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Reducing Carbon Emissions from Power Plants Goes National (but stays local)

costantino, jon, manatt 2On June 2, 2014, EPA, under President Obama’s Climate Action Plan, released the long-awaited draft greenhouse gas (GHG) rule for existing power plants across the nation. Officially called “The Clean Power Plan,” the proposed rule establishes state-by-state 2030 GHG goals (except for Vermont, which doesn’t have any fossil-fuel-fired power plants). The three most important questions about how EPA would handle the regulation were 1) what the baseline year would be, 2) how deep the reductions would cut, and 3) what alternatives would be counted toward that reduction. In sum, the proposed regulations call for carbon emissions cuts from the power sector of 30 percent below 2005 levels by no later than 2030 and virtually all existing state programs to reduce GHG should be able to be counted toward the reductions.

The program is to be administered under EPA’s authority under Section 111 (d) of the Clean Air Act (CAA). Accordingly, EPA is not proposing emissions rate goals or guidelines for the four affected sources located in Indian country at this time, but rather has committed to working with those Tribes and sources in the future. This action is a continuation of the Obama Administration’s pledge to use executive powers under existing CAA authority to implement his Executive Branch Climate Action Plan. Combining a state-by-state approach with a broader “outside the fence line” view of GHG reductions, U.S. EPA has attempted to craft a reduction scheme which flexibly addresses the wide variety of emission profiles in the nation’s largest source of GHG emissions, its power sector, but inevitably requires reduction from coal burning power plants. The four main reduction components to the plan are:

  1. Reducing the carbon intensity of generation at individually affected EGUs (Existing Generation Units) through heat rate improvements. [On-site efficiency improvements]
  2. Reducing emissions from the most carbon-intensive affected EGUs in the amount that results from substituting generation at those EGUs with generation from less carbon-intensive affected EGUs (including Natural Gas units under construction). [Grid management]
  3. Reducing emissions from affected EGUs in the amount that results from substituting generation at those EGUs with expanded low- or zero-carbon generation. [Increased renewables and nuclear]
  4. Reducing emissions from affected EGUs in the amount that results from the use of demand-side energy efficiency that reduces the amount of generation required. [Increased energy efficiency, or reduction in electricity demand]

One of the main questions leading up to this release was, “What would the federal government do with existing state GHG programs?” Turns out they listened to the hundreds of stakeholders who commented as demonstrated by the following excerpt from the published rule.

How Tracking/Managing Energy Consumption Drives Real Cost Savings
Sponsored By: Digital Lumens

Staying Ahead of the Curve: Strategies for Managing Emerging Regulations (NAEM)
Sponsored By: VelocityEHS

Just the Facts: 8 Popular Misconceptions about LEDs & Controls
Sponsored By: Digital Lumens

How the Industrial Internet of Things (IIoT) Can Improve Your Business Operations
Sponsored By: Digital Lumens


4 thoughts on “Reducing Carbon Emissions from Power Plants Goes National (but stays local)

  1. I’ love to attend the July 31st public hearing in Pittsburgh. No doubt the pro-coal forces will give the EPA an earful. I just hope the EPA can address their “concerns” without lumping them into the same basket as the global warming deniers as is usually the case with environmentalists.

  2. I have yet to hear a single substantive concern cited by pro-coal forces; that can properly be described as being anything other than a global warming denial. Previous attempts by those same forces to claim that other Clean Air or Clean Water rules would cost them too much or are too technically difficult or drive up the price of electricity far beyond customer abilities to pay; have all been seen in hindsight to be a bunch of baloney (at best). Besides which, focusing on classical economic arguments while ignoring the overwhelming scientific evidence of GHG climate forcings; is a typical denier meme.
    I expect the usual rounds of useless court battles and political grandstanding, followed by the inevitable (but unfortunately delayed) implementation of these common-sense and much-needed GHG reductions – even though these reductions do not go nearly far enough.

  3. What if coal could be combusted as clean as natural gas?
    The technology is coming.
    Now imagine how much “clean energy” America has available.
    We will have natural gas and coal and our renewables, solar and wind and geothermal and tidal.
    With natural gas and coal operating almost as “clean” as the renewables, America has a lot of Clean Energy for our future.
    We are also hoping that this will bring more industry to America. More industry = more jobs = better economy.

    This is America. We will make it happen!!

  4. I have a hard time believing that large-scale and widespread coal combustion will ever be made as clean as natural gas. Coal combustion releases about twice as much CO2 per unit of produced energy as does natural gas. Carbon capture and storage (CCS) seems the only technical avenue available to reduce coal’s CO2 footprint; and CCS is expensive. In addition, extensive CCS would require equally extensive infrastructure to transport and to store the resulting CO2 stream; and furthermore it imposes an energy penalty on the power plant itself, requiring yet more coal burning to make up the energy deficit. Guaranteeing little or no leakage of CO2 from long-term storage also seems fraught with uncertainties.
    And even if coal could match natural gas in CO2 output, there would still be too much anthropogenic CO2 release to avoid climate change. Our overall CO2 releases have to eventually be reduced drastically, by something like 80% – a tall order that appears to permanently rule out most fossil fuel use.
    America and indeed the world have the potential for plenty of truly clean and renewable sources of energy just by using solar, wind, geothermal, and hydropower resources combined with energy storage technologies that are admittedly still in development. In the long run, fossil fuels will be moot. The good news is that agressive development of clean and renewable energy does indeed mean more jobs and a better economy.

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