CLEAN POWER PLAN

Proposal to Reduce 

Carbon Pollution From 

Existing Power Plants

March 23, 2015
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 in light of the 

interconnected nature of power generation.

• BSER factors

• Costs

• Size of reductions 

• Technology

• Feasibility
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

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Pennsylvania State Goal Summary
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
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 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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Recent Developments

• The proposed rule and supporting technical information are available 

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

• The public comment period ended on December 1, 2014.

• Public hearings were held:

• July 29 Atlanta and Denver

• July 30 Washington DC

• July 31 Pittsburgh

• Notice of Data Availability (NODA)

• Supplemental Proposal for Indian Country and Territories

• Rate-to-Mass Technical Support Document

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Clean Power Plan: Public Comment 

Period and What We’ve Heard

• Common issues

• State goals 

• Interim targets (the glide path)

• 2012 as a “baseline”

• Credit for early action

• Rate-based vs. mass-based goals

• The building blocks

• Biomass

• Renewable energy

• Dispatch

• Enforceability 

• Multi-state plans

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Responding to Public Input: Notice of 

Data Availability

• Issued on October 28, 2014

• Purpose 

• Describe and seek comment on several ideas raised by multiple stakeholders 

• Bring these ideas to the attention of other stakeholders and the public so that they 

have the opportunity to consider them as the develop their comments. 

• Topics

• Glide path of emission reductions from 2020 to 2029

• Certain aspects of the building block methodology

• Stringency of building block 2

• Methodology for building block 3 and how building block 3 targets relate to 

compliance options 

• The way the state-specific CO2 goals are calculated

• Goal-setting equation

• Alternatives to the 2012 data year

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Rate-to-Mass Technical Support Document

• Issued on November 6, 2014 in response to requests from states 

and other stakeholders.

• Provides two examples of how a state could translate its rate based 

goal to total metric tons of carbon (a mass-based equivalent). 

• The basic formula for translating from a rate-based goal to a mass- based equivalent is: 

Mass = CO2 Emissions Rate * Generation

• In calculating a mass-based equivalent, EPA used each state’s 

proposed rate-based goal from the June 2nd proposal as the 

emissions rate. 

• The TSD describes two approaches conceptually and applies the 

calculation to an example state. • The first approach calculates generation from existing affected fossil fuel-fired sources using historical data. 

• The second approach calculates generation from existing affected and new fossil fuel-fired sources using a 

combination of historical and projected data. 

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By mid-summer 2016

State submits initial multistate plan and request for 2-

year extension

EPA reviews initial plan 

and determines if 

extension is warranted

by mid-summer 2017

State submits progress 

report of plan

by mid-summer 2018

States submits multistate plan

State submits Negative Declaration

State submits complete implementation Plan by mid-summer 2016

State submits initial Plan by mid-summer 2016 and request 1-year extension

State submits initial multi-state Plan by June 30, 2016 and request 2-year extension

Emission 

Guideline 

Promulgation

mid-summer 2015

by mid-summer 2016

State submits negative 

declaration

EPA publishes FR notice

by mid-summer 2016

State submits plan

by mid-summer 2016

State submits initial plan 

and request for 1-year 

extension

EPA reviews initial plan and 

determines if extension is 

warranted

by mid-summer 2017

State submits complete plan

2015 2019

Proposed Implementation Timeline

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
Thank you!

Mike Gordon

215-814-2039

gordon.mike@epa.gov

Air Protection Division

US Environmental Protection Agency Region 3

1650 Arch Street

Philadelphia, PA 19103