energy efficiency saves water and avoids carbon emissions by reducing the need for new power plants.  It also has the advantage of being inexpensive compared to new generating capacity.

For these reasons, the four building blocks in EPA’s proposed rule—(1) higher coal plant efficiency, (2) switching from coal to natural gas-powered electric generation, (3) greater use of renewable power, and (4) increased energy efficiency—would all save water.

This study explores the impact of a number of new factors, including lower solar power costs; greater use of energy efficiency to reduce the future demand for electricity; and how carbon emissions reductions and water savings would vary in different plans for implementing the CPP.  The new study includes a new baseline scenario with substantially lower forecasts for industrial solar prices than in the 2014 report. The updated prices were supplied by the Electric Reliability Council of Texas (ERCOT), which oversees the wholesale and retail electric markets in the state.  Others in Texas, including Austin Energy, confirmed the lower prices and higher forecasts for future use of solar power in the state. 

Among the key findings in the report:

  1. Currently, the proposed rule calls for a steep initial change in carbon emissions. Adopting a slower rate of implementation of the CPP, while still hitting the interim target, would increase water savings by 15%, from 20 to 35% relative to water use in 2012.
  2. If EPA dropped the interim target in its proposed rule but kept the final target, that formulation would produce a similar cut in water consumption in 2029. However, the cumulative 2020-29 savings would be less than half of that produced under EPA’s current proposal with the interim target—280,000 acre-feet versus 608,000 acre-feet.
  3. Removing the interim target would produce a similar final rate of carbon emissions in 2029, but cumulative emissions between 2020 and 2029 would be only 43% of the carbon reductions without an interim target.
  4. Lower costs for solar power could decrease water use between 2012 and 2029 by 9%, from 5% (the higher cost estimates used in the study’s original baseline scenario). If a 10% cut in electric demand were achieved through energy efficiency, water savings would amount to 12%. These measures together would bring Texas within 11% of the final target in the CPP as currently proposed.
Editor's Note: This study was funded by the Cynthia and George Mitchell Foundation. For additional information, visit or follow the foundation at @MitchFound.

< Go Back

© 2012-2024 Cynthia and George Mitchell Foundation.