EPA’S GHG REGULATIONS 

FOR POWER PLANTS

Shutsu Wong

U.S. EPA, Region 1

July 23, 2015

Northeast Energy and Commerce Association Conference
OVERVIEW

 President’s Climate Action Plan

 Clean Air Act Section 111

 Carbon Pollution Standards (New Sources)

 Clean Power Plan (Existing Sources)

 Benefits

 Other GHG Regulations

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PRESIDENT OBAMA’S CLIMATE ACTION PLAN

 Reinforces the federal commitment to: 

 Cutting harmful pollution, 

 Protecting out country from the impacts of climate change, and

 Leading an international effort to address a changing climate

 EPA’s Role

 Reducing carbon pollution from power plants

 Building a 21st century transportation sector

 Cutting energy waste in homes, businesses, and factories

 Reducing methane and HFCs

 Preparing the U.S. for the impacts of climate change

 Leading international efforts to address global climate change

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CARBON POLLUTION IS THE BIGGEST DRIVER 

OF CLIMATE CHANGE

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CAA SECTION 111: 

NEW SOURCE PERFORMANCE STANDARDS

 EPA develops federal standards for new sources under 111(b). 

 Standards are determined based on the Best System of 

Emission Reduction (BSER).

 Setting New Source Performance Standards (NSPS) for new 

sources under 111(b) leads to regulating existing sources 

under 111(d).

 EPA develops guidelines for states. States use these guidelines 

to develop equivalent state plans tailored to their unique 

circumstances. 

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TIMELINE

SUMMER 2015

 Final New Source Performance Standards – 111(b)

 Final Performance Standards for Modified and Reconstructed Sources – 111(b)

 Final Existing Source Guidelines– 111(d)

 Proposed Federal Plan for Existing Sources – 111(d) 

SUMMER 2016

 Initial State Plans Due – 111(d) 

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BSER: BEST SYSTEM OF EMISSION REDUCTION

Key Factors in BSER Determination

 Feasibility

System of emission reduction must be technically feasible

 Costs

Costs of the system are reasonable

 Size of Reductions

EPA may consider the amount of emission reductions the system would generate

 Technology

Designed to promote the implementation and further development of technology

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CARBON POLLUTION STANDARDS: 

111(b) PROPOSAL FOR NEW SOURCES

 Separate standards for natural gas-fired turbines and coal-fired units. 

Proposed Limits

(lb CO2/MWh-gross)

Natural Gas Combined 

Cycle

Large 

(> 850 mmBtu/hr)

1,000

Small 

(≤ 850 mmBtu/hr)

1,100

Fossil Fuel-fired Boilers 

and Integrated Gasification 

Combined Cycle (coalfired)

12 operating month 

(1 year)

1,100

84 operating month 

(7 years)

1,000 – 1,050 

(in this range)

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States and Communities with Programs that Reduce 

Carbon Pollution

State programs that reduce carbon include 

carbon cap and trade programs and energy 

efficiency and renewable energy standards 

or goals. 
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111(d) PROPOSED CLEAN POWER PLAN:

Best System of Emissions Reduction (BSER)

Proposed Limits

(lb CO2/MWh-gross)

Natural Gas Combined 

Cycle

Large 

(> 850 mmBtu/hr)

1,000

Small 

(≤ 850 mmBtu/hr)

1,100

Fossil Fuel-fired Boilers 

and Integrated Gasification 

Combined Cycle (coalfired)

12 operating month 

(1 year)

1,100

84 operating month 

(7 years)

1,000 – 1,050 

(in this range)

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 CCS (e.g.,WA Parish in 

Texas)

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-rates)

New coal with CCS

4. Use electricity more 

efficiently

Demand-side energy efficiency 

programs

Demand-side energy efficiency 

programs

Transmission efficiency 

improvements

Energy storage
STATE PERFORMANCE GOALS – lbs/MWh

State

2012 Fossil 

Emission Rate

2012 Fossil, RE, 

Nuclear Rate

Interim Goal 

(2020 - 2029 

average)

Final Goal (2030 

and thereafter)

Connecticut 844 765 597 540

Maine 873 437 393 378

Massachusetts 1,001 925 655 576

New Hampshire 1,119 905 546 486

Rhode Island 918 907 822 782

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 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 to 

meet the goal through 

whatever collection of 

measures reflects its particular 

circumstances and policy 

objectives. 

 State measures may impact 

and, in fact may be explicitly 

designed to reduce, CO2

emissions from utilities on a 

regional basis.

 EPA would support building off 

existing reduction programs. 

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FLEXIBILITIES AVAILABLE TO STATES
Source: RGGI, Inc.

70

75

80

85

90

95

2014 2015 2016 2017 2018 2019 2020

CO2 Emissions Budget (million 

short tons)

RGGI Emissions Cap

Data Source: RGGI, Inc.

Regional Nine State CO2 Emissions Budget

REGIONAL GREENHOUSE GAS INITIATIVE (RGGI)
24%

12%

-20%

-71%

-93%

-100%

-80%

-60%

-40%

-20%

0%

20%

40%

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

New England Economic Growth and ISO New England 

System Emissions, 1999-2012

New England GDP Total Generation CO2 Emissions NOx Emissions SO2 Emissions

Data Sources: 2012 ISO New England Electric Generator Air Emissions Report, 

US Department of Commerce, Bureau of Economic Analysis

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When these rules 

are implemented, 

Americans will: 

Source: Whitehouse.gov
ELECTRICITY BILLS DOWN 8% IN 2030

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$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
NEXT STEPS

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Milestones Dates

Final Standards for New Sources Summer 2015

Final Standards for Modified & 

Reconstructed Sources Summer 2015

Final Emissions Guidelines for 

Existing Sources Summer 2015

Proposal for Federal Plan Summer 2015

Initial State Plans due Summer 2016
OTHER GHG REGULATIONS

Greenhouse Gas Reporting Rule, 40 CFR Part 98

 Subpart C – General Stationary Combustion

 Subpart D – Electricity Generation 

 Subpart W – Petroleum & Natural Gas Systems

 Subpart DD – Use of Electric Transmission and Distribution Equipment

 Subpart NN – Suppliers of Natural Gas and Natural Gas Liquids

New Source Review (NSR) – Prevention of Significant Deterioration (PSD) 

Permits

CO2 Best Available Control Technology (BACT) analysis required if: 

 an “anyway” source* emits or has potential to emit 75,000 tons per year of CO2e

* “Anyway” sources are sources required to obtain a PSD permit based on emissions of NSR pollutants 

other than CO2

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THANK YOU

For more information, visit: 

http://www2.epa.gov/carbon-pollution-standards

Shutsu Wong

U.S. EPA, Region 1

wong.shutsu@epa.gov

617-918-1078

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