CLEAN POWER PLAN

Proposal to Reduce 

Carbon Pollution From 

Existing Power Plants

Symposium on the EPA’s Proposed Rules

on Carbon Reduction

Jacksonville, FL

September 25, 2014

Kenneth L. Mitchell, Ph.D.

U.S. Environmental Protection Agency

Atlanta, GA
Climate Change and the SE

• Coastal communities in the Southeast will likely 

face sea level rise, increased hurricane intensity, 

and storm surge, among other climate change 

impacts

• Higher temperatures, longer periods between 

rainfall events, and greater demand for water will 

likely strain water resources in the Southeast

• Incidences of extreme weather, increased 

temperatures, and flooding will likely impact 

human health

• Higher temperatures will likely affect the growth 

and productivity of crops and forests in the 

region

• Increasing the range of insects that spread 

diseases such as Lyme disease and West Nile 

virus

2

Projected average number of days per year 

with maximum temperatures above 95°F for 

2041-2070 compared to 1971-2000, 

assuming emissions continue to grow (A2 

scenario). Patterns are similar, but less 

pronounced, assuming a reduced emissions 

scenario (B1). (Figure source: NOAA NCDC 

/ CICS-NC).
U.S. GHG Pollution

3
EPA Actions to Reduce Carbon Pollution

•Building a 21st century 

transportation sector

• Cutting energy waste in homes, 

businesses, and factories

•Reducing methane and HFCs

• Preparing the U.S. for the impacts 

of climate change

•Helping lead international efforts 

to address global climate change

•Reducing carbon pollution from 

power plants

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President’s June 2013 Directive to EPA:

Develop carbon pollution standards, regulations or guidelines, as appropriate, for:

1. New power plants - Proposed January 8, 2014

2. Modified and reconstructed power plants

• Proposed June 2014

• Final June 2015

3. Existing power plants

• Proposed Guidelines June 2014

• Final Guidelines June 2015

• State Plans due June 2016

GHG NSPS Requirements for Fossil Fuel-Fired Power Plants

http://www.epa.gov/cleanpowerplan

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This proposal will: 

• Reduce carbon pollution from existing power plants, for which there are currently no national 

limits

• Maintain an affordable, reliable energy system and will help move us toward a cleaner, more 

stable environment for future generations

• By 2030, reduce nationwide carbon dioxide emissions, from the power sector by approximately 

30% from 2005 levels, with significant reductions to begin by 2020

• Cut hundreds of thousands of tons of harmful particle pollution, sulfur dioxide and nitrogen 

oxides as a co-benefit

• Proposal will avoid an estimated 2,700 to 6,600 premature deaths and 140,000 to 150,000 asthma attacks in 

2030

• Provide important health protections to the most vulnerable, such as children and older 

Americans

• Lead to health and climate benefits worth an estimated $55 billion to $93 billion in 2030

• From soot and smog reductions alone, for every dollar invested through the Clean Power Plan -

- American families will see up to $7 in health benefits 

• Electricity bills down 8% in 2030

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Summary - 111(d) Existing Power Plant Proposal
• Build on actions states, cities and businesses across the country are already 

taking to address the risks of climate change

• Spur investment in cleaner and more efficient technologies, creating jobs and 

driving innovation

• Require a reasonable emission reduction glidepath starting in 2020

• Provide a flexible timeline—up to 15 years from guideline issuance—for all 

emission reduction measures to be fully implemented in 2030

o Recognizing that investments in infrastructure can take time to put in place and 

o Avoiding stranded assets

• Provide an array of tools states can use to formulate approvable plans.

Summary - 111(d) Existing Power Plant Proposal

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http://www.epa.gov/cleanpowerplan
Other Benefits

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Electricity bills down 

8% in 2030

$0

$20

$40

$60

$80

$100

$120

1990 1995 2000 2005 2010 2015 2020 2025 2030

Monthly Residential Electricity Bills (2011$)

Historical - Converted to 2011$ Base Case Clean Power Plan
After Proposal, Coal & Natural Gas Remain 

Leading Sources of Electricity Generation

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Each more than 30% of projected generation in 2030

Coal

31%

Natural Gas

32%

Other Fuel

37%
Background: Clean Air Act Section 111(d)

Best System of Emission Reduction

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• Previous EPA rules under this section of the 

Clean Air Act have considered “add-on” control 

technologies – like scrubbers -- that are technically 

feasible to deploy at virtually any facility

• In contrast, there are a wide variety of ways to 

reduce carbon pollution that are commercially 

available, technically feasible, and cost effective

• The opportunities vary from state to state, depending on how electricity is 

generated, energy infrastructure, and other factors

• In this proposal, EPA took an approach that viewed the Clean Air Act factors in 

determining Best System of Emission Reduction (BSER) in light of the 

interconnected nature of power generation

BSER factors

• Costs

• Size of reductions 

• Technology

• Feasibility

http://www.epa.gov/cleanpowerplan
• EPA conducted a robust pre-proposal stakeholder engagement process

oParticipated in meetings with over 300 utility, consumer, labor and 

environmental groups since June 2013

oHeld 11 public listening sessions around the country.

3,300 people attended

More than 1,600 people offered oral statements

• Reached out to all 50 states

oSome states noted their programs to address carbon evolved because of:

The need to address carbon pollution

Electric system that is dynamic, and in 

the midst of market changes

Modernizing the power sector is good 

for the economy

• Common themes included reliability, flexibility, 

affordability, time for plans and implementation 11

Early Outreach Informed This Proposal
EPA Establishes a Goal for Every State

• EPA analyzed the practical and affordable strategies that states and utilities are 

already using to lower carbon pollution from the power sector 

• Proposed goals are based on a consistent national formula, calculated with 

state and regional specific information 

• The result of the equation is the state goal 

• Each state goal is a rate (pounds of CO2 per MWh) – a statewide number for 

the future carbon intensity of covered existing fossil-fuel-fired power plants in 

a state

o Encompasses the dynamic variables that ultimately determine how much carbon pollution is 

emitted by fossil fuel power plants

o Accommodates the fact that CO2 emissions from fossil fuel-fired power plants are influenced 

by how efficiently they operate and by how much they operate

http://www.epa.gov/cleanpowerplan 12
EPA Establishes a Goal for Every State

State Emission Rate Goal = 

(coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions 

Coal gen. + OG gen. + NGCC gen. + “Other” gen. + Nuclear gen. uc + ar + RE gen. + EE gen. 

• The state rate goal is calculated to account for the mix of power sources in each state 

and the application of the “building blocks” that make up the best system of emission 

reduction

• States will need to meet an interim goal and a final goal

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Florida’s Proposed Final Goal is 740 lbs of CO2 per MWh
Building Block Strategy EPA Used to 

Calculate the State Goal

Maximum Flexibility:

Examples of State 

Compliance Measures

1. Make fossil fuel-fired

power plants more 

efficient

Efficiency Improvements • Efficiency improvements

• Co-firing or switching to 

natural gas

• Coal retirements

• Retrofit carbon capture and 

sequestration (CCS)

2. Use lower-emitting power 

sources more

Dispatch changes to 

existing natural gas 

combined cycle (CC)

• Dispatch changes to existing 

natural gas CC

3. Build more zero/lowemitting energy sourcesRenewable Energy

Certain Nuclear

• New NGCC

• Renewables

• Nuclear (new and up rate)

• New coal with CCS

4. Use electricity more 

efficiently

Demand-side energy 

efficiency programs

• Demand-side energy 

efficiency programs

• Transmission efficiency 

improvements

• Energy storage

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States Have Flexibility

Basis for state goal –

Potential emissions 

pathway reflecting 

EPA’s analysis

 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029

 

A state can choose any trajectory 

of emission improvement as long 

as the interim performance goal is 

met on average over 10 years, and 

the final goal is met by 2030

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Carbon emissions from affected power 

plants in an example state

As an example, states could do less in the early years, and more in the later 

years, as long as on average it meets the goal

Timing of Power Plant Emission Reductions
When States Plan, They Can...

• Look broadly across the power sector for strategies that get reductions

• Choose to rely to varying degrees on measures that EPA used to calculate the goal, 

or on other measures that were not part of the state goal-setting analysis

• Invest in existing energy efficiency programs or create new ones

• Consider market trends toward improved energy efficiency and a greater reliance on 

lower carbon energy

• Tap into investments already being made to upgrade aging infrastructure

• Expand renewable energy capacity

• Integrate their plans into existing power sector planning processes

• Design plans that use innovative, cost-effective regulatory strategies

• Develop a state-only plan or collaborate with each other to develop plans on a multistate basis

• Decide how to treat plants nearing the end of their useful life and how to help plants 

avoid “stranded investments”

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Flexibilities Available To States

• Timing 

o Up to 15-year window in which to plan for and achieve 

reductions in carbon pollution 

o Up to two or three years to submit final plans 

• Form of goal

o States can use either a rate-based or mass-based goal

• Single or multi-state plans

o States can collaborate and develop plans on a multi-state 

basis

• Selection of measures 

o States will choose how to meet the goal through whatever 

collection of measures reflects its particular circumstances 

and policy objectives

o State measures may impact and, in fact may be explicitly 

designed to reduce, CO2 emissions from utilities on a 

regional basis

o EPA would support building off existing reduction programs 

http://www.epa.gov/cleanpowerplan 17
States Choose How to Meet the Goals

• Demand-side energy efficiency 

programs*

• Generating electricity from 

low/zero-emitting facilities* 

• Expanding use of existing NGCC 

units*

• Transmission efficiency 

improvements

• Energy storage technology

• Working with utilities to consider 

retiring units that are high emitting 

• Energy conservation programs

• Retrofitting units with partial CCS

Use of certain biomass.

• Efficiency improvements at higheremitting plants*

• Market-based trading programs

• Building new renewables

• Dispatch changes

• Co-firing or switching to natural gas

• Building new natural gas combined 

cycle units

* Measures EPA used in calculating the state goals

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http://www.epa.gov/cleanpowerplan
Details About State Plans

• EPA will provide a list of about a dozen components that will need to be 

included in the plan

• Measures to meet the state’s interim goal and final goal

oInterim goal -- meet on average over a 10-year period from 2020-2029 

oFinal goal -- meet in 2030 and thereafter

• Individual and multi-state plans due June 30, 2016 

• Proposed timing of extensions to submit a complete plan, if justified and 

supported:

oSubmit initial plan by June 30, 2016

oIndividual state plans: a one-year extension (June 30, 2017)

oMulti-state plans: a two-year extension (June 30, 2018)

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By June 30, 2016

State submits initial multistate plan and request for 2-

year extension

EPA reviews initial plan 

and determines if 

extension is warranted

by June 30, 2017

State submits progress 

report of plan

by June 30, 2018

States submits multistate plan

State submits Negative Declaration

State submits complete implementation Plan by June 30, 2016

State submits initial Plan by June 30, 2016 and request 1-year extension

State submits initial multi-state Plan by June 30, 2016 and request 2-year extension

Emission 

Guideline 

Promulgation

June 1, 2015

by June 30, 2016

State submits negative 

declaration

EPA publishes FR notice

by June 30, 2016

State submits plan

by June 30, 2016

State submits initial plan 

and request for 1-year 

extension

EPA reviews initial plan and 

determines if extension is 

warranted

by June 30, 2017

State submits complete plan

2015 2019

Proposed Implementation Timeline

Compliance 

period begins

2020

2020

EPA reviews plan and 

publishes final decision 

within 12 months on 

approval/disapproval

EPA reviews plan and 

publishes final decision 

within 12 months on 

approval/disapproval

EPA reviews plan and 

publishes final decision 

within 12 months on 

approval/disapproval

2016 2017 2018
Next Steps

• The proposed rule, as well as information about how to comment and 

supporting technical information, are available online at: 

http://www.epa.gov/cleanpowerplan

• EPA held 4 public hearings the week of July 28th in Denver, Atlanta, 

Pittsburgh and Washington, D.C. – over 2,700 people attended

• Comments are due December 1, 2014

• Comments on the proposal should be identified by Docket ID No. 

EPA-HQ-OAR-2013-0602

Questions? 

Ken Mitchell; mitchell.ken@epa.gov; 404-562-9065

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