The proposed Clean Power Plan to reduce carbon emissions from existing power plants is a long overdue turning point in America’s response to climate change.
EPA’s approach gives the states tremendous flexibility to design strategies that work best for them. States have always been incubators of innovation, and they will drive technological and policy innovation as they encourage low-cost solutions to implement the plan.
We need to encourage that innovation – by cities, states, and businesses -- to show the path forward to a clean energy economy.
C2ES submitted comments today as part of the EPA’s process to seek stakeholder input to the proposed rule before finalizing it in June 2015.
Here are five suggestions that could make EPA’s framework even better.
On June 2, 2014, the U.S. Environmental Protection Agency (EPA) released its proposed Carbon Pollution Standards for Existing Power Plants (known as the Clean Power Plan), per its authority under Section 111(d) of the Clean Air Act (CAA). The development of this rule was announced by President Obama during his June 25, 2013, climate policy speech. The Clean Power Plan would establish different target emission rates (lbs of CO2 per megawatt-hour) for each state due to regional variations in generation mix and electricity consumption, but overall is projected to achieve a 30 percent cut from 2005 emissions by 2030, with an interim target of 25 percent on average between 2020 and 2029.
See more resources and maps at the C2ES Carbon Pollution Standards Resource Page.
Why is regulation of greenhouse gas emissions from existing power plants important?
Electric power generation is responsible for nearly 40 percent of U.S. carbon dioxide emissions.
Figure 1: 2012 U.S. CO2 Emissions
Source: Energy Information Administration
Since the federal government adopted new vehicle efficiency standards last summer to address transportation emissions through 2025, the power sector represents the greatest opportunity for greenhouse gas reductions.
Figure 2: Electric Power Sector Carbon Dioxide Emissions without Proposed Emission Standards
Source: Energy Information Administration
Power sector emissions have declined over the past five years in part due to the economic downturn, increased energy efficiency, greater use of renewable energy and a switch from coal, the most carbon-intensive fossil fuel, to natural gas, the least carbon-intensive (in terms of combustion). In the absence of any policy changes, the U.S. Energy Information Administration projects that as the economy grows and natural gas prices rise slowly over the next five years, emissions will rise. The Clean Power Plan will have to push against these underlying trends.
Figure 3: Distribution of Fossil Fuel Power Plants across the Contiguous United States
What is in EPA’s proposal?
Typically, EPA regulations are set at the federal level and then administered by states. For example, EPA sets a limit on the level of smog in the atmosphere, and states then submit plans for how they will meet that standard. Once approved by EPA, states then administer these plans, known as State Implementation Plans.
The proposed Clean Power Plan is similar in that states would be given a target emissions rate, but have broad flexibility to determine how to achieve that target. Each state would be assigned a carbon emissions baseline based on its level of carbon emissions from fossil-fired power plants divided by its total electricity generation. (See our Proposed State Emission Rate Targets Map.) Electricity generation in this case includes fossil generation, nuclear, renewables, plus generation avoided through the use of energy efficiency programs. A target for 2030 is then established for each state based on its capacity to achieve reductions using the following four “building blocks” identified by EPA:
1. Make fossil fuel power plants more efficient.
2. Use low-emitting natural gas combined cycle plants more where excess capacity is available.
3. Use more zero- and low-emitting power sources such as renewables and nuclear.
4. Reduce electricity demand by using electricity more efficiently.
Each state could then meet its established target however it sees fit. States could join multi-state programs to reduce emissions collectively, for example through a cap-and-trade program.
How much flexibility will states have to minimize costs?
States would have considerable flexibility to adopt a variety of approaches to reduce carbon dioxide emissions from the power sector, if they can demonstrate that they will achieve the emissions target.
Among the possibilities:
- States could allow emissions credit trading among power plants owned by the same operator. This means that if one power plant reduced its emission rate below the state target, it could trade credits to a power plant that could not meet the target so that the company overall would be in compliance.
- States could allow emissions trading between power companies and even across state lines (such a program would be similar to the Regional Greenhouse Gas Initiative). Averaging or trading across power plants, companies, and states cut overall compliance costs by taking advantage of the lowest-cost opportunity for emissions reductions.
- States could use energy efficiency or renewable energy for compliance, provided that the total emissions met an EPA-approved target.
- States could also set a standard that is more stringent than what would be required by EPA's guidelines.
How much will this rule cost?
EPA projects that the compliance costs for this rule would be between $7.3 billion and $8.8 billion annually by 2030. EPA projects that this would lead to about a 3 percent increase in electricity rates by 2030. The rule would deliver considerable benefits as well, including a total of $55 billion to $93 billion in public health benefits by 2030, as projected by EPA. The rule could also reduce electricity consumption, meaning a homeowner’s electricity bill could stay the same or even decrease. It is important to weigh any costs of the Clean Power Plan against the costs of allowing carbon dioxide emissions to continue to rise unabated, contributing to climate change. The costs of climate impacts such as more frequent and intense heat waves, higher sea levels, and more severe droughts, wildfires and downpours, are projected to be much higher.
What can power plants do to reduce emissions?
An individual power plant could reduce its greenhouse gas emission rate by using fuel more efficiently or by switching to a lower carbon fuel, such as natural gas or biomass instead of coal. However, states would be complying with this rule on a statewide basis using any number of emission reduction options. As long as states met carbon dioxide targets broadly, action would not necessarily be required at particular power plants. States could meet their emissions targets by increasing their consumption of renewable electricity relative to fossil-generated electricity or improving energy efficiency. Options to reduce carbon dioxide emissions in the power sector are illustrated in Figure 4.
Figure 4: Opportunities to reduce carbon dioxide emissions in the power sector
How will existing state policies, such as the Regional Greenhouse Gas Initiative, be affected?
States would have significant flexibility in setting regulations for existing power plants within their borders, but are required to follow the broad limits in EPA’s proposed rule. Since states have been given the authority to use market-based mechanisms, the nine Northeast states participating in the Regional Greenhouse Gas Initiative (RGGI)would be able to demonstrate that their cap-and-trade program for power plants satisfies the required emission reductions, and that further regulation is therefore unnecessary. Policy measures that states might employ to achieve their carbon targets are listed in Table 1.
Table 1: Policy options to reduce power sector carbon dioxide emissions
|Power plant performance standard||Each power plant must achieve a set emissions intensity||California, New York, Washington|
|Renewable Portfolio Standard||Utilities must deliver a set percentage of renewable electricity||Colorado, Hawaii, Kansas, Missouri, Nevada, Rhode Island, and others|
|Energy Efficiency Resource Standard||Utilities must cut demand by a set amount by target years||Arizona, Connecticut, Maryland, Minnesota, Texas, and others|
|Decoupling||Reduce utility incentive to deliver more electricity by decoupling revenue and profit||California, Idaho, Massachusetts, Michigan, Oregon, and others|
|Net Metering||Encourage residential solar by paying homeowners to put excess electricity back on grid||Arkansas, Colorado, Georgia, Louisiana, and others|
|Cap & Trade||Issue a declining number of carbon allowances, which must be surrendered in proportion to each plant’s emissions||California, Regional Greenhouse Gas Initiative|
|Carbon Tax||Charge a tax for emitting carbon||British Columbia|
|Grid Operator Carbon Fee||Add a carbon price to grid operator decision over which power plants to run||None currently|
|Appliance Efficiency Standards||Require new appliances sold to meet set electricity consumption standards||California, Florida, New Jersey, and others|
|Commercial & Residential Building Codes||Require new buildings to include electricity saving measures||California, Illinois, Maryland, Mississippi, and others|
What happens now?
EPA has been directed by President Obama to work closely with states, power plant operators, and other stakeholders as it finalizes its guidelines due to their novelty and far-reaching implications. Administration officials have said they aim to issue a final rule in the summer of 2015. The target date for states to submit their proposed plans to EPA is June 30, 2016, but states can apply for a one-year extension. After a plan is submitted, EPA will have a year to either approve plans or send them back to states for revision. If a state does not submit an adequate plan, EPA is authorized to impose a federal plan to drive the necessary reductions.
It is important to note that this action is not voluntary on the part of EPA. According to the Supreme Court in Massachusetts v. EPA (a decision that was recently reaffirmed), EPA is legally required to regulate greenhouse gases under the Clean Air Act if it finds them to endanger public health and welfare, just as EPA has addressed more traditional pollutants for the past 43 years. In 2010, EPA settled a suit with several states and environmental groups by agreeing to finalize greenhouse gas standards for existing power plants by May 26, 2012.
Additional resources can be found on the C2ES Carbon Pollution Standards Resource Page.
With all the fuss around the EPA’s proposed carbon dioxide standard for new power plants, you would be forgiven for missing the following line: “EPA projects that this proposed rule will result in negligible CO2 emission changes, quantified benefits, and costs by 2022.” That’s right, the standard will likely have little to no effect before the date by which EPA will be required by law to revise it.
Why? As I recently told the National Journal, because the most credible projections have natural gas so inexpensive for the next several years that very few power companies are planning to build new coal plants – compared with the 150 natural gas power plants in the works. Pulling the proposed standard wouldn’t change that reality. In fact, the one coal plant being built today includes carbon capture and storage (CCS), and is expected to meet the tough carbon standard EPA has proposed. A handful of additional coal plants with CCS may move forward in the next several years, as well.
So what’s all the fuss about?
I recently replied to a question on the National Journal blog, "Do the results of the 2012 election pave the way for Washington to achieve bipartisan energy and environment policies?"
You can read other responses at the National Journal.
Here is my response: In his victory speech, President Barack Obama called for an America “that isn’t threatened by the destructive power of a warming planet.” With mostly the same players who failed to pass any significant climate legislation returning to Washington, can we expect a different result?
Possibly -- and for two reasons.
It’s too early to know whether Hurricane Sandy will be the “Love Canal” of climate change, catalyzing a strong national response. But with Sandy’s costs still mounting, President Obama has an opportunity and an obligation to press the case for stronger climate action.
In his victory speech, the president called for an America “that isn’t threatened by the destructive power of a warming planet.” We hope he keeps driving that message home -- to be clear with the American people about the urgency of cutting carbon emissions and strengthening our critical infrastructure against the rising risks of climate change.
In a resounding victory for sound science and policy, the US Court of Appeals decided unanimously this week to uphold both EPA’s finding that greenhouse gases endanger public health and welfare and the agency’s initial set of regulations limiting emissions from vehicles and major new and modified industrial sources.
Given the choice, we’d much prefer to see a new law establishing a comprehensive market-based program to reduce greenhouse gas emissions. But until Congress gets its act together, regulating emissions under the Clean Air Act is really the only option.
Statement of Eileen Claussen
President, Center for Climate and Energy Solutions
June 26, 2012
Today’s decision reaffirms sensible science-based regulation and takes an important step to protect the American people from dangerous climate change.
We’ve always maintained that the best way to reduce U.S. greenhouse gas emissions is through new legislation establishing a comprehensive market-based approach. But in the face of Congressional inaction, EPA has no choice but to move forward under the existing Clean Air Act—not the best tool, but for now the only one available.
As expected, the Court affirmed EPA’s interpretation of the overwhelming scientific evidence that climate change endangers America’s environment and economy. It also affirmed common-sense steps by EPA to tailor the somewhat cumbersome provisions of the Clean Air Act to the particular challenges of regulating greenhouse gases.
The ruling significantly reduces the regulatory uncertainty facing major emitters so they can begin factoring carbon reductions into their investment decisions. Far from the draconian scenarios painted by opponents, the greenhouse gas standards for vehicles will deliver huge fuel savings for consumers,
Hopefully we can now move past the false debate over whether or not climate change is real, and continue the hard work of building common ground for common-sense solutions.
Contact: Rebecca Matulka, 703-516-4146, email@example.com
This week, C2ES filed comments on EPA’s proposed greenhouse gas (GHG) emissions standard for new power plants.
Let me start by saying I would prefer to be working on the implementation of a market-based program to reduce GHG emissions. For years, C2ES has believed that a market-based policy—whether a cap-and-trade program, an emissions tax, emissions averaging among companies, or a clean energy standard with tradable credits—would be the best way of reducing GHG emissions and spurring clean energy technology. Market-based policies create a good division of labor, with the law setting the goal, and private industry deciding how best to achieve it.
Below are the comments C2ES submitted on June 25, 2012, on EPA's proposed greenhouse gas emissions standard for new power plants.
Comments of the Center for Climate and Energy Solutions on
Standards of Performance for Greenhouse Gas Emissions for
New Stationary Sources: Electric Utility Generating Units;
United States Environmental Protection Agency
(77 Fed. Reg. 22392 (April 13, 2012))
Docket ID No. EPA-HQ-OAR-2011-0660; FRL-9654-7
This document constitutes the comments of the Center for Climate and Energy Solutions (C2ES) on the proposed standards of performance for greenhouse gas (GHG) emissions for new electric utility generating units (Proposal), proposed by the U.S. Environmental Protection Agency (EPA) and published in the Federal Register on April 13, 2012. C2ES is an independent nonprofit, nonpartisan organization dedicated to advancing practical and effective policies and actions to address our global climate change and energy challenges. As such, the views expressed here are those of C2ES alone and do not necessarily reflect the views of members of the C2ES Business Environmental Leadership Council (BELC). In addition, the comments made in this document pertain to new sources in the specific industrial sector addressed by the Proposal and may not be appropriate for other industrial sectors or for existing electric utility generating units.
Preference for Market-based Policy
C2ES believes market-based policies—such as emissions averaging among companies, a cap-and-trade system, an emissions tax, or a clean energy standard with tradable credits – would be the most efficient and effective way of reducing GHG emissions and spurring clean energy development and deployment. Properly-designed market-based policies create an appropriate division of labor in addressing climate change, with the law establishing the overarching goal of reducing GHG emissions, and private industry determining how best to achieve that goal. Under market-based policies, the government neither specifies a given company’s emission level nor requires the use of any given technology—both of these questions are determined by the company itself.
Beyond providing an incentive for the use of best available technologies, market-based policies provide a direct financial incentive for inventors and investors to develop and deploy lower-cost, clean energy technologies, and leave the private market to determine technology winners and losers. Market-based policies can be designed to minimize transition costs for companies and their customers in moving from high-emitting technologies to low-emitting technologies; to prevent manufacturers in countries without GHG limits from using this as a competitive advantage over U.S. manufacturers; and to reverse any regressive impacts of increased energy prices. At the federal level, market-based policies have been used to reduce sulfur dioxide emissions at a fraction of the originally estimated cost, while at the state level they have been used successfully in renewable energy programs and cap-and-trade programs.
However, enactment of federal legislation that would establish a comprehensive market-based policy to reduce GHG emissions does not appear imminent. Given the urgency of addressing the rising risks that climate change poses to U.S. economic, environmental and security interests, C2ES believes that in the absence of Congressional action to reduce greenhouse gas emissions, EPA must proceed using its existing authorities under the Clean Air Act.
The Context of the Proposal
The Proposal is consistent with the EPA’s authority to implement the Clean Air Act, as interpreted by the U.S. Supreme Court. On April 2, 2007, in the case of Massachusetts v. EPA, the court found that the harms associated with climate change are serious and well recognized, the EPA has the authority to regulate CO2 and other GHGs under the existing Clean Air Act, and, although enacting regulations may not by itself reverse global warming, that is not a reason for EPA not to act in order to “slow or reduce” global warming.
The Court required that the EPA determine whether GHG emissions from new motor vehicles cause or contribute to air pollution which may reasonably be anticipated to endanger public health or welfare. The EPA released a draft Technical Support Document (TSD) in 2008 that provided technical analysis of the potential risks of GHGs for human health and welfare and contribution of human activities to rising GHG concentrations, and adopted a final endangerment finding in December 2009. The finding explained and documented the determination that (1) the ambient concentration of six key GHGs—CO2, methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—contribute to climate change, which results in a threat to the public health and welfare of current and future generations, and (2) emissions from motor vehicles contribute to the ambient concentration of the GHGs.
The EPA’s endangerment finding did not, by itself, impose any restrictions on any entities. It was, however, a required step in the EPA’s process of regulating GHG emissions. The EPA has already issued several requirements pertaining to GHG emissions—two as a consequence of the endangerment finding, and two in response to specific Congressional mandates regarding the reporting of GHG emissions.
Reporting CO2 emissions from power plants. Under section 821 of the Clean Air Act Amendments of 1990, the EPA requires power plants to monitor their CO2 emissions and report the data to the EPA, which makes the data available to the public. Under this provision, power plants have been reporting their CO2 emissions since the early 1990s, and the data have been made publicly available through the EPA’s website.
GHG Reporting Rule. As part of the Fiscal Year 2008 Consolidated Appropriations Act, signed into law in December 2007, the EPA was ordered to publish a rule requiring public reporting of GHG emissions from large sources. The GHG Reporting Program database was published for the first time in January 2012, and consisted of data reported under the rule.
Vehicle tailpipe standards. The first and most direct result of the Supreme Court’s ruling in Massachusetts V. EPA and the EPA’s subsequent endangerment finding was the EPA’s promulgation of GHG emissions standards for vehicles. In April 2010, the EPA and the U.S. Department of Transportation issued a joint regulation to establish new light-duty vehicle standards for Model Year (MY) 2012 to MY 2016; in August 2011, they issued the final rulemaking for heavy-duty vehicles for MY 2014-2018; and in November 2011, they issued a joint proposal for light-duty vehicle standards for MY 2017 to MY 2025.
New Source Review/Best Available Control Technology. Under the Clean Air Act, major new sources or major modifications to existing sources must employ technologies aimed at limiting air pollutants. Once GHGs were regulated as air pollutants through the vehicle tailpipe standard, the requirement that new or modified sources must use “best available control technology” (BACT) for GHGs also took effect. In November 2010, the EPA released guidance to be used by states in implementing BACT requirements for GHG emissions from major new or modified stationary sources of air pollution. Under the BACT guidance, covered facilities are generally required to use the most energy-efficient technologies available, rather than install particular pollution control technologies. More than a dozen facilities have received permits under the program.
The Proposal is the first GHG standard proposed by the EPA under the New Source Performance Standard provision of the Clean Air Act. Electric power plants account for about one-third of U.S. GHG emissions—nearly twice the contribution of light-duty vehicles.
Comments on the Proposal
C2ES has some concerns with the Proposal, as discussed below. If the concerns are adequately addressed, C2ES supports moving the rule forward.
The EPA should set the emissions standard at a level that can be reliably achieved by currently available technology under reasonably expected operating conditions.
The technology on which the standard in the Proposal is based is natural gas combined cycle (NGCC). It is imperative that the EPA set the GHG emissions standard at a level and in a form that can be reliably achieved by currently available NGCC technology under the full range of reasonably expected operating conditions. A recent study raises questions about the extent to which currently available NGCC units can reliably achieve the standard in the Proposal. In order to maximize the efficiency of the overall interconnected electric system – and often to minimize the overall GHG emissions – it is sometimes necessary to run a particular plant at less than peak efficiency. The standard should reflect this reality.
C2ES agrees that, as proposed, the standard should not cover simple cycle combustion turbines and biomass-fueled boilers.
The standard must be consistent with the advancement of carbon capture and storage technology.
Carbon capture and storage (CCS) is not one of the technologies on which the Proposal’s standard is based. Rather, CCS is a method by which a facility could potentially comply with the NGCC-based standard.
CCS operations have been built at scale in other industrial sectors, but not yet in the electricity sector. The first commercial-scale U.S. power plant with CCS is currently under construction. Power companies are planning several additional CCS projects, some of which will be in conjunction with enhanced oil recovery (EOR). CCS power projects that would supply captured CO2 to EOR are in the planning stages in Texas, Mississippi, California, North Dakota, and Kentucky for the 2014—2020 timeframe. Several more power companies have had plans to build CCS operations that did not go forward primarily because of the cost of CCS and the uncertainty with respect to CO2 emission regulation and legislation.
The Proposal offers an alternative compliance mechanism in which a coal power plant could be operated for 10 years without CCS, followed by 20 years with CCS. While the standard and the alternative compliance mechanism could make it easier for public utility commissions to approve proposals to build coal power plants with CCS, given the current cost and limited demonstration and deployment of CCS technologies, these alone may not be enough to surmount the challenge of financing a plant with CCS. (Please see the discussion of CCS under “Related Matters” below.)
More concerning is the possibility that the standard could inadvertently inhibit the advancement of CCS. For example, one intermediate step in demonstrating the compatibility of CCS with large-scale electricity generation might be to capture and sequester only a fraction of the CO2 from a large coal plant – which might not be allowed under the Proposal. C2ES suggests that the EPA consider mechanisms by which CCS demonstration projects and other operations important to the advancement of CCS could go forward.
Given the unique circumstances of electricity generation today, it is on balance appropriate to set a standard that does not differentiate between fuel types for new power plants. A non-differentiated standard may not, however, be appropriate for other industry sectors or existing sources in this sector.
Perhaps the most novel aspect of the Proposal is that it does not issue separate NSPS for coal and natural gas. Under the Clean Air Act, section 111(b)(2), the EPA “may distinguish among classes, types and sizes within categories of new sources for the purpose of establishing [NSPS] standards.” (Emphasis added.) It has in fact typically been the case that Clean Air Act regulations have established separate air pollution standards for coal- and natural gas-fired power plants. While this differentiation is authorized, however, it is not required by the Clean Air Act. Because the proposed rule would apply to new units only, and because prospective owners have options in selecting the designs of their units, fuel switching (i.e., replacing coal use at existing plants with natural gas) would not be required by the rule.
Moreover, recent developments having nothing to do with GHG regulation, such as the availability of inexpensive natural gas and the regulation of other pollutants, have created conditions under which the GHG emissions intensity of electricity generation is declining. Aside from a small number of facilities far along in the planning process and specifically exempt from the Proposal, no new construction of conventional coal plants is currently foreseen at recent forward market natural gas prices through 2020 (when the Clean Air Act requires that the rule be reevaluated). The Proposal reflects the projections of independent analysts with regard to the future of new coal and natural gas electricity generation. For this reason, the Office of Management and Budget estimates that there will be no cost for industry compliance with the Proposal as compared with the status quo.
That said, it is important to recognize that widely fluctuating natural gas prices are a recent memory, and that, while the majority of independent analysts currently project an abundant and inexpensive supply of natural gas for decades to come, this forecast may prove wrong. Issuing a standard that in effect prohibits the construction of new high-emitting coal plants (i.e., those not using CCS) therefore poses risks – as would issuing a standard that allows the construction of such plants. If the construction of new high-emitting coal plants is effectively prohibited and natural gas prices rise higher than currently foreseen, electricity rates could face an upward pressure. On the other hand, allowing the construction of new high-emitting coal plants could lock in the emissions of those plants for decades to come, exacerbating the challenges the United States faces in reducing its GHG emissions and increasing the risks and costs of dangerous anthropogenic climate change.
On balance, C2ES believes the best choice in implementing the NSPS requirement for new power plants is to issue one standard, regardless of fuel type, but with a mechanism that allows for technological innovation (as discussed above). This should be accompanied by heavy federal investment in low-emitting technologies, including CCS, with the goal of maintaining a diverse set of energy sources in generating the nation’s electricity.
Finally, while the establishment of one emission standard regardless of fuel type may be appropriate with respect to new facilities in the power sector, it may not be appropriate for existing facilities in the power sector or for other sectors for which the EPA may issue regulations.
The United States needs a comprehensive energy strategy that delivers a diverse set of affordable low-emitting sources of electricity.
C2ES believes that as a matter of national policy and economic common sense, it is imperative to enhance energy diversity through programs that advance low-emitting uses of coal and natural gas; nuclear power; renewable energy; and efficiency in generation, transmission and end-use.
In particular, the United States needs an effective strategy for demonstrating CCS and making it inexpensive enough to use on future coal and natural gas power plants. Coal- and natural gas-fired generation will likely be predominant sources of electricity in the United States and most of world’s other major economies for decades to come. It will therefore be essential to advance CCS to the point that its use is economical in the context of electricity generation.
A CCS strategy should include a major research, development and demonstration effort, and subsidies to actively encourage the use of CCS with new and existing natural gas and coal power plants so that the technology can travel down the learning curve. C2ES strongly supports, among other measures, the federal grant programs that have allowed the construction of the previously-mentioned CCS projects. Another option is to establish a trust fund to support demonstration projects at commercial scale for a full range of systems applicable to U.S. power plants. CO2-enhanced oil recovery (CO2-EOR), a practice in which oil producers inject CO2 into wells to draw more oil to the surface, presents an important opportunity to advance CCS while boosting domestic oil production and reducing CO2 emissions. A coalition, co-convened by C2ES, has called for a federal tax credit for capture and pipeline projects to deliver CO2 from industrial and power plants to operating wells. (Note that the recommended tax credit is focused on plant and pipeline operators, rather than EOR operators.)
In addition to investing in CCS, it should be a national priority to invest in and otherwise advance a range of low-emitting energy technologies—for economic, as well as environmental, reasons. The diversity of energy sources used in electricity generation has been a valuable hedge against the unpredictable volatility of the various fuel sources, including natural gas. An electricity sector that increasingly relies on any single fuel would create unintended risks for our economy.
C2ES urges the EPA to move forward with the GHG NSPS for existing power plants, and to do so in a way that builds on existing state programs and allows states to use flexible market-based measures to implement the standards.
As mentioned, C2ES believes market-based policies would be the best way of reducing GHG emissions and spurring clean energy development and deployment. In the absence of a legislated solution, there appears to be an opportunity to utilize market-based policies in the regulation of GHG emissions from existing power plants.
Under section 111(d) of the Clean Air Act, the EPA, in concert with the states, is required to establish GHG emission standards for existing stationary sources—including existing power plants, which account for about one-third of U.S. GHG emissions today. The EPA has, in fact, entered into a settlement agreement under which it will implement section 111(d) for existing power plants. C2ES urges the EPA to move forward in implementing section 111(d) in a manner that can utilize market-based policies as soon as practicable.
Over the next few years, power plant owners will have to make billions of dollars’ worth of decisions about retrofitting, retiring, and replacing a large number of older, carbon-intensive coal plants in light of pending non-climate air, water, and waste regulations. Not knowing what GHG standards these existing facilities will have to meet presents facility owners with enormous uncertainty, greatly complicating and even delaying their decisions, ultimately at the expense of electricity rate payers. Because the Proposal addresses only new sources, this uncertainty pertains even to reconstruction or modification of existing sources. The Proposal mitigates some of the regulatory uncertainty faced by the power sector, but not all.
At the same time, several northeastern states already have an operational regional cap-and-trade program for CO2 from power plants (the Regional Greenhouse Gas Initiative), California is implementing an economy-wide GHG cap-and-trade program, and several states have renewable energy standards, alternative energy standards, or other programs that are effective in reducing the average GHG emission rate across all sources, as well as the overall level of GHG emissions.
C2ES strongly prefers that Congress establish a comprehensive, national market-based GHG reduction policy that would cover both new and existing sources and help to reduce this patchwork quilt of state and regional regulation. In the absence of such legislation, however, C2ES recommends that, in implementing section 111(d) for existing power plants, the EPA issue GHG emission rate-based performance standards in a manner that allows for averaging, banking and trading among sources, giving states the flexibility to adopt various market-based policies that will meet or outperform the standard.
3. Matthew J. Kotchen and Erin T. Mansur, “How Stringent is the EPA’s Proposed Carbon Pollution Standard for New Power Plants?” University of California Center for Energy and Environmental Economics, April 2012.
Statement of Eileen Claussen
President, Center for Climate and Energy Solutions
March 27, 2012
We welcome EPA's proposal today to limit greenhouse gas emissions from new power plants and urge the Administration to quickly move forward with rules for existing plants, which account for 40 percent of U.S. carbon dioxide emissions. Power companies face huge investment decisions as they meet new pollution standards and retire or upgrade outdated plants. They need to know the full picture - including future greenhouse gas requirements - in order to keep our electricity supply as reliable and affordable as possible.
While highly efficient natural gas-fired power plants would meet the standard proposed today, new coal-fired power plants not already in the pipeline could likely meet the standard only by capturing and permanently sequestering their greenhouse gas emissions. This underscores the urgency of stronger public and private investment in carbon capture and storage technologies. The United States, China and India - the world's three largest greenhouse gas emitters - all have substantial coal reserves. If we can't figure out how to get the energy value out of coal with a minimal carbon footprint, we will not solve the climate problem.
With prospects for substantial public investment in CCS unclear, C2ES is now working with policymakers and stakeholders on ways to expand enhanced oil recovery using captured carbon dioxide - an approach that can boost domestic oil production, reduce greenhouse gas emissions, and help lay the groundwork for full-scale carbon capture and storage.
Contact: Rebecca Matulka, 703-516-4146
Learn more about EPA's greenhouse gas standard for new power plants.