Contributions of CAIR/CAMR/CAVR 

Attainment: Focus on Control Technologi

Reductions in the Electric Power 

Office of Air and Radiation

U.S. Environmental Protection Agen

April 18, 2006
Introduction

•

Recent analyses of multipollutant legislative prop

released in October 2005, show that, under the CMercury, and Visibility Rules (CAIR/CAMR/CAVRindustry —especially coal-fired generation—will pcleaner electric power in the future. The installatiopollution controls, use of cleaner coal, and changlead to very substantial reductions in SO

2 and NO

throughout the region. This report focuses in detafindings by addressing the following questions: 

–

What is CAIR designed to do?

–

Why does CAIR offer states an emissions cap 

approach?

–

Will CAIR result in new advanced pollution co

generating sources?

–

How and where will emission reductions occu

CAI

R/CAMR/CAVR in 2010, 2015, and 2020?

–

What happens to coal-fired sources without a

for SO

2 and NO

x in 2010, 2015, and 2020? 
I. What Is CAIR Designed to 
CAIR Is Designed to Reduce Interstate 

Fine Particles and Ozone

Electric power generation is a major source of air em

SO

2 Emissions NOx Emis

10.3 Million Tons

5.1 Million 

Tons

16.4 Million To

Total: 1

5.4 Million Tons Total: 21.1 M

Note: Emissions data is for 2002 and is taken from EPA’s 2003 National E

missions Inventory. “Other” sources of pollutants include transp
CAIR Is Designed to Reduce Interstate 

Fine Particles and Ozone

•

Air pollution can travel 

hundreds of miles and cause multiple health and environmental problems on regional or national scales.

•

Attaining national ambient air 

quality standards will require some combination of emission reductions from:

–

Sources located in or 

near nonattainment areas (such as mobile sources) and

–

Sources, such as power 

plants, located further from the nonattainment area.
CAIR Is Designed to Reduce Interstate 

Fine Particles and Ozone

•

National Ambient Air Quality Standards (NAAQS

pollutants of concern to public health, such as S

particulate m

atter.

•

Over the years, power plants have installed poll

technology for particulates, almost universally.

• In order to address Acid Rain and regional ozon

been designed and implemented, resulting in su

NO

x emission reductions.

•

Because of the interest and need to reduce SO

2 

from power plants, CAI

R/CAMR/CAVR were pro

•

Note that data presented here represent implem

CAI

R, CAMR, and CAVR rules, although the an

on SO

2 and NO

x.
What Is CAIR?

• CAIR: In March 2005, EPA found that 28 states and the 

contribute significantly to nonattainment of the national astandards (NAAQS) for fine particles and/or 8-hour ozon

• EPA is requiring these states to revise their State Implem

to include control measures to reduce emissions of SO2 

• The required emission reductions are based on controls 

highly cost-effective for electric generation units (EGUs)considered in detail what was reasonable to require for pinstallation by 2009 for NOx and 2010 for SO2 in setting t

• EPA provided a model rule for multi-state cap and trade 

SO2 and NOx emissions for PM2.5 and seasonal NOx em

states can choose to adopt to meet the required emissioflexible and cost-effective manner.

• Based on discussions with states to date, EPA expects a

region to participate in the trading programs.

• CAIR will reduce emissions of SO2 and NOx from power 

70% and 60% from 2003 levels, respectively, assisting mcounties in the eastern U.S. to meet EPA’s protective air ozone and fine particles.
CAIR: Affected Region and Emissi

States controlled for fine particles (annual SO2 and NOx)States not covered b

y

C

AIR

States controlled for ozone (

ozone season N

Ox)

States controlled for both fine particles (annu

al SO2 and NOx) and ozone (ozone season NOx)
What Are CAMR and CAVR

•

The Clean Air Mercury Rule, CAMR, establishes p

for Hg for new and existing coal-fired electric genemandatory declining emissions cap of 38 tons starttons in 2018. 

•

The Clean Air Visibility Rule, CAVR, requires emisbest available retrofit technology, or BART, for induair pollutants that cause or contribute to regional ha

that reduce visibility include fine particles (PM2.5) a

contribute to PM2.5 formation, such as NO

x and SO

•

These rules, together with CAIR, provide a nationw

strategy to reduce SO

2and Hg by more than 70% a

60%. 

•

Note that data presented here represent implemen

CAMR, and CAVR rules to capture the interactive eprograms.
Nationwide Emissions from Electric Gen

Historical and Projected under CAIR/C

Note: 

The C

AIR regional S

O2 caps are 3.6

million tons in 2010 and 2.5 million tons in 2015, and the annual regional N

Ox caps are 1.5 

C

A

M

R caps for Hg are 38 tons in 2010 and 15 tons in 2018.

SO

2

NO

x

PCH
II. Why Does CAIR Offer States an E

Cap and Trade Approach?
Previous Effectiveness of Approach S

Rain Program and NOx SIP C

A study* in 2005 shhealth and environmProgram in 2010 ar1 benefit to cost ratannual health bene*

A fresh look at the benefits an

Environmental Management Vo

Wet Sulfate Deposition

Average 1989-1991

Wet Sulfate Deposition

Average 2002-2004

Source: NADP

Source: www.gpv/airtrends

Source: NADP

Regio

nal Red

8-Hour Ozo

ne

Source: www.gpv/airtrends
How Emissions Cap and Trade 

•

An air emissions cap is set

– Level and timing of cap determine cost of program

•

Emissions “allowances”

equal to the cap are dis

–

Each allowance authorizes an amount (e.g, one t

•

Sources choose compliance approach

–

Controls, fuel switching, buying/selling/banking al

•

Sources continuously measure and report emiss

•

Sources must surrender allowances to cover reg

–

Automatic penalties for non-compliance

•

Through their implementation of national health-

States and local governments retain authority to impacts
Why Emissions Cap and Trade W

•

Full sector coverage –

all sources o

f sector includ

–

Minimizes shifting of production (and emission

sources (“leakage”)

–

Assures achievement of emission reduction g

case review

•

The cap – government issues fixed quantity of all

–

Limits emissions to achieve/maintain environm

–

Limits creation of “paper credits” and “anyway 

–

Provides certainty to allowance market

•

Monitoring –

accurate measurement and reportin

–

Assures accountability and results

–

Establishes integrity of allowances and confid

•

Trading – unrestricted trading and banking (emiss

allowed to protect local air quality)

–

Allows facilities to choose/change compliance 

–

Minimizes compliance cost

–

Ensures that trading will not cause “hotspots”
Cap and Trade Provides Flexibility an

•

Cap and trade programs do not specify how a s

with the cap, yet it must comply.

•

This flexibility in how sources comply includes in

control technology or acquiring emission allowaemissions.

•

Market forces and the circumstances specific to determine the appropriate choice of control techpurchase and trade of allowances, or a combinawith the rule.

• In any case, sources must monitor and account 

emissions. Compliance with emission cap and thas been nearly 100% each year.
III. Will CAIR Result in New Advanc

Controls on Power Generating S
Changes to Coal-Fired Generation Are K

Compliance

• Focusing on SO

2 and NOx 

contribution to fine particle and ozone nonattainment, there are several types of power generation that produce these air emissions.

• Because coal-fired generation is 

the dominant source, and analysis shows that these coalfired units also install the majority of pollution controls, EPA primarily looks at these sources and emissions in this report.

SO2 E

mis

201

NOX E

mis

20
Projected Coal Capacity with Advanced P

• There are currently around 305 GW of coal-fired capacity in the 

U.S. That number is projected to incr

e

ase to about 3

21 GW* of 

coal-fired capacity by 2020 with CAIR/CAMR/CAVR.

• By 2020, about 79% of CAIR-affected coal-fired capacity is 

projected to have one or m

ore of the f

ollowing installed: s

elective 

catalytic and non-catalytic reduction (SCR/SNCR) for NOx, flue 

gas desulfurization (scrubbers) for SO2, and/or activated carbon 

injection (ACI)** for mercury. The existing and/or NOx SIP Call 

SCR/SNCR will go from seasonal to year-round operation beginning i

n 2009 (see note).

• The graphics show cumul

ative capacity with existing controls; 

controls projected to be retrofitted under the NOx SIP Call, NSR 

settlements, State-enacted programs, and CAA Title IV; and controls projected to be retrofitted with CAIR/CAMR/CAVR.

Note: In 2004 SCR/SNCR generally operated only in the ozone season (May-September); by 2009, they will operate year-round. 

*This data includes capacity from all coal units nationwide, including units ≤ 25 M

W. These smaller units, which number about 165 units and represent about 2.2 G

W of capacity in 2010 an

2020, are not regulated under CAIR, CAMR, or CAVR. For purposes of this analysis, Delaware and New Jersey were not included as part of the CAIR region because the modeling was doprograms for SO2 and NOx. Adding these two States would not alter the results presented here in any significant way.**There are no constraints on the feasibility of ACI for mercury control in IPM and results need to be reviewed with this in mind.
Percent of Electricity Generated from Foss

(by Fuel Type and Emission Control 

• These charts show pe

generated from coal-fiof pollution controls insU.S. electricity comes scrubbers and SCR/SNgeneration.

• In 2003, coal-fired gen

compared to total genenumber is projected to 2020 under CAIR/CAMgeneration of 4.8 trillio

• Graphics sho

w an incr

generation with advan

*“Other” category includes nuclear, hydroelectric, and 

Note: Numbers may not add up due to rounding. This data includes generation from all EGUs nationwide, including fossil units ≤ 25 M

W. These smaller units are not regulated under CAIR, 

NOx removal (either scrubbers, SCR, or SNCR) will typically have combustion controls for NOx control, burn low-sulfur coal (from 0.45 to 1.2 lbs/mmBtu), and/or be utilized less frequently. 
Percent Coal Generation and Controls in 2010, 

• The graphics show 

generated from co

• Over 99% of coal g

years (2010, 2015with some NO

x or 

place.

• There is a clear sh

SO

2, NO

x, and me

SCR/SNCR for NO

Activated Carb

o

n I

control.

Note: Numbers may not add up due to rounding. This data includes generation from all coal EGUs nationwide, including units ≤ 25 M

W. These smaller coal units, which number about 165 u

204 units and represent about 2.4 GW of capacity in 2020, are not regulated under CAIR, CAMR, or CAVR. Units without advanced pollution controls for SO2 and NOx removal (either scrubb

burn low-sulfur coal (from 0.45 to 1.2 lbs/mmBtu), and/or be utilized less frequently.
Average Emission Rates Decr

Significantly in CAIR State

All Fossil Generation P

Historical Average Emission Rates in lbs/MM

SO2 CAI

States NOx CAIR States SO2 CAIR States

0.921.01

1.101.17

2004 0.292000 0.42

Avera

ge Projected Emission Rates in lbs/MMBtu under C

All Fossil Generation P

SO2 CAIR 

States

NOx CAIR 

States

SO2 CAI

States 

2010 0.50 0.14 0.59 2015 0.36

0.28

0.46 0.36 

0.11

2020 0.10

Note: For the emission rates presented here, States categorized here as part of CAI

R are the States covered by the annual C

AI

and Dela

ware, but not ozone-season only States. Historical data is from EP

A’s Acid Rain Progra

m, projected data is from EP

A’s 
Average Emission Rates Decr

Significantly in Non-CAIR St

Note: For the emission rates presented here, States categorized here as part of non-CAI

R are the States not covered by the ann

from EPA’s Acid Rain Progra

m, projected data is from EPA’s Integrated Planning Model.

Avera

ge Projected Emission Rates in lbs/MMBtu under C

All Fossil Generation P

SO2 Non-CAIR NOx Non-CAIR SO2 Non-

2010 0.29 0.24 0.45 

0.22 0.360.19

0.34 

2015 0.182020 0.16

All Fossil Generation P

Historical Average Emission Rates in lbs/M

SO2 Non-CAIR NOx Non-CAIR SO2 Non-

0.340.42

0.450.52

2004 0.282000 0.33
IV. How and Where Will Emission Redu

under CAIR/CAMR/CAVR in 2010, 201
Emission Reductions Occur through Proje

of Advanced Air Pollution Control Techno
Emission Reductions Occur through Proje

of Advanced Air Pollution Control Techno
Emission Reductions Occur through Proje

of Advanced Air Pollution Control Techn
Where: State-by-State SO

2 Emis

• Largest SO

2

emitting states reduce the most.
Where: State-by-State NO

x Emi

• CAIR will build 

on the ozone season emission reductions from the NO

x SIP Call.

• The largest 

NO

x emission reductions will 

continue to occur in the central portion of the eastern United States.
Where: State-by-State Ozone Season N

• Ozone season 

emissions in the NO

x Trading Program region 

decreased nearly 70% from 1990 through 2004.

• Summertime NO

x emissions in the 

SIP Call region with CAIR will continue to significantly decrease due to additional SCR/SNCR/lowNOx burner retrofits by 2020.
Where Plant-Level Emission Reduct

This and the next slide compare plant-level SO

2 emiss

2010 and 2020
Where Plant-Level Emission Reduct

Plant-level SO

2 Emission Reductions in 
Where Plant-Level Emission Reduct

This and the next slide compare plant-level NO

x ann

reductions in 2010 and 2020
Where Plant-Level Emission Reduct

Plant-level NO

x Annual Emission Reduction
Where Plant-Level Emission Reduct

This and the next slide compare plant-level NO

x ozon

reductions in 2010 and 2020
Where Plant-Level Emission Reduct

Plant-level NO

x Ozone Season Emission Redu
CAIR States and Projected Installation of Advan

Control Technology—2010, 2015, an

• In 2010, AL, CT, DE, FL, MA, MD, N

C, NJ, OH, PA, and WV will have m

fired capacity retrofitted with advanced air pollution controls for SO2 and 

– In 2010, CT, MA, MD, NC, and NJ will have more than 95% of the

retrofitted with advanced air pollution controls for SO2 and NO

X

• In 2015, AL, AR, CT, D

E, FL, IN, MA, MD, MS, N

C, N

J, NY, OH, PA,

TN

more than 75% of their coal-fired capacity retrofitted with advanced air p

and NO

X

– In 2015, AL, AR, CT, MA, MD, MS, N

C, NJ, and WV will have mor

fired capacity retrofitted with advanced air pollution controls for SO

• In 2020, AL, AR, CT, DE, FL, IN, KY, MA, MD, MS, NC, NJ, NY, OH,

PA

have more than 75% of their coal-fired capacity retrofitted with advanceSO2 and NO

X

– In 2020, AL, AR, CT, MA, MD, MS, NC, NJ, PA, and W

V will have 

c

oal-fired capacity retrofitted with advanced air pollution controls fo

• Advanced air pollution controls include SCR, SNCR, Scrubbers, IGC

C, 

• C

AIR’s S

O2 and NOx emission caps are based on EPA’s initial asse

s

sm

control the power sector could reasonably install without creating a boile

could pot

enti

ally drive costs up.
V. What Happens to Coal-Fired Sour

Advanced Controls for SO

2 and NO

x in 2

2020? 
A Primer on Units vs. Generation an

•

A unit is an electrical energy generator. There ma

units comprising a power plant. (For instance, a pof 1,000 MW may have two 500 MW units, or a 5250 MW units, etc.)

•

Capacity (MW) is the maximum electric power ou

produced by a unit or combination of units (e.g., iexample, 1,000 MW).

•

Power output (MW) is the rate (how fast) at which 

electrical energy. (A 500 MW unit can operate—genergy—at any power output between zero and 5

•

Generation is the total amount of electrical energy 

(generated) over a period of time (MWh). Generacumulative product of power output and time (MW MW unit operated at an average power output of 500 MWh in 10 hours.)
A Primer on Units vs. Generation an

• In discussing emission controls under CAIR, we sh

fired capacity that will install controls, as well as thassociated with the generation from that capacity. describe units that will not have controls, their capaemissions associated with their projected generatio

• It should be understood that the emissions from an 

fired unit that operates at 10% of its capacity for a equivalent to the emissions from a scrubbed coal-fsame size that runs at 100% of its capacity for that 

•

The more an owner operates an unscrubbed unit, t

associated with the unit’s emissions, and the more be to add advanced pollution controls or operate le

•

Notably, units that have advanced controls tend to those that do not, as it is more economical to dispathat have relatively lower costs. Lower costs resulresidual pollution per MWh to offset with emission 
Coal-Fired Units Operating without Adva

2010, 2015, 2020

Most coal-fired units operating without advanced pollution contr

ols 

scrubbers or SCRs) have installed precombustion contr

ols (low-NO

very low NO

x rates, and many may also burn low-sulfur coal and/or 

operation. This slide (2010) and the next 2 slides show the decreas

without advanced controls as CAIR is implemented.
Coal-Fired Units Operating without Advan

2015

This slide shows the decreasing number of units withouCAIR is implemented, as of 2015.
Coal-Fired Units Operating without Adva

2020

This slide shows the decreasing number of units without CAIR is implemented, as of 2020.
Providing Context: Number of Regulated U

• Looking at the number of units without advanced pollution controls provides 

composition of those units (i.e., size). The largest and highest emitting units install controls, as dem

onstrated by the graphics above.

• Units without advanced pollution controls for SO2 and NOx removal (either s

typically have baghouses or electrostatic precipitators for particulate controlNOx control, and burn low-sulfur coal (from 0.45 to 1.2 lbs/mmBtu). In addit

utilized less frequently.

295 

units 

(33%)

* The existing coal fleet has already installed advanced controls for direct particulate control on almost every unit. Advanced pollution cont

SNCR technologies for N

Ox control. All new pulverized coal-fired units will have both 

S

C

R and scrubbers. New IG

C

C is included as havin

with S

C

R and scrubbers). Data is for CAIR annual States only and includes affected sources with non-zero generation only (units ≤ 25 M

W 

New Jersey

were not included as part of the CAIR region because the modeling

was done prior to EP

A’s recent final rule to include the

m i

these two States would not alter the results presented here in any significant way. Historical data is from EPA’s National Electric Energy S

Planning Model.

592 

units 

(67%)
Historical and Projected Pollution Controls 

• There are many ways to analyze pollution control data; isolating one 

uncontr

olled units) could provide an incomplete picture.

• Although 295 regulated coal units* (33% of the total number of 

projected to be without any scrubbers, SCR, or SNCR in 2020, tonly 21% of coal capacity and only 20% of CAIR-affected coal-f

Historical and Proje

cte

d P

ollution Controls in the C

AIR R

egion for 

Fired U

nits

Units w/o 

A

d

v

ance

d

P

ollution Controls

Un

Po

# of Unit

s 57

6 

% of T

otal 65% 

Ca

p

acity (G

W) 11

8 

% of T

otal 48% 

# of Unit

s 39

4 

% of T

otal 48% 

Ca

p

acity (G

W) 81 

% of T

otal 34% 

# of Unit

s 31

6 

% of T

otal 39% 

Ca

p

acity (G

W) 61 

% of T

otal 25% 

# of Unit

s 29

5 

% of T

otal 33% 

Ca

p

acity (G

W) 54 

% of T

otal 21% 

2004201020152020

* The existing coal fleet has already installed advanced controls for direct particulate control on almost every unit. Advanced pollution cont

SNCR technologies for N

Ox control. All new pulverized coal-fired units will have both 

S

C

R and scrubbers. New IG

C

C is included as havin

with S

C

R and scrubbers). Data is for CAIR annual States only and includes affected sources with non-zero generation only (units ≤ 25 M

W 

New Jersey

were not included as part of the CAIR region because the modeling

was done prior to EP

A’s recent final rule to include the

m i

these two States would not alter the results presented here in any significant way. Historical data is from EPA’s National Electric Energy S

Planning Model.
VI. Getting Back to the Goal of Protecting 

and the Environment
Ozone and Particle Pollution: CAIR, together with 

Will Bring Cleaner Air to Areas in th

Legend

Both P

M and Ozon

e Nonattainme

nt

PM O

nly Nonattainment

Ozone Only Nonattainme

nt

Are

a Count

36

3

90

Nonattainme

nt

Ozone Only Nonattainme

nt

Are

a Count

36

3

90

Legend

Both P

M and Ozon

e Nonattainme

nt

PM O

nly Nonattainment

Ozone Only Nonattainme

nt

Are

a Count

36

3

90

Legend

Both P

M and Ozon

e Nonattainme

nt

PM O

nly Nonattainment

Ozone Only Nonattainme

nt

Are

a Count

36

3

90

Nonattainme

nt

Ozone Only Nonattainme

nt

Are

a Count

36

3

90

129 Areas CurreNonattainment foOzone (

April, 200
92 Areas Are Projected to Meet the PM2

Ozone Standards in 2010

with CAIR/C

AMR/CAVR and Som

e

C

urrent Rul

e

s* Ab

s

ent Additional Lo

c

al Control

s

**Areas forecast to additional local or dates set pursuant re

gional measures 

overstat

es the exte

*Current rules in

clude Title IV of C

AA, NOx SIP Call, and some e

xisting State rules.

Ar

e

a Count

6

1516

92

Legend

Both PM and O

zone Nonattainm

e

nt

PM Only Nonattainm

e

nt

Ozon

e Only Nonattainm

e

nt

N

o

n

attain

m

e

nt areas projecte

d t

o

attain
104 Areas Projected to Meet the PM2.5 and 

Standards in 2015

with CAIR/C

AMR/CAVR and Som

e

C

urrent Rul

e

s* Ab

s

ent Additional Lo

c

al Control

s

**Areas forecast to additional local or dates set pursuant re

gional measures 

overstat

es the exte

Ar

e

a Count

3

14

8

104

Legend

Both PM and O

zone Nonattainm

e

nt

PM Only Nonattainm

e

nt

Ozon

e Only Nonattainm

e

nt

N

o

n

attain

m

e

nt areas projecte

d t

o

attain

*Current rules in

clude Title IV of C

AA, NOx SIP Call, and some e

xisting State rules.
106 Areas Projected to Meet the PM2.5 and 

Standards in 2020

with CAIR/C

AMR/CAVR and Som

e

C

urrent Rul

e

s* Ab

s

ent Additional Lo

c

al Control

s

**Areas forecast to additional local or dates set pursuant re

gional measures 

overstat

es the exte

Ar

e

a Count

3

13

7

106

Legend

Both PM and O

zone Nonattainm

e

nt

PM Only Nonattainm

e

nt

Ozon

e Only Nonattainm

e

nt

N

o

n

attain

m

e

nt areas projecte

d t

o

attain

*Current rules in

clude Title IV of C

AA, NOx SIP Call, and some e

xisting State rules.
Summary

– What is CAIR designed to do?

• Reduce interstate transport of fine particles and ozone

– Why does CAIR offer states an emissions cap and tra

• Most cost-effective way to reduce regional pollution fro

– Will CAIR/CAMR/CAVR result in new advanced pollu

and NOx on power generating sources?

• Results in advanced SO2 and NOx controls on over 80% 

generation. Already have widespread major controls on 

– How and where will emission reductions occur under 

2010, 2015, and 2020?

• Largest emitting states make the largest reductions

– What happens to coal-fired sources without advance

controls in 2010, 2015, and 2020? 

• Many of these units contribute to reductions through hig

burners, lower sulfur coals, and reduced operation—thesmallest units.

• State and local governments remain empowered to con

where warranted.

• Air quality will still improve due to reductions from other 

area that will run more.
For More Information on Power Sector 

on Power Sector 

Clean Air Interstate Rule: http://www.epa.gov/cClean Air Mercury Rule:

http://www.epa.gov/c

Clean Air Visibility Rule:

http://www.epa.gov/v

Multi-Pollutant Analyses: http://www.epa.gov/aAcid Rain Program:

http://www.epa.gov/a

NO

x SIP Call:

http://www.epa.gov/a