EPA’s Proposed Clean 

Power Plan 

Lisa Conner

U.S. EPA, Office of Air and Radiation 

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

October 16, 2014
Clean Power Plan Summary

►EPA’s proposed Clean Power Plan looks across 

our whole power sector to take important steps to 

protect our health and environment, and fight 

climate change by:

► Reducing nationwide carbon dioxide (CO2) emissions, 

from the power sector by approximately 30% from 2005 

levels by 2030

► Maintaining an affordable, reliable energy system

► Achieving significant co-benefits by cutting hundreds of 

thousands of tons of harmful particle pollution, sulfur 

dioxide and nitrogen oxides

► Providing important health protections to the most 

vulnerable, such as children and older Americans

► Leading to health and climate benefits worth an 

estimated $55 billion to $93 billion in 2030 2
Clean Power Plan−How it Works

► The agency’s proposal:

► Was shaped by public input, presents trends and proven 

technologies

► Recognizes the progress states, cities and businesses have 

already made

► Builds on ongoing efforts

► The proposal aims to cut carbon pollution and leverage 

cleaner energy sources by: 

► Setting achievable, enforceable state goals to cut carbon 

pollution per megawatt hour of electricity generated

► Laying out a national framework that gives states the flexibility 

to chart their own, customized path to meet the goals in their 

state plans

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Clean Power Plan: State Goals

► 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; the BSER 

factors are:

► Costs

► Size of reductions

► Technology

► Feasibility

► To set the goals, EPA looked to see what states could reasonably 

accomplish by 2030, using the four strategies that we determined 

meet the definition of BSER: 

1. Measures to make fossil fuel-fired plants more efficient

2. Increased use of high efficiency, natural gas combined cycle (NGCC) 

units

3. Generating electricity from low- or zero-emitting facilities

4. Demand-side energy efficiency

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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

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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Clean Power Plan: State Goals (cont.)
Examples of Regulatory Mechanisms

► States can consider a variety of approaches to ensure that 

limits on carbon pollution are addressed in the course of 

normal power sector planning and operation through: 

► Direct emission limits on power plants (rate- or mass-based)

► Regional emission reduction agreements, such as multi-state 

emission budget trading programs

► Legislation or regulations establishing EE resource standards 

(EERS) and/or renewable portfolio standards (RPS)

► Integrated resource plan (IRP)-type approaches for reducing utility 

fleet CO2 emissions that use multiple measures (e.g., “portfolio” 

approach)

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Clean Power Plan: Timing Flexibilities

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

• Responding to input from 

stakeholders, EPA proposed 

a flexible compliance 

timeline

 2030 compliance date—giving 

states 10-15 years to meet 

the goals

 2020-2029 glidepath, giving 

states time to ramp up 

programs and to be sensitive 

to reliability and enforceability 

issues

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Design of State Plans

► Emission guidelines provides a list of required state plan 

components that must be submitted to EPA for review/approval

► Identification of affected entities 

► Description of plan approach and geographic scope

► Identification of state emission performance level 

► Demonstration that plan is projected to achieve emission performance 

level

► Identification of emission standards

► Demonstration that each emission standard is quantifiable, nonduplicative, permanent, verifiable, and enforceable

► Identification of monitoring, reporting and recordkeeping requirements 

► Description of state reporting 

► Identification of milestones

► Identification of backstop measures

► Certification of hearing on state plan 

► Supporting material 

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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 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
Input on the Proposed Plan

► 165-day public comment period open through December 1, 2014

► EPA held four public hearings

► Almost 3,000 attendees, with more than 1,300 speakers

► So far, the agency has received more than 750,000 public comments

► EPA Regional Offices

► Our regional offices are great resources on specific state issues; we 

encourage you to touch base with the 111(d) contact in each of the regions 

► Outreach to States

► EPA continues to meet with states and other stakeholders to answer 

questions and get input

► As States work to develop state plans over the coming months and years, 

ideas about potential opportunities in your state’s plan can be addressed to 

state officials 

• State environmental agencies

• State public utility commissions 

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