# 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

2 

### • 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.

• I n 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

• FeasibilityBuilding 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/low

emitting energy sources Renewable 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
34 

# Pennsylvania State Goal Summary

# States Have Flexibility

Basis for state goal

– Potential e missions 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

5Carbon emissions from affected powerplants 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.

• U p 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, CO 2 

### emissions from utilities on a regional basis.

• EPA would support building off existing reduction programs.

6

# 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

7

# 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 b lock 3 and how building b lock 3 targets relate to compliance options

• The way the state

- specific CO 2 goals are calculated

• Goal

- setting equation

• Alternatives to the 2012 data year

9

# Rate

- to

- Mass Technical Support Document

• Issued on November 6, 2014 in response to requests from states and other stakeholders.

• P rovides 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 = CO 2 

## Emissions Rate * Generation

• In calculating a mass

- based equivalent, EPA used each state’s proposed rate

- based goal from the June 2 nd 

## 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. 1011 By mid
- summer 2016 State submits initial multi
state 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 multi
state 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 m ulti - state P lan by June 30, 2016 and request 2 - year extension Emission Guideline Promulgation mid
- summer 2015 by mid
- summer 2016 State submits n egative 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