EPA’s Proposed 

Clean Power Plan (CPP)

Presentation for Environmental Justice Groups 

Kevin Culligan, Associate Director, Sector 

Policies and Programs Division, OAQPS, 

Office of Air and Radiation 

October 30, 2014
Overview 

► Background on rulemaking

► Summary of proposal 

► State goals 

► Proposal and implementation timeline

► Input on the proposed plan

► How EJ was addressed in the proposed CPP

► Initial feedback received 

► Appendix

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Clean Power Plan Summary

► EPA’s proposed Clean Power Plan looks across our whole power 

sector to take important steps to boost our economy, 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

► Cutting hundreds of thousands of tons of harmful particle pollution, 

sulfur dioxide and nitrogen oxides as a co-benefit

► 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

► 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

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Clean Power Plan−How it Works

► The agency’s proposal:

► Was shaped by public input, present trends and proven 

technologies

► Follows the law

► Recognizes the progress states, cities and businesses have 

already made

► Builds on ongoing efforts

► The proposal aims to cut energy waste 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 in light of the 

interconnected nature of power generation; the BSER factors are:

► Costs

► Size of reductions

► Technology

► Feasibility

► The Clean Power Plan proposes state-specific goals, which aim 

to reduce a state’s carbon intensity rate, or “pollution-to-power 

ratio” 

► To set the goals, EPA started with emissions data from 2012−the 

most current information available 

► Then EPA looked ahead to see what states could reasonably 

accomplish by 2030, using the four strategies we determined best 

meet the definition of BSER: 

1. Measures to make coal 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 5
Keys to state planning and flexibility

1. State-specific numeric rate

The numeric goal puts states in charge of choosing cost- effective strategies that reflect their particular circumstances and 

policy objectives; states are not limited to measures EPA used to 

set state goals

2. States get to decide which mechanisms to use 

States can consider a broad range of regulatory and design 

options that would lead to emission reductions at power plants; 

states can collaborate and develop plans on a multi-state basis

3. 10- to 15-year time frame gives states flexibility

This much time provides opportunities to integrate state plans 

with existing power sector planning processes, tap into 

investments already under way to upgrade aging infrastructure, 

and explore innovative mechanisms to meet goals

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Examples of Emission Reduction Actions

Options to reduce emissions through changes 

at existing fossil plants

► Efficiency improvements

► Best practices: controls tuning, reduce air heater leakage, minimize parasitic 

loads, focused operator training

► Equipment/systems upgrades: steam turbine upgrade, economizer upgrade 

(lower exit gas temperature)

► Co-firing lower carbon fuels

► Natural gas

► Switching completely to lower carbon fuels

► Firing natural gas in an existing boiler

► Repowering to NGCC

► Integrated concentrating solar and other renewable energy at the fossil 

fuel fired power plant

► Retrofit CCS

► Biomass could play a role

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Example of Reduction Actions (cont.)

Options to reduce emissions through the use of lowor non-emitting generation

► Increase use of existing NGCC

► Build new NGCC

► Use and/or increase use of existing utility scale renewables

► Build new utility scale renewables including:

► Wind

► Solar

► Geothermal

► New Hydro

► Build new distributed renewables

► Incremental hydro at existing facilities (capacity uprates)

► Uprates at existing nuclear power plants

► Use of energy storage to increase utilization of existing or new low- or 

zero-emitting technologies

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Examples of Reduction Actions (cont.)

Options to reduce emissions through demand-side energy 

efficiency measures

► Demand side energy efficiency programs

► Building energy codes

► Smart grid-enabled strategies including: 

► Consumer information and feedback supporting demand-side energy 

efficiency

► Optimization of grid operations including through conservation 

voltage reduction (CVR)

► Integration of low-and non-emitting generation (central station and 

distributed) and demand response

► Transmission improvements to reduce line losses

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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 – just as limits on other air pollutants already are; (for example, 

existing NOX and SO2 emission limits and related trading programs change 

the cost of generation of individual units and thus affect EGU dispatch)

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

► Could be plant-specific, company-wide, state-wide, or region-wide

► Could include emission rate averaging programs that allow crediting of renewables and 

energy efficiency

► Regional emission reduction agreements, such as multi-state emission 

budget trading programs

► For example, RGGI, which includes complementary EE and RE programs to lower costs 

and/or achieve other goals

► 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)

► Approach similar to Colorado Clean Air- Clean Jobs Act that required utility plans to reduce 

SO2 and NOX emissions, including consideration of power plant retirements and 

repowering, and use of EE/RE

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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

• EPA recognizes states’ concerns regarding 

timing for submission of plans

 Opportunity for phased plan submittals:

• Individual state plans: a one-year 

extension (June 30, 2017) 

• Multi-state plans: a two-year 

extension (June 30, 2018); would 

submit a progress report on June 30, 

2017

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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
How EJ was addressed in the proposed CPP

► Strong scientific evidence shows that EJ communities are 

especially vulnerable to the impacts of climate change

► For example, lower income communities can be especially vulnerable to 

climate change impacts because they tend to have more limited 

adaptive capacities and are more dependent on climate-sensitive 

resources such as local water and food supplies

► EPA’s qualitative EJ analysis for the proposed rule looks at the 

illustrative state compliance scenarios that are modeled in the 

RIA; this power sector modeling (using IPM) shows significant 

overall state and national reductions in CO2, SO2, PM, NOx and 

mercury from power plants as a result of this rule 

► While there will be many locations with improved air quality for fine 

particles, ozone, and toxics, there may also be a few power plants 

whose emissions may increase as a result of state choices to implement 

the proposed rule

• In cases where these increases may occur, EPA’s analysis discusses how 

local, state or federal permitting programs already in place provide 

opportunities to help make sure emissions increases from these types of 

changes – and effects on nearby communities − are minimized 

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Initial Feedback Received

► Below is a summary of the issues that we have heard thus far from a 

variety of stakeholders:

► EJ specific issues:

► Preference for more quantitative analysis

► More opportunities to engage, share ideas

► Concerns over cap and trade programs (and potential localized 

emission increases)

► Other common issues:

► State goals

► 2012 as a “baseline”

► Credit for early action

► Rate-based vs. mass-based goals

► Stringency of the building blocks

► Renewable energy

► Enforceability 

► Regional plans 

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Appendix

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Maps of Power Plant Sector

► Interactive maps illustrate:

► Locations of fossil fuel fired power plants covered by the proposed 

Clean Power Plan

► State summaries describing each state’s power sector CO2 emission 

rates (using 2012 data) and each state’s proposed emission rate 

goal

► For more information, please visit:

► http://cleanpowerplanmaps.epa.gov/CleanPowerPlan/

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