EPA Proposes CO2 Emission Guidelines for Existing Coal-Fired Power Plants

On June 2, 2014, the EPA released its proposed emission guidelines for CO₂ emissions from existing power plants, called the Clean Power Plan Proposal, under §111(d) of the Clean Air Act. The proposed rule would require a 30% reduction in CO₂ emissions from existing power plants from 2005 levels by 2030. Rather than setting limits that apply directly to affected sources, EPA has proposed CO₂ performance goals for each state. The proposal would require states to develop plans to implement the emission guidelines and submit them to EPA for approval by June 30, 2016, although one-year extensions would be available for single-state plans and two-year extensions would be available for multi-state plans. States would be required to meet interim goals from 2020-2029, and meet a final target by 2030.

EPA arrived at the state goals (expressed in average pounds per net megawatt hour) by first determining that the best system for emissions reduction (BSER) for CO₂ emissions from power plants consists of two basic approaches and four building blocks. The basic approaches are (1) reducing carbon intensity from individual fuel burning electric generating units and (2) addressing mass CO₂ emissions by varying utilization level of coal, gas, nuclear, and renewable energy sources. To accomplish these two basic approaches and implement BSER for CO₂ emissions from existing electric generating units, EPA applied measures from the following four building blocks:

1. Reducing CO₂ emissions by improving efficiency by six percent;
2. Reducing the dispatch of coal units in favor of natural gas combined cycle (NGCC) units with a target of 70% of total generation from NGCC;
3. Shifting additional generation to low- and zero-carbon generation (nuclear and renewables); and
4. Increasing demand-side energy efficiency programs.

The proposal does not prescribe the means by which states will meet these goals. States have substantial flexibility in developing plans and can use multi-state, market-based approaches as long as each state’s goals are met.

The EPA will accept comments for 120 days after the proposed rule is published in the Federal Register. The Agency will also be holding public hearings in Atlanta, Denver, Pittsburgh, and Washington, D.C., during the week of July 28, 2014.