Summary of Listening Session 1: Electric Power Industry Representatives

February 4, 2011

How to set the standard

• General Advice

o Think of the industry as an interconnected grid and not plant by plant.

o Rate-based approach is preferred (i.e. lbs CO2 / MWh)

 A potential danger to be avoided is wealth transfer among regions

o Allow for technological and fuel flexibility

o Allow for flexibility for states when demonstrating equivalency

• New sources: 

o Set a rate-based standard by fuel types based on the best performing existing and 

commercially available technologies

o Standards must differentiate between fuel and technology to avoid wholesale fuel 

switching

 Differentiate between peaking, baseload, combined cycle, and capacity factor

• Existing sources:

o Sector-wide performance standard (includes all generating units)

 prefer lbs of CO2 / MWh

 determine best practices nationwide using existing technologies and set the 

standard based on those technologies

 Give states flexibility in regards to meeting those standards (e.g. allow for the 

use of existing programs and varying technologies)

 Allow for a fleet-wide approach to meet performance standards

• Allow for emissions averaging and the use of offsets across companies

o Efficiency

 Take into account limitations for existing units

• Some existing fleets may be as efficient as they can be

 Legal and regulatory pathways must be clear

• Some efficiency opportunities on existing units have had issues with the 

EPA enforcement initiative over the last ten years

 Standards must differentiate between fuel types and technologies

• Differentiate between peaking, baseload, combined cycle, and capacity 

factor

o Give credit for retiring old dirtier sources and replacing with cleaner or renewable 

sources

• Approaches to Avoid

o Limitations on the technologies that can be used to comply with the standard

o Plant by plant approach to existing units

How to implement the standard 

• Keep in mind GHGs are part of a suite of regulations applied to power plants

Chris Frantz

3/11/2011
o Utilities need to see the full timeline of implementation of all the regulations for 

investment planning

o Many regulations decrease plant efficiency (parasitic load), which increases GHG 

emissions

o Creating reliability issues for utilities

o Modification required under a different rule may move a plant from “existing” to 

“modified” under the GHG rule

• Implementing on a state by state basis creates limitations because the grid and utilities span 

many states

• Mimic the light duty vehicle rule: began with reasonably achievable standards that become 

progressively more stringent as new technologies come on line

o Provide incentives for the different fuel sources and technologies to adjust over time

• Timeline 

o Must allow for utilities to maintain reliability (slower timeline)

o Must move quickly to address global warming effects

How to provide states flexibility to use mechanisms they are already pursuing (e.g., cap and trade, 

clean coal/clean energy standards) 

• Sector-wide performance standards that include all generating units for existing sources and 

allow for flexibility in demonstrating equivalency

o Allow for fleet-wide approach to demonstrate equivalency with averaging and offsets

• Avoid a plant by plant approach for existing units

Technologies

• Carbon Capture and Storage (CCS)

o Not ready to be deployed on a commercial scale (only in demonstration phase)

o Some geographies have no available storage sites

• Integrated Combined Cycle Plants (IGCC) are being built

• In several cases utilities are butting up against transmission limits, which restricts flexibility in 

meeting standards

Chris Frantz

3/11/2011