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Clean Energy or Fossil Fuels? A Review of Existing “Clean” Energy Standard Proposals from Members of Congress

by Sarah Lutz, climate campaigner

Friends of the Earth
5 min readMay 12, 2021


In 2012, then President Obama alarmed climate activists during his State of the Union by saying,

“The development of natural gas will create jobs and power trucks and factories that are cleaner and cheaper, proving that we don’t have to choose between our environment and our economy.”

A few minutes later, the President implored Congress to pass a Clean Energy Standard. The two issues — natural gas and Clean Energy Standards — have been deeply connected since the inception of the term. The most prominent proposal from a decade ago, from New Mexico Senator Jeff Bingaman in 2012, was written to explicitly count natural gas as clean energy.

A decade later, we should not be repeating the same mistake. Natural gas, a fossil fuel, should never be included in a clean energy definition. Yet Congress continues to propose “Clean” Energy Standards that bundle dirty energy with truly renewable sources.

What is a Clean Energy Standard (CES)?

A Clean Energy Standard (CES) has been touted as the solution to our reliance on fossil fuels in the power sector. Very basically, CES proposals set a timeline for utilities to achieve a target carbon emissions rate. A core principle of CES is “technology neutrality,” meaning that any power source can qualify as “clean” if it meets the emissions target. A logical emissions target for a CES would be zero, but most proposals incentivize natural gas by allowing this dirty energy to claim “partial credits” in order to meet clean energy targets. This results in a giveaway to polluters that greenwashes gas and other false climate solutions.

The concept of a CES was explicitly designed to allow for gas and other dirty energies to qualify as clean energy. The policy was designed specifically to be vague and to obfuscate public discourse around what types of energy should and should not qualify

What are the current CES proposals?

Examining the major CES proposals under consideration by Congress demonstrates the danger of allowing fossil fuels to qualify as “clean.”

  • CLEAN Future Act: The only proposal with anything resembling the 2035 emissions target championed by the Biden administration is the CLEAN Future Act, a bill from Chairman Frank Pallone of the House Energy & Commerce Committee. But Pallone’s CES undermines its own timeline by sacrificing the definition of ‘clean’ and allowing gas to operate unchecked for over a decade, before still never reaching the ‘zero’ emissions claimed by 2035.
  • Clean Energy Standard Act of 2019: Another CES proposal, introduced in 2019 from Senator Tina Smith, does not attempt to claim ‘zero emissions’ until 2050, but similarly fails to address natural gas. Although it has a more stringent target for uncaptured fossil fuel emissions, it still includes a baseline for partial credits that could benefit many gas power plants.

The actions we take in this decade are pivotal in keeping global warming below 1.5 C. President Biden has pledged a 50% reduction in GHG emissions by 2030, and decarbonizing the power sector will be a crucial piece of those reductions. A CES that does not even start to phase down natural gas before 2030, such as the Pallone standard, cannot claim to be part of the climate solution.

How does a CES count natural gas as “clean”?

The Pallone CES proposal implements tiered emission intensity benchmarks. The first decade allows for any power generation that produces less than .82 metric tons of carbon per MWh to generate a partial “zero emission” credit. This emissions benchmark will lead to no significant reduction of natural gas. The target is so generous to polluters that fewer than 1% of gas-powered facilities would be excluded from qualifying for the standard. In fact, facilities eligible to generate partial credits under the Pallone standard emitted 573 million tons of carbon dioxide in 2019. That’s a lot of pollution for facilities receiving clean energy credits.

Some advocates claim that the .4 metric tons per MWh baseline of the Smith CES would eliminate gas from the generating mix. This is an assumption based on the EPA accurately and aggressively measuring leaking methane emissions and factoring them into the analysis (see below).

The truth is that even the more aggressive baseline of .4 metric tons of CO2 per MWh is still potentially very generous to frackers. In fact, a careful look at EPA electricity and emissions data from 2019 reveals a majority of existing gas generation would be eligible to receive credits. That data shows that:

  • 187 natural gas facilities across the country had stack emissions low enough to generate partial credits under the Smith baseline.
  • These eligible natural gas facilities were responsible for generating 808 million megawatt hours of electricity, or 64 percent of the total power generated by gas power plants across the country
  • These same eligible natural gas facilities emitted 335 million tons of CO2, or 58 percent of all the CO2 emissions from existing gas power plants.

In theory, both the Pallone and Smith CES proposals require the emissions from gas plants to consider methane leakage. Some estimates show that when super-polluting methane leaks from natural gas infrastructure, the results can make the fuel even dirtier than coal. But this lifecycle measurement would have to be implemented by the EPA. Although it is possible that the agency could accurately and aggressively measure lifecycle emissions, another possibility is the agency succumbing to political pressure from either the fossil fuel industry or a future Presidential administration.

In the past, policies like the EPA’s Renewable Fuel Standard have required the measurement of lifecycle emissions. But the agency has often failed to faithfully deliver on this mandate, to the detriment of our air, water, and climate. Therefore, we must assume that the EPA may substantially underestimate the risk of methane leaks or fail to fully consider them at all. This would have a substantial effect on the inclusion of natural gas in CES proposals — to the detriment of both communities and the climate.

Conclusion: Why we need a Renewable Energy Standard

If we are serious about addressing climate pollution in the power sector, we must adopt a Renewable Energy Standard (RES). Rather than give polluters a pass under the guise of technology neutrality, an RES is specific about what power sources do and do not qualify as ‘clean’. False climate solutions such as natural gas (with and without CCS), burning woody biomass, factory farm gas, landfill gas, and nuclear energy only prolong our dirty energy economy. The science is clear, we must transition to renewable sources of energy, such as wind and solar, while investing in conservation, storage and efficiency. This vision is obtainable. The obstacles standing in its path are not technological, they are political.



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