- The EIA Does Not Assess the Substantial Impacts on the Climate of the Project’s Greenhouse Gas Emissions
Page 303 of the EIA provides the following information of the project’s greenhouse gas emissions:
“In addition, CO2 emission of the project is estimated 7,319,280 t-CO2/y..”
The Matarbari 2X600 MW Ultra Super Critical Coal Fired Power Project, Phase-2, (Unit 3/4) is expected to have a 30-year operational life. This implies that over the 30-year operational life of the project it would emit nearly 220 million metric tons of CO2.
In July of 2021, the number of expected deaths caused by the emission of one additional metric ton of CO2 was estimated by research conducted at the Columbia University School of International and Public Affairs: The study states the following:
“In this study, we create an extension to DICE-2016 called DICE-EMR (Dynamic Integrated Climate-Economy Model with an Endogenous Mortality Response). We construct an additional reduced-form mortality damage function that projects the effect of climate change on the mortality rate using estimates from studies chosen from an interdisciplinary systematic research synthesis of the scholarly literature (see “Methods” section for details). We use DICE-EMR to produce a new metric that avoids some of the limitations of the SCC: the mortality cost of carbon (MCC). The 2020 MCC is the number of expected temperature related excess deaths globally from 2020 to 2100 caused by the emission of one additional metric ton of carbon-dioxide equivalent emissions in 2020. We find that in the DICE baseline scenario that results in 4.1°C warming above preindustrial temperatures by 2100, the 2020 MCC is 2.26 x 10−4 lives per metric ton in the central estimate, which implies that adding 4,434 metric tons of carbon dioxide in 2020 … causes one excess death globally in expectation between 2020 and 2100.”[1]
“We find that optimal climate policy in DICE-EMR, however, involves large immediate emissions reductions and full decarbonization by 2050. This results in 2.4 °C warming by 2100.
“If the world undertakes the optimal emissions path in DICEEMR and restrains global average temperatures to 2.4 °C, we largely avoid the temperatures where marginal increases in temperature resulting from a marginal emission today are most damaging. Therefore, the SCC and the MCC are highly sensitive to future climate policy. On the optimal emissions path the 2020 MCC drops by 53% from 2.26 × 10−4 lives per metric ton in the baseline emissions scenario to 1.07 × 10−4 lives per metric ton (see Table 1). This implies that under DICE-EMR’s optimal climate policy, adding (reducing) 9,318 tons of carbon dioxide— equivalent to the lifetime emissions of 7.3 average Americans—causes (reduces) one excess death globally between 2020 and 2100. It also implies that adding (reducing) 1,276 metric tons of carbon dioxide in 2020 … causes (reduces) 0.14 excess deaths between 2020 and 2100 in expectation on the optimal emissions path ….”[2]
This analysis allows us to calculate the mortality costs associated with the Matarbari 2X600 MW Ultra Super Critical Coal Fired Power Project, Phase-2, (Unit 3/4). For example, if the world undertakes the optimal emissions path and restrains global average temperatures to 2.4 °C by 2100, then for the eighty-year period that encompasses the operational life of the project, expected CO2 emissions from the project would cause 23,600 excess deaths.[3]
- The EIA Does Not Assess How the Project is Compatible with Recent International Agreements for Meeting the Temperature Targets of the United Nations Framework Convention on Climate Change
In November of 2021 at the 26th Conference of the Parties (COP26) to the United Nations Convention on Climate Change (UNFCC), countries around the world agreed to the following to hold the increase in the global average 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. Specifically, at COP26, the Conference of the Parties in the Glasgow Climate Pact:
“15. Reaffirms the long-term global goal to hold the increase in the global average 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;
“16. Recognizes that the impacts of climate change will be much lower at the temperature increase of 1.5 °C compared with 2 °C, and resolves to pursue efforts to limit the temperature increase to 1.5 °C;
“17. Also recognizes that limiting global warming to 1.5 °C requires rapid, deep and sustained reductions in global greenhouse gas emissions, including reducing global carbon dioxide emissions by 45 per cent by 2030 relative to the 2010 level and to net zero around mid-century, as well as deep reductions in other greenhouse gases;
- Further recognizes that this requires accelerated action in this critical decade, on the basis of the best available scientific knowledge and equity, reflecting common but differentiated responsibilities and respective capabilities and in the context of sustainable development and efforts to eradicate poverty;
- Invites Parties to consider further actions to reduce by 2030 non-carbon dioxide greenhouse gas emissions, including methane;
- Calls upon Parties to accelerate the development, deployment and dissemination of technologies, and the adoption of policies, to transition towards low-emission energy systems, including by rapidly scaling up the deployment of clean power generation and energy efficiency measures, including accelerating efforts towards the phasedown of unabated coal power and phase-out of inefficient fossil fuel subsidies, while providing targeted support to the poorest and most vulnerable in line with national circumstances and recognizing the need for support towards a just transition ….”[4]
The proposed Matarbari 2X600 MW Ultra Super Critical Coal Fired Power Project, Phase-2, (Unit 3/4) is fundamentally inconsistent with the Glasgow Climate Pact. According to Section 11.3 (Expected Project Implementation Schedule) on page 348 of the EIA, commissioning of the the Matarbari 2X600 MW Ultra Super Critical Coal Fired Power Project, Phase-2, (Unit 3/4) is not expected until 2029. The expected 30-year life of the project (See EIA at page 53) means that the project is expected to be operational from 2029 to 2059. An unabated coal power project plant emitting more than 7.3 million metric tons of CO2 per year for the years 2029-2059 is not consistent with the following elements of the Glasgow Climate Pact:
- “reducing global carbon dioxide emissions by 45 per cent by 2030 relative to the 2010 level and to net zero around mid-century”
- a “transition towards low-emission energy systems”
- “accelerating efforts towards the phasedown of unabated coal power.”
[1] Bressler, R. D. (2021). The mortality cost of carbon. Nature communications, 12(1), 1-12, at page 2.
[2] Ibid., at page 4.
[3] 220 million metric tons CO2eq x 1 excess death/9318 tons CO2eq = 23,600 excess deaths.
[4] Conference of the Parties serving as the meeting of the Parties to the Paris Agreement (13 November 2021) “Glasgow Climate Pact”
