carbon pollution standards
Carbon Pollution Standards
The U.S. Environmental Protection Agency's (EPA) Clean Power Plan, proposed in June 2014, would limit carbon pollution from existing power plants.
Electric power generation is responsible for nearly 40 percent of U.S. carbon dioxide emissions – making it the largest single source. Reducing power sector emissions is a key part of President Obama’s Climate Action Plan, which aims to reduce overall U.S. greenhouse gas emissions 17 percent below 2005 levels by 2020. His June 2013 presidential memorandum directed EPA to set standards for both new and existing plants.
Under the Clean Power Plan for existing power plants, each state has its own target (due to regional variation in generation mix and electricity consumption). Overall, the rule is designed to cut emissions 30 percent from 2005 emissions by 2030, with an interim target of 25 percent on average between 2020 and 2029. EPA is expected to finalize this rule by June 2015.
In September 2013, EPA released a “Carbon Pollution Standard for New Power Plants,” replacing a March 2012 proposal. EPA proposed standards for coal- and natural gas-fired plants (measured as tons of greenhouse gas emissions per megawatt-hour of electricity produced) that states would apply at each regulated plant. EPA is expected to finalize this rule in 2014.
Explore the issues and options involved in EPA regulation of carbon pollution from power plants through the following resources.
- Blog: 5 Ideas for EPA's Clean Power Plan (December 2014)
- C2ES Comments on Proposed EPA Rule for Existing Power Plants (December 2014)
- Brief: Cross-State Electricity Load Reductions Under EPA's Proposed Clean Power Plan (November 2014)
- Cornerstone Article: Carbon Pollution Standards for New and Existing Power Plants and Their Impact on Carbon Capture and Storage (September 2014)
- Map: Energy efficiency in the Clean Power Plan (August 2014)
- Map: Renewables in the Clean Power Plan (June 2014)
- Map: Proposed state emission rate targets (June 2014)
- Q&A on EPA Greenhouse Gas Standards for Existing Power Plants (June 2014)
- Graphic: Policy options to reduce carbon emissions in the power sector (June 2014)
- Blog: EPA’s proposed carbon standard for power plants is stringent and flexible (June 2014)
- Event: Carbon Pricing: State and Federal Options (May 2014).
See video of the event, and relevant slides from Dallas Butraw, David Bookbinder, Brian Turner, and Jon Brekke
- C2ES Comments on Proposed EPA Rule for New Power Plants (May 2014)
- Brief: Carbon Pollution Standards for Existing Power Plants: Key Challenges (May 2014)
- Brief: Carbon Pollution Standards for Existing Power Plants: Issues and Options (March 2014)
- Q&A on EPA Greenhouse Gas Standards for New Power Plants (November 2013)
- Blog: EPA’s Regulation of Greenhouse Gases: What are the Facts? (January 2011)
- Brief: Events Leading to Regulation of Greenhouse Gases under the Clean Air Act (March 2010)
- U.S. Environmental Protection Agency, Carbon Pollution Standards webpage.
- Presidential Memorandum – Power Sector Carbon Pollution Standards
- Megan Ceronsky and Tomas Carbonell, Section 111(d) of the Clean Air Act: The Legal Foundation for Strong, Flexible & Cost-Effective Carbon Pollution Standards for Existing Power Plants (Washington, DC: Environmental Defense Fund, 2013).
- Samuel D. Eisenberg, Michael Wara, Adele Morris, Marta R. Darby and Joel Minor, A State Tax Approach to Regulating Greenhouse Gases Under the Clean Air Act (Washington, DC: Climate and Clean Energy Economics Project at Brookings, 2014).
- Georgetown Climate Center, Carbon Pollution Standards for Existing Power Plants: State Opportunities and Potential Benefits (Washington, DC: Georgetown Climate Center, 2013).
- Daniel Lashof et al., Closing the Power Plant Carbon Pollution Loophole: Smart Ways the Clean Air Act Can Clean Up America’s Biggest Climate Polluters (Washington, DC: Natural Resource Defense Council, 2013).
- Daniel Lashof and Starla Yeh, Cleaner and Cheaper: Using the Clean Air Act to Sharply Reduce Carbon Pollution from Existing Power Plants, Delivering Health, Environmental, and Economic Benefits (Washington, DC: Natural Resource Defense Council, 2014).
- Jonas Monast et al., Regulating Greenhouse Gas Emissions From Existing Sources: Section 111(d) and State Equivalency, 42 Environmental Law Reporter 10206 (Washington, DC: Environmental Law Institute, 2012).
- James McCarthy, “EPA Standards for Greenhouse Gas Emissions from Power Plants: Many Questions, Some Answers.” Congressional Research Service (CRS). R43127. November 15, 2013.
- Stephen Munro, EPA's Clean Power Plan: 50 chefs stir the pot (Washington, DC: Bloomberg New Energy Finance, 2014).
- National Conference of State Legislatures, States Reactions to Proposed EPA Greenhouse Gas Emissions Standards webpage.
- Conrad Schneider, Power Switch: An Effective, Affordable Approach to Reducing Carbon Pollution from Existing Fossil-Fueled Power Plants (Boston, MA: Clean Air Task Force, 2014).
- Robert Sussman, Power Plant Regulation under the Clean Air Act: A Breakthrough Moment for US Climate Policy? (Charlottesville, VA: Virginia Environmental Law Journal, 2014).
- Jeremy M. Tarr, Jonas Monast, and Tim Profeta, Regulating Carbon Dioxide under Section 111(d) of the Clean Air Act: Options, Limits, and Impacts (Durham, NC: Nicholas Institute for Environmental Policy Solutions, 2013).
- Gregory E. Wannier et al., Prevailing Academic View on Compliance Flexibility under § 111 of the Clean Air Act, RFF Discussion Paper 11-29 (Washington, DC: Resources for the Future, 2011).
In its proposed Clean Power Plan to reduce carbon dioxide emissions in the power sector, EPA has set a unique target emissions rate for each state to hit by 2030. To develop this target, EPA first determined a carbon emissions baseline (using 2012 data) based on each state’s level of CO2 emissions from fossil-fired power plants divided by its total electricity generation (including fossil-fired generation, renewable generation, and nuclear generation). Targets for 2030 were then established based on the capacity of each state to achieve reductions using the following four “building blocks” identified by EPA:
- Make coal-fired power plants more efficient;
- Use low-emitting natural gas combined cycle plants more where excess capacity is available;
- Use more zero- and low-emitting power sources such as renewables and nuclear; and
- Reduce electricity demand by using electricity more efficiently.
Since there is a wide variation among states in both emissions baseline and capacity to leverage each of the four building blocks, there is a wide variation in how much each state must cut from current emissions to hit its 2030 target emissions rate. (See Table 1.)
Each state can meet its established target however it sees fit, and does not need to leverage each building block to the extent that EPA projects. States will be able to convert their target emissions rate (pounds CO2 per megawatt-hour of electricity generated) to a mass-based standard (tons of CO2 emitted per year) to enable a cap-and-trade program. States are also free to join together and work toward an aggregated regional target.
Table 1: Building Block Reduction by State
|State||Emissions Rate of Power System, including zero-carbon generation (lbs CO2 / MWh) (2012||Block 1 (Coal-plant Efficiency)||Adding Block 2 (Natural Gas Fuel Switching)||Adding Block 3 (Renewable and Nuclear Generation)||Final Target by Adding Block 4 (Demand-side Energy Efficiency)||Total Emissions Reduction Target by 2030|
|Vermont||No affected sources|
Source: U.S. Environmental Protection Agency, Technical Support Document (TSD) for the CAA Section 111(d) Emission Guidelines for Existing Power Plants: Goal Computation, Appendix 5.
The Obama Administration today took a major step toward reducing the carbon dioxide emissions that are impacting our climate. The Environmental Protection Agency (EPA) released its “Clean Power Plan,” which leverages existing authority in the Clean Air Act to propose carbon pollution standards for existing power plants, the largest single source of U.S. carbon emissions. The proposal would cut emissions in the power sector by 30 percent by 2030, based on 2005 levels. We reviewed the basics of the Clean Power Plan with four critical questions in mind:
1. Is the standard based on emission reductions outside the power plant fence line?
The short answer is “yes.” EPA cannot require states or power plant operators to take any specific measures, but it can set the emissions target stringent enough so that it would be challenging to achieve unless certain measures are taken. EPA is proposing state-specific targets based on the capacity of each state to leverage four “building blocks.” They are:
- Make fossil fuel power plants more efficient.
- Use low-emitting natural gas combined cycle plants more where excess capacity is available.
- Use more zero- and low-emitting power sources such as renewables and nuclear.
- Reduce electricity demand by using electricity more efficiently.
Although “outside-the-fence-line” measures are not specifically required under the proposal, states would be hard-pressed to meet their targets without using programs to reduce the demand for fossil electricity, by, for example, increasing energy efficiency and encouraging renewable energy.
Looking to Figure 1, EPA has chosen the System-level Option.
Figure 1: Scope of reduction requirements
On June 2, the Environmental Protection Agency (EPA) is expected to release its proposal to cut carbon dioxide (CO2) emissions from existing power plants. This proposal is a key element of President Obama’s Climate Action Plan, and will be critical to reducing U.S emissions of CO2, the most common greenhouse gas contributing to climate change.
The proposed rule, being developed under EPA’s authority under Section 111(d) of the Clean Air Act, could be groundbreaking for at least two reasons. First, it has the potential to drive major reductions in the highest emitting sector in the United States – the power sector – which is responsible for nearly 40 percent of U.S. carbon emissions. Second, EPA has indicated that the proposal will include a number of novel policy provisions to advance low-emitting generation and energy efficiency.
At C2ES, we’ll be looking for answers to four key questions as we read through EPA’s proposal. These questions are expanded upon in our new brief, Carbon Pollution Standards for Existing Power Plants: Key Challenges.