CLEAN POWER PLAN 

Proposed Carbon Pollution 

Standards For Existing 

Power Plants

Shutsu Wong

EPA Region 1

Regional P2, Assistance and Sustainability Meeting

October 28, 2014
Outline

• President’s Climate Action Plan

•Background on Clean Air Act Section 111(d)

• Setting State Goals

• Flexibilities Available to States

• State Plans

•How to comment

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President’s Climate Action Plan

•Reduce carbon pollution from 

power plants

• Prepare the U.S. for the impacts 

of climate change

• Lead international efforts to 

address global climate change

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This Proposal Deals With the Largest Source 

of GHG Emissions in the U.S.

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Reducing Carbon Pollution From Power Plants

President’s Directive to EPA:

Develop carbon pollution standards, regulations or 

guidelines, as appropriate, for:

1. New power plants

• Proposed: January 8, 2014

2. Modified and reconstructed power plants

• Proposal: June 2014

• Final: June 2015

3. Existing power plants

• Proposed Guidelines: June 2014

• Final Guidelines: June 2015

• State Plans due: June 2016

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• Lays out different approaches for new and existing 

sources

• New sources under section 111(b)

• Federal standards for new, modified and reconstructed 

sources

• Existing sources under section 111(d) 

• State programs for existing sources that are equivalent to 

federal guidelines

•Applies the “Best System of Emissions Reduction” 

(BSER)

• Feasibility

• Costs

• Technology

• Size of Reductions

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EPA’s Regulatory Approach

Clean Air Act Section 111
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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State Performance Goals (lbs/MWh)

State 2012 Fossil 

Emission Rate1

Interim Goal (2020 -

2029 average)2

Final Goal (2030 

and thereafter)2

Connecticut 844 597 540

Maine 873 393 378

Massachusetts 1,001 655 576

New Hampshire 1,119 546 486

Rhode Island 918 822 782

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1 From Goal Computation Technical Support Document, Appendix 5 – 2012 Emissions Rate and Building Block Application

2 From Table 1 to Subpart UUUU of Part 60 – State Rate-Based CO2 Emission Performance Goals, Proposed
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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State Plans & Criteria

• The EPA will evaluate the sufficiency of each plan based on the plan 

addressing twelve plan components and on four general criteria to 

determine whether a state’s plan is “satisfactory” under CAA section 

111(d)(2)(A)

• Four general criteria 

1. A state plan must contain enforceable measures that reduce EGU CO2

emissions from affected EGUs

2. Measures in the plan must be projected to achieve emission performance 

equivalent to or better than the applicable state-specific CO2goal on a 

timeline equivalent to that in the emission guidelines

3. EGU CO2 emission performance under the state plan must be quantifiable 

and verifiable 

4. The state plan must include a process for state reporting of plan 

implementation (at the level of the affected entity), CO2 emission 

performance outcomes, and, if necessary, implementation of corrective 

measures

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See FR 34909-34911 for more detail
Required State Plan Components

1. Identification of affected entities (affected EGUs and other responsible 

parties)

2. Description of plan approach and geographic scope

3. Identification of required emission performance level for affected EGUs

4. Demonstration that plan is projected to achieve required emission 

performance level

5. Identification of milestones

6. Identification of corrective measures

7. Identification of emission standards and any other measures

8. Demonstration that each emission standard is quantifiable, non-duplicative, 

permanent, verifiable, and enforceable

9. Identification of monitoring, reporting, and recordkeeping requirements

10. Description of state reporting

11. Certification of hearing on state plan

12. Supporting material

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See FR 34911-34915 for more detail
Toolbox for States

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http://www2.epa.gov/cleanpowerplantoolbox
Next Steps

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

and supporting technical information, are available online at: 

http://www.epa.gov/cleanpowerplan

• Comments on the proposal should be identified by Docket ID No. 

EPA-HQ-OAR-2013-0602. 

• Comment period closes: December 1, 2014

• Final guidelines: June 1, 2015

• State plans due: June 30, 2016

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For more information

http://www.epa.gov/cleanpowerplan