EPA’s Proposed 

Clean Power Plan

DOE WINDExchange Summit

Cocoa, FL

May 18, 2015

Ken Mitchell, Ph.D.

U.S. Environmental Protection Agency

Atlanta, GA
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Some Key Efforts Under the CAA

• Cleaning Up Outdoor Air

• NAAQS pollutants (e.g., Ozone, PM), 

Regional Haze, air toxics, acid rain

• Cleaner vehicles, engines, and the fuels 

that power them

• Addressing Climate change

• Protecting the stratospheric ozone layer 

• Indoor air is also a focus of OAR efforts, 

but not explicitly addressed in the CAA

http://www.epa.gov/air/caa/
U.S. GHG Pollution

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• Although there are limits at power plants for other pollutants like arsenic and 

mercury, there are currently no national limits on carbon 

GHG NSPS Requirements for Fossil Fuel-Fired Power Plants

http://www.epa.gov/cleanpowerplan

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Using the Section 111 of the Clean Air Act, EPA is working to develop carbon 

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

1. New power plants

• Proposed January 8, 2014

• Final Summer 2015

2. Modified and reconstructed

power plants

• Proposed June 2014

• Final Summer 2015

3. Existing power plants

• Proposed Guidelines June 2014

• Final Guidelines Summer 2015

• State Plans due Summer 2016

• Proposed Federal Plan summer 

2015 (final ready summer 2016)

Carbon Pollution Standards for the Power Sector

http://www.epa.gov/cleanpowerplan

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This Clean Power Plan (CPP) 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

• Electricity bills down 8% by 2030

• 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

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Summary - 111(d) Existing Power Plant Proposal
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 “addon” 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

http://www.epa.gov/cleanpowerplan

BSER factors

Costs 

Size of reductions 

Technology

Feasibility
EPA Establishes a Goal for Every State

• EPA is proposing state-specific emissions goals for reducing CO2 emissions from the power sector

• State goals are not requirements on individual electric generating units

• States have broad flexibility to meet the rate by 2030 by lowering the overall carbon intensity of the power 

sector in the state

• Basic formula for the state goal is a rate: 

___________________CO2 emissions from fossil fuel-fired power plants in pounds (lbs)___________________

electricity generation from fossil-fuel fired power plants and certain low- or zero-emitting power sources (MWh)

o Factors in MWh from fossil fuel power plants plus other types of power generation like renewables and nuclear, as 

well as MWh savings from energy efficiency

o State- and regional-specific information is plugged into the formula, and the result of the equation is the statespecific goal

o Each state’s goal is different, because each state has a unique mix 

of emissions and power sources to plug in to each part of the formula

o EPA has proposed an interim (met over 2020-2029) and final goal 

(2030 and thereafter) for each state

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Building Block Value Allocated in Goal-Setting Formula

(1) Make fossil fuel power plants more efficient

• Improve equipment and processes to get as much 

electricity as possible from each unit of fuel

• Using less fossil fuel to create the same amount of 

electricity means less carbon pollution.

Average heat rate improvement of 6% for coal steam 

electric generating units (EGUs)

(2) Use low-emitting power sources more

Using lower-emitting power plants more frequently to 

meet demand means less carbon pollution.

Dispatch to existing and under-construction natural gas 

combined cycle (NGCC) units to up to 70% capacity factor

(3) Use more zero- and low-emitting power sources

• Expand renewable generating capacity, which is 

consistent with current trends.

• Using more renewable sources, including solar and 

wind, and low-emitting nuclear facilities, means less 

carbon pollution.

Dispatch to new clean generation, including new nuclear 

generation under construction, moderate deployment of 

new renewable generation, and continued use of 

existing nuclear generation

(4) Use electricity more efficiently

Reducing demand on power plants is a proven, low-cost 

way to reduce emissions, which will save consumers and 

businesses money and mean less carbon pollution.

Increase demand-side energy efficiency to 1.5% annually
How we included renewables in the goal setting

• Used a “best practices” scenario for RE generation 

based on RPS requirements already established by a 

majority of states

• Did not assume any specific type of RE technology for 

the best practices scenario

• Not an EPA forecast of renewable capacity development

• Does not establish RPS requirements for any state

• Does not make any determinations regarding allowable 

RE compliance measures

• Represents a level of RE development for individual 

states – with recognition of regional differences –

that EPA views as reasonable and consistent with 

policies that a majority of states have already 

adopted

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How we included renewables in the goal setting

• The “best practices” scenario 

consists of increasing annual levels 

of RE generation estimated based 

on application of an annual RE 

growth factor to the state’s 

historical RE generation, subject to 

a max RE generation target

• Annual RE growth factors and max 

RE generation targets were 

developed separately for each of 

six regions

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See Chapter 4 at: 

http://www2.epa.gov/carbon-pollution-standards/clean-power-plan-proposed-rule-ghg-abatement-measures

(Note: EPA also sought comment on an alternative approach that relies on a 

state-by-state assessment of RE technical and market potential)
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 

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http://www.epa.gov/cleanpowerplan
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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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

*See Update: http://www2.epa.gov/carbon-pollution-standards/fact-sheet-clean-power-plan-carbon-pollution-standards-key-dates
Questions?

mitchell.ken@epa.gov

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