By Andrew Childers
Any carbon dioxide emissions standards for existing power plants in the
future should credit states and utilities for the emissions reductions they have
already achieved, panelists said during a July 9 forum.
EPA has proposed a new source performance standard for carbon dioxide emitted
from all new fossil fuel-fired power plants, but that proposal does not address
existing or modified sources. EPA could achieve significant greenhouse gas
emissions reductions from existing sources by focusing on the power system as a
whole rather than regulating individual power plants, environmental advocates
and utility executives said during the forum sponsored by the National
Association of Clean Air Agencies, National Association of State Energy
Officials, and National Association of Regulatory Utility Commissioners.
Frank Prager, vice president for environmental policy and services at Xcel
Energy Inc., said his company reduced its carbon dioxide emissions 12 percent in
Colorado even after building a new coal unit as a result of state emissions
programs. Those reductions should be credited under any future EPA rule that
addresses emissions from existing units, he said.
“Those reductions really should be credited in the carbon program going
forward or EPA will be punishing people who got out in front,” Prager said.
EPA said it has no plans to regulate existing power plants. However, Section
111(d) of the Clean Air Act requires EPA to set standards for existing units as
Megan Ceronsky, an attorney in the Environmental Defense Fund's air and
climate program, also recommended EPA “ look at the electricity system as a
whole” and credit power companies for investing in demand reduction programs and
cleaner generation when crafting any standards for existing sources.
“We want to support those actions and encourage other states and utilities to
catch up,” Ceronsky said.
The proposed carbon dioxide emissions limit for new fossil fuel-fired power
plants effectively bans new coal units, utilities said. The carbon capture and
storage technology that the plants would need to comply is not commercially
available, the utilities said.
“The reality is no utility is going to invest now in a billion-dollar coal
plant” until carbon capture has been adequately demonstrated at commercial
scale, Prager said.
EPA's proposed performance standard would limit carbon dioxide emissions to
1,000 pounds per kilowatt-hour for all new fossil fuel-fired power plants. New
natural gas combined-cycle plants would be able to meet the proposed performance
standard with no additional controls. New coal plants would be required to
install carbon capture systems (77 Fed. Reg. 22,392).
The comment period on the proposed rule closed June 25.
John Voyles, vice president for transmission and generation services for
LG&E & KU Energy LLC, said his company plans to retire 800 megawatts of
coal-fired capacity in Kentucky, 10 percent of its total capacity. It will
replace much of that capacity with a new 600-megawatt natural gas combined-cycle
“The proposed rule as written effectively eliminates coal from the national
portfolio,” Voyles said.
Although EPA has not yet regulated carbon dioxide emissions from existing
plants, utilities said they were concerned about the interaction between EPA's
proposed performance standard and its new source review program. The performance
standard sets the baseline of required emissions controls for new source review,
known as best available control technology. Utilities said they worried that
EPA's proposed performance standard would effectively make carbon capture and
storage the best available control technology when power plants make
modifications that require additional pollution controls.
If so, that would be “ catastrophic for existing units,” Voyles said.
Utilities have criticized EPA's decision to propose a single carbon dioxide
performance standard for all new power plants rather than setting individual
emissions limits by fuel type.
However, Joseph Goffman, EPA senior counsel, said proposing the single
emissions standard would “ meet a basic level of carbon performance.”
“We thought it was logical to define the category in terms of the function of
these sources, which is to generate electricity at intermediate load or base
load levels,” he said.
EPA has issued performance standards for 74 source categories under Section
111 of the Clean Air Act, Goffman said. The agency has taken several approaches
to issuing emissions limits based on the individual characteristics of the
industry and the nature of the pollutant being regulated.
“Each category we've done has a highly specific to the sector and pollutant
rationale and that's the only kind of precedent we can follow,” Goffman