EPA’s Clean Power Plan

Region 4 Title V and New Source Review

Air Permitting Workshop

May 7, 2015

Kenneth Mitchell, Ph.D.

U.S. Environmental Protection Agency

Atlanta, GA
• President Obama’s Climate 

Action Plan

• EPA Actions to Support the 

President’s Plan

• EPA’s Clean Power Plan

Outline

www.epa.gov/climatechange and www.epa.gov/cleanpowerplan
U.S. GHG Pollution

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• President Obama’s Climate 

Action Plan takes a series of 

ambitious steps to combat 

climate change

• Cuts carbon pollution in America 

through domestic policies that involve 

both voluntary and regulatory action

• Prepares our country for the impacts of 

climate change

• Leads international efforts to address 

global climate change

• Advances the Science

The President’s Climate Action Plan

https://www.whitehouse.gov/climate-change
Advancing the President’s Plan at EPA

• Collecting Emissions Data

• Advancing the Science

• Partnering With States, Localities, 

and Tribes

• Partnering Internationally

• Helping Communities Adapt

• Getting Reductions

• Building a 21st century transportation sector

• Cutting energy waste in homes, businesses, 

and factories

• Reducing methane and HFCs

• Reducing carbon pollution from power plants 

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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)

GHG NSPS Requirements for Fossil Fuel-Fired Power Plants

http://www.epa.gov/cleanpowerplan

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• EPA conducted a robust pre-proposal stakeholder engagement process

oParticipated in meetings with over 300 utility, consumer, labor 

and environmental groups since June 2013

oHeld 11 public listening sessions around the country

3,300 people attended

More than 1,600 people offered oral statements

• Reached out to all 50 states

o Some states noted their programs to address 

carbon evolved because of:

The need to address carbon pollution

Electric system that is dynamic, and in 

the midst of market changes

Modernizing the power sector is good 

for the economy

• Common themes included reliability, flexibility, affordability, time for 

plans and implementation

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Early Outreach Informed This Proposal
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

• Provide important health protections to the most vulnerable, such as children and older 

Americans

• Lead 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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Summary - 111(d) Existing Power Plant Proposal
• 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

• Require a reasonable emission reduction glidepath starting in 2020

• Provide a flexible timeline—up to 15 years from guideline issuance—for all 

emission reduction measures to be fully implemented in 2030

o Recognizing that investments in infrastructure can take time to put in place and 

o Avoiding stranded assets

• Provide an array of tools states can use to formulate approvable plans.

Summary - 111(d) Existing Power Plant Proposal

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http://www.epa.gov/cleanpowerplan
Other Benefits

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Electricity bills down 

8% in 2030

$0

$20

$40

$60

$80

$100

$120

1990 1995 2000 2005 2010 2015 2020 2025 2030

Monthly Residential Electricity Bills (2011$)

Historical - Converted to 2011$ Base Case Clean Power Plan
After Proposal, Coal & Natural Gas Remain Leading Sources 

of Electricity Generation

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Each more than 30% of projected generation in 2030

Coal

31%

Natural Gas

32%

Other Fuel

37%
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 “add-on” 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

BSER factors

• Costs

• Size of reductions 

• Technology

• Feasibility

http://www.epa.gov/cleanpowerplan
EPA Establishes a Goal for Every State

• EPA analyzed the practical and affordable strategies that states and utilities are already 

using to lower carbon pollution from the power sector 

• Proposed goals are based on a consistent national formula, calculated with state and 

regional specific information 

• Each state goal is expressed as a rate (pounds of CO2 per MWh) – a statewide number 

for the future carbon intensity of covered existing fossil-fuel-fired power plants in a 

state

• The state rate goal is calculated to account for 

the mix of power sources in each state and the 

application of four “building blocks” that make 

up the best system of emission reduction

• States will need to meet an interim goal and 

a final goal

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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 carbon capture and 

sequestration (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 rate)

• 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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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
States Have Flexibility

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

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Carbon emissions from affected power 

plants in an example state

As an example, states could do less in the early years, and more in the later 

years, as long as on average it meets the goal

Timing of Power Plant Emission Reductions
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

Implementation Timeline as Proposed

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
Actions since the proposal

• October 28, 2014 - EPA issued a supplemental proposal to its 

proposed CPP that sets area-specific goals for Indian country and 

territories

• October 28, 2014 - EPA issued a NODA

related to the proposed CPP

• November 6, 2014 – EPA issued a TSD

on converting rate-to-mass

• November 19, 2014 – EPA issued second draft 

of Framework for Assessing Biogenic Carbon Dioxide

for Stationary Sources and associated memo from Janet McCabe

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During the comment period....

• The proposed rule and supporting technical information, are 

available online at: http://www.epa.gov/cleanpowerplan

• EPA held 4 public hearings the week of July 28th in Denver, 

Atlanta, Pittsburgh and Washington, D.C. – over 2,700 people 

attended

• Comments on the CPP proposed rule and NODA closed

December 1, 2014; over 4 million comments received

• Comments on the proposal are identified by Docket ID Number: 

EPA-HQ-OAR-2013-0602

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Questions?

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