CLEAN POWER PLAN

Reducing Carbon Pollution From 

Existing Power Plants

Suzanne Murray – Regional Counse

EPA Region 6

November 5, 2014
Disclaimer

• This presentation is a discussion of the proposed Clean Pow

Any error in this presentation does not trump the language proposal.

• This presentation is not a forum to take comment on the Cle

Plan; to comment, you must follow the comment procedurethe proposal.

• Clean Power Plan proposal citation: 79 FR 34830 (June 18, 2

http://www.epa.gov/cleanpowerplan. Note: the deadline to comments has been extended to December 1, 2014.

• Notice of Data Availability (NODA) and Supplemental Propos

separate documents announced on October 28, 2014, and npublished in the Federal Register. Access them at the link abDeadline to submit comments: December 1, 2014 and Dece2014, respectively.
This Proposal Deals With the 

Source of GHG Emissions in th
This proposal will: 

• Reduce carbon pollution from existing power plants, for which the

currently no national limits.

• Maintain an affordable, reliable energy system.• By 2030, reduce nationwide carbon dioxide (CO2) emissions, from t

sector by approximately 30% from 2005 levels.

• Cut hundreds of thousands of tons of harmful particle pollution, su

and nitrogen oxides as a co-benefit. 

• Build on actions states, cities and businesses across the country are 

taking to address the risks of climate change. 

• Spur investment in cleaner and more efficient technologies, creatin

driving innovation.

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

emission reduction measures to be fully implemented in 2030. 

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

Summary
Background: Clean Air Act Section 111

Best System of Emission Reduction (BS

• Previous EPA rules under this section of the Clean Air Act hav

considered “add-on” control technologies – like scrubbers -- ttechnically feasible to deploy at virtually any facility. 

• In contrast, there are a wide variety of ways to reduce carbon 

that are commercially available, technically feasible, and cost 

• The opportunities vary from state to state, depending on how 

is generated, energy infrastructure, and other factors. 

• In this proposal, EPA took an approach that viewed the Clean 

factors in determining Best System of Emission Reduction in linterconnected nature of power generation.

• BSER factors

• Costs• Size of reductions • Technology• Feasibility
•EPA conducted a robust preproposal stakeholder engagement 

process.

•Participated in meetings with 

over 300 utility, consumer, labor and environmental groups since June 2013.

•Held 11 public listening sessions 

around the country.

•Reached out to all 50 states.

Early Outreach Informed This Pro
EPA Establishes a Goal for Every 

• EPA analyzed the practical and affordable strategies that states and u

already using to lower carbon pollution from the power sector. 

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

and regional specific information. 

• The result of the equation is the state goal. • Each state goal is a rate – a statewide number for the future carbon in

covered existing fossil-fuel-fired power plants in a state.

• Encompasses the dynamic variables that ultimately determine how much carb

emitted by fossil fuel power plants.

• Accommodates the fact that CO2 emissions from fossil fuel-fired power plants 

by how efficiently they operate and by how much they operate. 

• The state goal rate is calculated to account for the mix of power sourc

state and the application of the “building blocks” that make up the beemission reduction.

• States will need to meet an interim goal and a final goal.
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 

Carbon emissions from affected power 

plants in an example state

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

years, as long as on average it meets the goal

Timing of Power Plant Emission Reductions
Building Block Strategy EPA Used to 

Calculate the State Goal

Maximum 

Examples 

Compliance 

1. Make fossil fuel-fired

power plants more efficient

Efficiency Improvements Efficiency improv

Co-firing or switcgasCoal retirementsRetrofit CCS (e.gTexas)

2. Use lower-emitting power 

sources more

Dispatch changes to existing natural gas combined cycle (CC)

Dispatch changenatural gas CC

3. Build more zero/lowemitting energy sources Renewable Energy Certain Nuclear New NGCC Renewables

Nuclear (new anNew coal with C

4. Use electricity more 

efficiently

Demand-side energy efficiency programs

Demand-side enprogramsTransmission effimprovementsEnergy storage
When States Plan, They Can:

• Look broadly across the power sector for strategies that get re

• Choose to rely to varying degrees on measures that EPA used 

calculate the goal, or on other measures that were not part of goal-setting analysis. 

• Invest in existing energy efficiency programs or create new on• Consider market trends toward improved energy efficiency an

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 proce• Design plans that use innovative, cost-effective regulatory stra• Develop a state-only plan or collaborate with each other to de

plans on a multi-state basis.

• Decide how to treat plants nearing the end of their useful life 

to help plants avoid “stranded investments.”
Flexibilities Available To States

• Timing: 

• Up to 15-year window in which 

to plan for and achieve reductions in carbon pollution. 

• Up to two or three years to 

submit final plans. 

• Form of goal: States can use either 

a rate-based or mass-based goal.

• Single or multi-state plans: States 

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

• Selection of measures: 

• States will choose how 

the goal through whacollection of measureits particular circumstpolicy objectives. 

• State measures may i

in fact may be explicitdesigned to reduce, Cemissions from utilitieregional basis.

• EPA would support bu

existing reduction pro
Focus on Renewable Energy: Building Block 

(Build more zero/low-emitting energy sour• Renewable energy is a cost-effective approach for reducing 

emissions from fossil fuel-fired EGUs through the substitutioelectricity generated from renewable resources. 

• Portfolio of available RE sources encompasses a wide variet

technologies from utility-scale RE plants to smaller-scale disgeneration sited at residential, commercial, or industrial fac

• RE technologies are fueled by the sun, wind, water, organic 

and other resources regularly replenished by physical and bcycles. 

• To integrate the rapidly increasing and evolving portfolio of 

the Best System of Emission Reduction (BSER), EPA has deveproposed approach that builds upon current state policy enincreased production of RE taking into account renewable pin particular regions of the country. 
Focus on Renewable Energy: Building Block 

(Build more zero/low-emitting energy sour• A note on timing: RE generation counts towards a state goal 

regardless of when the RE project was constructed or commoperations. 

• The exception is for hydro – the proposal excludes existing h

place before June 2014), and EPA is taking comment on that 

• For additional in-depth information, see the (224 pg.) Techn

Support Document (TSD) “GHG Abatement Measures” at 

http://www2.epa.gov/carbon-pollution-standards/clean-poproposed-rule-ghg-abatement-measures (notably Chapter 4“Chapter 4: Cleaner Generation Sources”)
Focus on Renewable Energy: Building Blo

(Use electricity more efficiently)• There are a variety of state energy efficiency (EE) policies.• In a given year, EE policies lead to new investments.• Impacts of EE policies ramp up over time as impacts of inves

accumulate.

• In setting the state goal, each state ramps up annual increm

energy savings from base levels to that of leading states.
States Choose How to Meet the G

• Demand-side energy efficiency 

programs.

*

• Generating electricity from 

low/zero-emitting facilities.* 

• Expanding use of existing NGCC 

units.

*

• Transmission efficiency 

improvements.

• Energy storage technology.• Working with utilities to consider 

retiring units that are high emitting. 

• Energy conservation programs.• Retrofitting units with partial CCS.• Use of certain biomass.

• Efficiency improvements 

emitting plants.

*

• Market-based trading pro• Building new renewables• Dispatch changes.• Co-firing or switching to n• Building new natural gas 

cycle units.

* Measures EPA used in calculatgoals
0

200400600800

1,0001,2001,4001,6001,8002,000

Baseline (lb/MWh) 2030 Goal (lb/MWh)

lb/MWh

111(d) - Comparison of Region 6 State Baselines and 2030 Targets

Arkansas

New Mexico

Louisiana

Oklahoma

Texas

47%42%43%

42%

44%
After Proposal, Coal & Natural Gas Rem

Leading Sources of Electricity Generatio

Each more than 30% of projected generation in 203

Coal

31%

Natural Gas

32%

Other Fuel

37%
Next Steps

• The proposed rule, as well as information about how to comm

supporting technical information, are available online at: 

http://www.epa.gov/cleanpowerplan

• There will be a 165-day public comment period on the propos

comments by December 1, 2014.

• Comments on the proposal should be identified by Docket ID 

EPA-HQ-OAR-2013-0602. 
Recent Developments, Part 1: Supplemental P

Announced on October 28, 2014• Not yet published in the Federal Register.• The 115 page .pdf version can be accessed here: 

http://www.epa.gov/cleanpowerplan

• Docket number is the same as the other documents: EPA-HQ

2013-0602. 

• Deadline for comments: December 19, 2014.• A public hearing will be held in Phoenix.• Supplemental proposal will deal exclusively with the issue o

EGUs on tribal lands and in U.S. territories. It will propose band targets for these areas.
Recent Developments, Part 2: Notice of Data 

Availability (NODA) Announced on October 28• Not yet published in the Federal Register.• The 60 page .pdf version can be accessed here: 

http://www.epa.gov/cleanpowerplan

• Docket number is the same as the other documents: EPA-HQ-OAR-20

• Deadline for comments: December 1, 2014.• NODA will present information that EPA has received in comments tha

beyond the proposed rule and issues for which comments were requeintention is to make known comments and suggestions received from other stakeholders so that everyone can have a chance to review them submit comments on these ideas. The five main areas addressed in thare:

• 1. Early reduction credits for compliance with the interim targets• 2. How new coal-fired and NGCC turbines are handled in BSER• 3. A regionalized approach for handling RE generation and accounting for RE that 

one state and used in another

• 4. A slight modification to the general BSER equation used to calculate the baseli• 5. CO2 emissions and power generation data for 2010 and 2011 so that stakehold

in a multi-year baseline can evaluate how that might affect the baselines for their stat
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 2

Proposed Implementation Timeli

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 rev

publishe

within 1

approva

2016 2017 2018
Questions? 

Kristen Bremer

111(d) EPA HQ, Office of Air and Radiation Contact for Region 6

Bremer.Kristen@epa.gov

(919) 541-9424

Rob Lawrence

111(d) EPA Region 6 Outreach 

Coordinator

Lawrence.Rob@epa.gov

(214) 665-6580

Terry Johnson

111(d) R6 Liaison for Texas, 

Arkansas & Louisiana

Johnson.Terry@epa.gov

(214) 665-2154

Clovis Steib

111(d) R6 Liaison for Oklahoma & 

New Mexico

Steib.Clovis@epa.gov

(214) 665-7566

Josh Olszewski

111(d) Regional Counsel

Olszewski.Joshua@epa.gov

(214) 665-2178

Carrie Thomas

111(d) Regional Counsel

Thomas.Carrie@epa.gov

(214) 665-7121

Aust

111(d) Office 

Vela.Aus

(214) 

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