OPPORTUNITIES TO DEPLOY 

AND REDUCE GHGS THRO

EPA’S CLEAN POWER 

Te

Energy Recove

W

Octobe
Overview

• June 2, 2014 – EPA released the “Clean Power Plan” Proposed 

providing emission guidelines under section 111(d) of the Clea

for carbon dioxide from fossil fuel‐fired electric generating uni

• The emission guidelines are based on a suite of technologies/st

that EPA has designated as Best System of Emission Reduction 

existing fossil fuel‐fired electric generating units.

• Through the application of BSER, EPA has proposed state‐speci

that reflect EPA’s calculation of the emission limitation that eac

achieve, taking into account costs and any non‐air quality healt

environmental impacts.
OVERVIEW OF STATE GOAL COMPUTA

USING BUILDING BLOCKS
Building Blocks Informing State Goals ‐ Overview

EPA created four categories of emission reduction measures (bu

blocks) used to determine state emission rate goals. States will 

flexibility to meet the standards using any combination of buildin

Building Block #1

Heat Rate

Improvement

at Coal Plants

Building Block #2

Redispatch to

Existing Natural

Gas Combined

Cycle (NGCC)

Plants

Building Block #3

Existing and New

Renewables

and

New and At‐Risk

Nuclear

Build

End‐

Effi

Starting Point: Unadjusted 2012 state fossil emission rate for covered 

Finishing Point: Interim and Final State Emission Rate Goal
BSER Building Block #1 – Heat Rate Improveme

EPA assumes that a

6% heat rate

improvement at coal

facilities is achievableand will directly

translate to a 6%reduction of CO2

emissions.Building Block #1 will

have a greater impact

on overall reductionsin states with aheavier reliance on

coal plants.

Data source: EPA Goal Computation Technical Support Document, Appendix 5 table. Levels bareductions from 2012 rates based on fossil, and compliance eligible renewables and nuclear.Note: Vermont is omitted since it does not have any fossil fuel-fired EGUs subject to regulation 
BSER Building Block #2 – Redispatch to NGCC

Building block #2

assumes that each

state’s existing and

under construction

NGCC fleet willoperate at a

minimum 70%capacity.All generation

increased at an

NGCC plant is

associated with anequal reduction inpower generated by

coal/oil/gas, therebyachieving less carbon

intensity.

Data source: EPA Goal Computation Technical Support Document, Appendix 5 table. Levelon reductions from 2012 rates based on fossil, and compliance eligible renewables and nucleaNote: Vermont is omitted since it does not have any fossil fuel-fired EGUs subject to regulat111(d).
BSER Building Block #3 – Renewable Energy (RE

Zero‐emitting RE

generation is

added to the state’s

generationbaseline, reducing

overall carbon

intensity.States are given theflexibility to definewhat is renewable

energy (subject to

EPA approval of

state compliance

plans).

Data source: EPA Goal Computation Technical Support Document, Appendix 5 table. Levelreductions from 2012 rates based on fossil, and compliance eligible renewables and nuclear.Note: Vermont is omitted since it does not have any fossil fuel-fired EGUs subject to regulati
BSER Building Block #3 – Under Construction an

At‐Risk Nuclear

EPA has identified that approx. 5.8%of domestic nuclear capacity is “atrisk” of being retired and seeks to

preserve this zero‐CO2 emitting

capacity.

The expected generation f

construction and “at risk” 

added to the state’s gener

baseline, reducing overall intensity.

Under construction and at‐risk

nuclear capacity is also part of theinventory that the state can count

towards compliance with its state

goal.

Preserving at‐risk WTE pro

same benefit as preserving 

nuclear. Preservation of exfacilities avoids immediate 

in GHG emissions that wou

if the facility closed.
BSER Building Block #4 – End‐use Energy Efficie

EPA determines a

state‐specific

amount of net

generation that

could potentially be

avoided through

demand‐side

energy efficiency

measures.This avoidedgeneration is added

to the state’sgeneration baseline,

reducing overallcarbon intensity.
Calculate Interim and Final Goals Based on Building Blo

Interim State

Goal: Average of

the adjusted

yearly emission

rates for the

period 2020‐

2029

Final State

Goal:

The 2029emission ratebecomes the

state goal for2030 and eachyear thereafter

Data source: EPA Goal Computation Technical Support Document, Appendix 5 table. Levereductions from 2012 rates based on fossil, and compliance eligible renewables and nuclear.Note: Vermont is omitted since it does not have any fossil fuel-fired EGUs subject to regulat
A CLOSER LOOK AT BUILDING BLOCK 
BSER Building Block #3

EPA assumes that each

state can cost‐

effectively increaserenewable generation

to levels consistent

with the goals of

leading states in the

same region.

EPA assumes each state

will grow renewable

energy generation over

time towards thattarget, starting at the

state’s current level of

renewable energy.

The goal of BBlock #3 is to 

generation fpower secto

zero‐ and low

sources, thereducing the carbon intenentire powe
Renewable Energy Regions

The United States is divided into regions. WTE is represented in each reg

Source: Figure 4.3 in EPA’s GHG Abatement Measure

Support Document, June 2014. WTE facility locations 

the 2014 ERC Directory of Waste‐to‐Energy Facilities.
Regional Renewable Energy Generation Targets

A renewable energy generation

target is calculated for each

region, based upon averaging all

2020 RPS requirements in that

region.The Northeast has the largest

regional generation target, and is

home to 28 WTE facilities.

Region Regio

Generatio

Alaska 10East Central (19 WTE facilities) 16

Hawaii (1 WTE facility) 10North Central (16 WTE facilities) 15Northeast (28 WTE facilities) 25South Central (1 WTE facility) 20Southeast (13 WTE facilities) 10West (6 WTE facilities) 2

Source: Table 4.4 in EPA’s GHG Abatement Measures 

Support Document, June 2014.
Regional Renewable Energy Growth Factors

An annual growth factor is

calculated that would allow the

region as a whole to reach the

regional RE target in 2029

assuming that 2012 RE

generation levels would

increase at the prescribedgrowth factor starting in 2017.

The East Central Region must

grow the fastest to reach its

targets and that region is home

to 19 WTE facilities.

Region RE Gr

Alaska East Central (19 WTE facilities) 

Hawaii (1 WTE facility) 

North Central (16 WTE facilities) Northeast (28 WTE facilities) 

South Central (1 WTE facility) 

Southeast (13 WTE facilities) 

West (6 WTE facilities) 

Source: Table 4.5 in EPA’s GHG Abatement Measures 

Support Document, June 2014.
Anticipated Renewable Energy Growth

The annual growth factor for a given

region is applied to individual states’2012 RE generation starting in 2017

and carrying forward to 2029, not to

exceed a maximum RE generationlevel equivalent to the regional RE

target.Annual RE generation levels for eachstate are used to calculate interim

and final RE targets for that state.

Year Existing and Incremen

Generation (MWh)

2012 898,1522017 1,053,1652018 1,234,9322019 1,448,0712020 1,697,9952021 1,991,0532022 2,334,6912023 2,737,6382024 3,210,1292025 3,764,1692026 4,413,8302027 5,175,6172028 5,982,0692029 5,982,069

Example: Maryland, 17% Growth

Source: State 2012 Generation Figures drawn from T

GHG Abatement Measures Technical Support Docum

Annual growth drawn from EPA Goal Computation Te

Document, Appendix 1 & 2 spreadsheet, June 2014.
Compliance Flexibility

• While EPA’s proposed approach is derived from RPS data, 

may also consider a broad variety of other RE policies to 

generation. There is NO requirement for states to adopt 

• Options include performance‐based incentives, financial 

programs, regulatory changes to facilitate the developme

renewable sources and their interconnection to the grid a

by example” strategies integrating RE generation into stat

properties.

• States may also participate in regional multi‐state plans a

approaches.
ANALYSIS
Where will the Anticipated Renewable Growth From 2012‐2029

Annual growth in

the 6‐17% range

compounds at an

amazing rate.The opportunities

for renewablegrowth in certain

states is compelling.

States must enactrobust policies to

drive the renewable

deployment that

EPA is anticipating.Treatment of

interstate trading

will impact market

value.

Data source: State 2012 Generation Figures drawn from Table 4.1 in EPA’s GHG Abatement Measures TecDocument, June 2014. 2029 Anticipated Generation drawn from EPA’s Goal Computation Technical SuppAppendix 1 & 2 spreadsheet, June 2014 Note: Vermont is omitted since it does not have any fossil fuel-fired EGUs subject to regulation by 111(d).
How Much Does Existing WTE Contribute to Renewab

Energy (RE) Levels?

2012 Non‐

Hydro RE

Generation

(MWh) (using

only WTE from

Biogenic MSW)

2012 Net

Generation

(MWh) from WTE

from Biogenic

MSW

% of 2012 Non‐

Hydro RE from

WTE from

Biogenic MSW

2012 Net

Generation

(MWh) from WTE

from All MSW

% of 2012 Non‐

Hydro RE from

WTE from All

MSW if All MSW

is Included in

2012 Baseline *

CT 666,525 640,684 96.1% 1,256,244 98.0%

MA 1,843,419 913,131 49.5% 1,790,440 65.8%

NJ 1,280,715 546,554 42.7% 1,071,688 59.3%

MD 898,152 308,603 34.4% 605,101 50.7%

FL 4,523,798 1,473,268 32.6% 2,888,746 48.6%

VA 2,358,444 495,840 21.0% 972,229 34.3%

PA 4,459,118 871,004 19.5% 1,707,863 32.2%

NY 5,192,427 947,167 18.2% 1,857,252 30.4%

HI 924,815 152,877 16.5% 299,765 28.0%

MI 3,785,439 192,439 5.1% 377,329 9.5%

NH 1,381,285 68,185 4.9% 133,697 9.2%

2012 Non‐

Hydro RE

Generation

(MWh) (using

only Biogenic

MSW)

2012 Net

Generation

(MWh) from

Biogenic MSW

% of 2012 Non‐

Hydro RE from

Biogenic MSW

(

ME 4,098,795 135,826 3.3% 

MN 9,453,871 282,362 3.0% 

WA 8,214,350 71,553 0.9% 

OR 7,207,229 43,885 0.6% 

IN 3,546,367 21,172 0.6% 

WI 3,223,178 18,293 0.6% 

CA 29,966,846 152,790 0.5% 

UT 1,099,724 4,809 0.4% 

OK 8,520,724 10,469 0.1% 

IA 14,183,484 13,781 0.1% 

• EPA’s technical support documents uses U.S. EIA data to determine the amount of rene

electricity was generated in the baseline year. EIA only recognizes electricity generated 

Biogenic MSW as a RE generating technology. Electricity from Non‐Biogenic MSW is “O

• The GHG benefits of WTE will be maximized only if EPA allows states to include generat

MSW / WTE in their state compliance plans. This will allow WTE to fully benefit from t

that will be put into place to deploy GHG‐mitigating renewable energy technologies.

*

 ‐ “Percentage of 2012 Non‐Hydro Renewables from All MSW if All MSW is 

in the 2012 Baseline” was calculated by dividing the net generation from all 

the sum of 2012 non‐hydro renewable (using only biogenic MSW) totals and 

generation from non‐biogenic MSW. WTE generation data obtained from En

Information Administration.
POTENTIAL: How Much Could WTE Contribute to 2029 Renewabl

If U.S. wastemanagementpractices followed

a model favored

in Europe (relyingon increased

recycling and

increased WTE),

the U.S. could

meet significant

portions of its

climate goalsthroughdeployment of a

progressive andsustainable waste

managementsystem.

Source: 2029 Anticipated Generation drawn from EPA Goal Computation Technical Support Do1 & 2 spreadsheet, June 2014. Net WTE generation based on 30% of 2011 MSW levels reported University 2013 MSW Report and assumes that net electric generation of 650 KWh/ton of MSW toward the 2029 goal. 
Conclusions

• Electricity generated from Biogenic MSW was included in EPA’s techn

documents as a renewable generating technology that can red, howev

have flexibility to determine which renewables to include in their plan

• EPA is relying on existing renewable energy facilities (except existing h

and major growth in new renewables to reduce the carbon intensity 

state’s power sector.

• States have significant flexibility in meeting the standards. EPA will b

deferential as possible in approving state or multi‐state plans.

• This is not a national program; it is a federal program implemented b

technology must be part of each state’s plan to gain traction. The ben

technology will be the market drivers put in place at the state level.
Ted Michaels

PresidentEnergy Recovery Council

2200 Wil

Arling

202‐467‐6240

tmichaels@energyrecoverycouncil.org

www.energyrecoverycouncil.org