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The First Cut is the Deepest: EPA Proposes First GHG Cuts for Power Plants

MOUNTAINS_Mountains_Montana_MHoldenBy Cecilia Segal — Oct. 9, 2013 at 2:14pm

On September 20, 2013, EPA issued a notice of proposed rulemaking to set standards of performance for GHGs emitted from new stationary sources. The proposal calls for new natural gas-fired plants to be built with an emissions limit of 1,000 lb CO2/MWh for smaller units and 1,100 lb CO2/MWh for larger units. New coal-fired plants must not exceed an annual average emission rate of 1,100 lb CO2/MWh. Alternatively, coal plants may elect to meet a 1,000 or 1,050 lb CO2/MWh/yr average over a seven-year period.

This rule proposal comes on the heels of a similar rule that was proposed in April 2012 but withdrawn on September 20, 2013. That earlier rule proposed a uniform standard for both natural gas- and coal-fired plants. Given new information discovered and the number of public comments received – over 2.5 million –in response to the 2012 rule, EPA felt substantial changes to the proposed standards were warranted and thus rescinded the 2012 version.

At first glance, the 2013 rule seems modest at best. It impacts only new plants being built, to the exclusion of existing, modified, or reconstructed sources. EPA also asserts that due to current industry trends – where low natural gas prices will encourage the construction of new natural gas, and not coal, power plants that already meet the emissions limits proposed – this rule “will result in negligible CO2 emission changes, quantified benefits, and costs by 2022.” With no declared costs or benefits, why then are environmentalists celebrating this rule and coal industry representatives condemning it?

There are a few reasons for this rule’s polarizing effect. For starters, this rule will in fact prevent the construction of any new coal-fired power plants that are allowed to emit an unlimited amount of CO– a huge win for environmentalists. Instead, such plants must incorporate partial implementation of carbon capture and sequestration (CCS) technology to reach the emissions limits. This is the piece that worries industry advocates. Because of its limited implementation to date, CCS is a young, expensive technology. Indeed, a coal plant with partial CCS will cost either 109 or 110 dollars per Megawatt hour, compared with 92 or 97 dollars per Megawatt hour without CCS technology. However, the main benefit of regulating CCS technology is that it will encourage technological innovation and widespread commercialization, which will in turn lower costs.

A bigger cause of the rule’s controversy is its symbolic effect. With this rule proposal, EPA is utilizing the authority granted it under Massachusetts v. EPA to regulate GHGs emitted by stationary sources for the first time ever. Moreover, this first step is a pivotal piece of President Obama’s Climate Action Plan, in which Obama intends to take executive action to evade congressional gridlock and move ahead with climate change regulation. This includes a rule imposing emissions limits on existing sources, to be proposed in June 2014. For this reason, opponents are denouncing the move as sparking a “war on coal.”

The real fight, then, is just gearing up. With standards regulating existing sources looming on the horizon, and possible Supreme Court review of Coalition for Responsible Regulation v. EPA, the D.C. Circuit decision upholding EPA’s GHG regulating authority, the next few months will mark a significant era in the U.S.’s stance on climate change.

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One Comment

  1. KarlOctober 14, 2013 at 1:55 amReply

    I could not believe it and now I see this is done by a student publication, so I guess a high or junior high HIGH student in refering to construction costs by the watt hours resulting entire business days ago. This is important. “OR” does not describe a range either.

    The essence of the matter is that a distinction between built and unbuilt plants exists now in how they are to be operated. You clearly are referring to the plant not the energy it will lose and the pollution it will generate converting what remains to electricity to be sold to a grid that by design will always be sociopathic when powering more then light and logic.

    A relationship exists between oxygen consumption for a particular fuel and electricity obtained as it does for what becomes of that oxygen. By failing but attempting to price the capture of that new molecule not by how many but rather by the potential revenue an opportunity for clarity is lost.

    Was this an opinion piece? Please when you remove the H consider redundancy beyond that in your specification of energy output versus cost. Please remind people that water is being heated from heat from burning despite the ability to obtain it from existing processes for less then free and that ice cold water is actually hundreds of degrees above zero in Kelvin meaning several times as much heat can be obtained from making ice with a certain amount of energy versus burning it at 100 PERCENT efficiency.

    For example for about ten thousand dollars installed you can obtain half a million btu’s of heat from outdoor air using well under a 100,000 btu’s of even grid electric delivered power.

    This though is a rare exception. But even in it we instead waste far more on fetish solar that costs far more to buy, own, and operate across time. I was linked here on your site by an artice that was apparently quite informative about a lack of regulation even now for wasted methane. Why is beef not taxed? Why does Australia for years discuss openly there intent years ago to charge coal for methane not captured yet I didn’t find much about that in the U.S.

    Much worse if more then 3 percent it says coal is better. Well over 15 percent is used to ship it, which is only five times as much, not twenty.

    I do not understand the amount of cheap speech. Someone should be expelled.

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