Nov. 7 — Proposed carbon dioxide standards for existing power plants could achieve even greater emissions reductions than proposed by the Environmental Protection Agency, states in the Regional Greenhouse Gas Initiative said.
The nine Regional Greenhouse Gas Initiative states also said the EPA's proposed carbon dioxide standards for existing power plants, known as the Clean Power Plan, may not give states sufficient credit for steps they already have taken to reduce greenhouse gas emissions, according to comments submitted Nov. 5.
The EPA in June proposed carbon dioxide emissions guidelines for existing power plants (RIN 2060-AR33). The proposed state-specific emissions rates would be administered by state and local air pollution officials (79 Fed. Reg. 34,830).
The EPA anticipates its proposal would reduce greenhouse gas emissions from existing power plants by 30 percent from 2005 levels when it is fully implemented in 2030. However, the Regional Greenhouse Gas Initiative states said even greater reductions could be achieved at minimal cost.
“Our experience in the RGGI region demonstrates that more substantial emission reductions are readily available from other states nationwide—particularly those that have not yet developed and implemented aggressive energy efficiency and renewable energy programs,” the states said.
RGGI is a collection of nine Northeastern states that participate in a greenhouse gas emissions trading program for power plants.
The RGGI states already have reduced carbon dioxide emissions from the power sector by 40 percent from 2005 levels, while the EPA's proposal would only require those nine states to reduce their emissions by a combined 38 percent. That demonstrates that more significant reductions could be sought, particularly in states that have yet to take action, the states said.
Greater use of new or repowered natural gas-fired power plants can achieve more emissions reductions than the EPA has projected, according to the states—Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island and Vermont.
“Failure to account for this potential allows states with no existing natural gas capacity to skirt consideration of this building block altogether in the computation of their rate-based goals, leaving significant additional cost-effective reductions on the table,” the states said.
The EPA's proposal also could do more to foster investment in renewable energy, the states said.
The RGGI states also had concerns that not all of their early action to reduce greenhouse gas emissions from the power sector would be credited under the EPA's proposal.
For example, the EPA included Northeastern states' hydroelectric generating capacity when determining their baseline emissions rates, but the states won't be able to take credit for that generation when determining compliance, David Littell, commissioner of the Maine Department of Environmental Protection and a member of RGGI's executive committee, told Bloomberg BNA Nov. 7.
“If they follow that methodology, they have to be consistent,” he said.
The states also supported the option for converting the EPA's proposed rate-based emissions standards into mass-based standards to accommodate emissions trading programs. The EPA offered states guidance Nov. 6 on how to convert the standards.
The RGGI states said they still are analyzing the EPA's options to see how they comport with their trading program, Littell said.
“EPA was careful when they issued it to say this was illustrative, and it's guidance. We're taking that seriously,” he said.
The EPA will accept public comments on the proposed rule through Dec. 1.
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The Regional Greenhouse Gas Initiative's comments are available at http://tinyurl.com/ovyfmo5.
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