CLEAN POWER PLAN 

Proposed Carbon Pollution 

Standards For Existing 

Power Plants

Shutsu Wong

EPA Region 1

A&WMA-NES Fall 2014 Conference

October 10, 2014
Outline

• President’s Climate Action Plan

•Background on Clean Air Act Section 111(d)

• Setting State Goals

• Flexibilities Available to States

• Costs and Benefits

•How to comment

2
President’s Climate Action Plan

•Reduce carbon pollution from 

power plants

• Prepare the U.S. for the impacts 

of climate change

• Lead international efforts to 

address global climate change

3
This Proposal Deals With the Largest Source 

of GHG Emissions in the U.S.

4
Reducing Carbon Pollution From Power Plants

President’s 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

• Proposal: June 2014

• Final: June 2015

3. Existing power plants

• Proposed Guidelines: June 2014

• Final Guidelines: June 2015

• State Plans due: June 2016

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• Establishes a mechanism for controlling air pollution from 

stationary sources

• Applies to sources for which the Administrator, in her judgment, 

finds “causes, or contributes significantly to, air pollution which 

may reasonably be anticipated to endanger public health or 

welfare”

• Can apply to new, existing, modified and reconstructed sources. 

• More than 70 stationary source categories and 

subcategories are currently regulated under section 111

• A full list of sources regulated under section 111 can be found in 40 

CFR Part 60

6

EPA’s Regulatory Approach

Clean Air Act Section 111
• Lays out different approaches for new and existing 

sources

• New sources under section 111(b)

• Federal standards for new, modified and reconstructed 

sources

• Existing sources under section 111(d) 

• State programs for existing sources that are equivalent to 

federal guidelines

•Applies the “Best System of Emissions Reduction” 

(BSER)

• Feasibility

• Costs

• Technology

• Size of Reductions

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EPA’s Regulatory Approach

Clean Air Act Section 111
States and Communities with 

Programs That Reduce Carbon Pollution

State programs that reduce carbon 

include carbon cap and trade programs 

and energy efficiency and renewable 

energy standards or goals. 8
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 CCS (e.g.,WA Parish in 

Texas)

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-rates)

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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State Performance Goals (lbs/MWh)

State 2012 Fossil 

Emission Rate1

Interim Goal (2020 -

2029 average)2

Final Goal (2030 

and thereafter)2

Connecticut 844 597 540

Maine 873 393 378

Massachusetts 1,001 655 576

New Hampshire 1,119 546 486

Rhode Island 918 822 782

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1 From Goal Computation Technical Support Document, Appendix 5 – 2012 Emissions Rate and Building Block Application

2 From Table 1 to Subpart UUUU of Part 60 – State Rate-Based CO2 Emission Performance Goals, Proposed
Flexibilities Available To States

• Timing: 

• Up to 15-year window in which 

to plan for and achieve 

reductions in carbon pollution. 

• Up to two or three years to 

submit final plans. 

• Form of goal: States can use either 

a rate-based or mass-based goal.

• Single or multi-state plans: States 

can collaborate and develop plans 

on a multi-state basis.

• Selection of measures: 

• States will choose how to meet 

the goal through whatever 

collection of measures reflects 

its particular circumstances and 

policy objectives. 

• State measures may impact and, 

in fact may be explicitly 

designed to reduce, CO2

emissions from utilities on a 

regional basis.

• EPA would support building off 

existing reduction programs. 

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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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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
22%

12%

-20%

-71%

-93%

-100%

-80%

-60%

-40%

-20%

0%

20%

40%

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

New England Economic Growth and ISO New England 

System Emissions, 1999-2012

New England GDP Total Generation CO2 Emissions NOx Emissions SO2 Emissions

Data Sources: 2012 ISO New England Electric Generator Air Emissions 

Report, US Department of Commerce, Bureau of Economic Analysis
Benefits and Costs

• Estimated costs of the plan are $7.3 billion to $8.8 billion in 2030.

• Estimated benefits by 2030

• CO2 emissions from the power sector reduced by approximately 30% from 

2005 levels.

• Pollutants that contribute to the soot and smog reduced by over 25%

• Avoid an estimated 2,700 to 6,600 premature deaths 

• Avoid 140,000 to 150,000 asthma attacks

• These reductions will lead to public health and climate benefits worth an 

estimated $55 billion to $93 billion in 2030. 

• Health and climate benefits far outweigh the estimated annual costs of 

meeting the standards.

• Proposal protects children and other vulnerable Americans from the 

health threats posed by a range of pollutants.

• Move us toward a cleaner, more stable environment for future 

generations. 

• Ensures an ongoing supply of the reliable, affordable power needed for 

economic growth.

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Commenting on the Proposal

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

and supporting technical information, are available online at: 

http://www.epa.gov/cleanpowerplan

• The comment period has been extended to December 1, 2014.

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

EPA-HQ-OAR-2013-0602. 

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For more information

http://www.epa.gov/cleanpowerplan