# 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

2

## 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 (CO 2 

### ) 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; s tates 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 low

or 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 NO X and SO 2 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 CO 2 emissions that use multiple measures (e.g., “portfolio” approach)

► Approach similar to Colorado Clean Air

- Clean Jobs Act that required utility plans to reduce SO 2 and NO X 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 e missions 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

1113 By June 30, 2016

State submits initial multi

state 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 multi

state 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 m ulti

- state P lan by June 30, 2016 and request 2

- year extension Emission Guideline Promulgation

June 1, 2015 by June 30, 2016

State submits n egative 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

## H ow 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 CO

2 

### , SO 2 

### , 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

15

## 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 CO 2 

### 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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