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EPA Kick-Starts Carbon Pollution Standards for Power Plants

David Doniger

Posted August 30, 2013 in Curbing Pollution, Solving Global Warming, U.S. Law and Policy

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In a half-hour YouTube video, the Environmental Protection Agency this week kicked off an ambitious drive to engage states, industry, the public health and environmental community, labor, and others in the nuts and bolts of developing standards to cut the dangerous carbon pollution coming from the nation’s electric power plants. 

Curbing power plants’ carbon pollution is the centerpiece of President Obama’s Climate Change Action Plan, announced in June.  The president’s plan calls for cutting total U.S. carbon pollution 17 percent by 2020, from 2005 levels.  We’re part way there already, but it will take more to reach this target.  So, along with other important actions, the president’s plan sets specific deadlines for EPA to use the Clean Air Act to cut the 2.2 billion tons of carbon dioxide (CO2) pollution coming from existing power plants each year. 

NRDC strongly supports the president’s climate plan and his focus on power plants, and we’re glad to see EPA moving forward.  Last year we started the ball rolling with an innovative plan to cut the power sector’s CO2 emissions by more than a quarter by 2020, compared to 2005 levels.  Our plan would bring climate protection and public health benefits worth $26-60 billion in 2020, at a reasonable cost of $4 billion.  Now the EPA public engagement process will draw out more proposals and draw in more stakeholders, and the process will pick up speed.

The EPA video presents an excellent overview of a little known but potent part of the Clean Air Act – called Section 111(d) – that gives EPA and the states specific roles in setting and enforcing carbon pollution standards for the nation’s more than 1500 coal- and natural gas-burning power plants.

The video reminds us why carbon pollution is dangerous.  Referring to EPA’s 2009 endangerment finding, the video reminds us that “the current and projected concentrations of six key greenhouse gases in the atmosphere threaten the public health and the welfare of current and future generations.”

These pollutants if left unchecked lead to long-lasting changes in our climate, such as: 

  • Rising global temperatures – they've risen 1.3 degrees Fahrenheit over the past 100 years.  In fact, 8 of the 10 warmest years on record have occurred since 2001. 
  • Rising sea level – which can increase the risk of storm surge and flooding along our coasts. 
  • Changes in weather and precipitation patterns that can lead to changes in ecosystems, habitats and species diversity

These changes threaten America's health and welfare for current and future generations. Public health risks include:

  • More heat waves and drought
  • Worsening smog, also called ground-level ozone pollution
  • Increasing the intensity of extreme events, like hurricanes, extreme precipitation and flooding
  • Increasing the geographic range of ticks and mosquitoes, which can spread disease such as Lyme disease and West Nile virus

Our most vulnerable citizens, including children, older adults, people with heart and lung disease and people living in poverty may be most at risk from the health impacts of climate change.

The EPA video then describes how “performance standards” for existing power plants will be set under Section 111(d).  It explains the deadlines set by President Obama:  EPA is to propose performance standards in “emissions guidelines” by June 2014, to solicit and consider public comments, and then to adopt final guidelines by June 2015. 

These federal emissions guidelines, the video explains, “are binding on states” and set “the goal or mark that States have to meet when developing standards of performance for existing sources.”  States then will have until June 2016 to adopt state plans that apply enforceable performance standards consistent with the guidelines to each of the carbon-emitting power plants in within their borders.

Here’s where the video gets especially interesting.  It says:

EPA believes the unique characteristics of carbon pollution and the interconnected nature of the electric power sector call for a broad and flexible approach to designing the program for existing power plants.  The President has told us to consider the full range of possibilities as we develop approaches that could accommodate market-based instruments, performance standards and other regulatory flexibilities.

It then summarizes the range of approaches already in discussion among stakeholders, and offers some useful common definitions: 

To help everyone build a common understanding of the range of opportunities for emission reductions, we want to take a moment to define some of these concepts.  First, the ideas of a "source-based approach" and a "system-based approach." 

A source-based approach evaluates emission reduction measures that could be taken directly at the affected sources – in this case – the power plants.

A system-based approach evaluates a broader portfolio of measures including those that could be taken beyond the affected sources but still reduce emissions at the source.

And when we talk about source-based and system-based approaches, there are a few additional terms that we should recognize.  First, supply-side options.  This term generally refers to actions that occur at the regulated source itself or at other power plants.  Second, demand-side options. This term generally refers to actions that occur at locations where electricity is used as well as transmitted and distributed -- not at the regulated source or other power plants.

Supply-side options can directly reduce or avoid power plant carbon dioxide emissions through energy efficiency at the source. They can also indirectly reduce or avoid power plant carbon dioxide emissions by increasing the use of low- or non-emitting electric generation.  Examples may include:

  • Heat rate improvements or energy efficiency at the electric generating unit;
  • Fuel switching to a lower-emitting fuel or co-firing to a lower-emitting fuel;
  • Re-dispatch of the electric generating unit based on carbon dioxide emission rate;
  • Or renewable energy portfolio requirements.

Demand-side options can indirectly reduce or avoid emissions by lowering electricity demand.   These can reduce the overall amount of electricity generated at carbon dioxide emitting power plants.  They may also change the dispatch of electric generators in response to lower electricity demand.  Examples may include:

  • End-use energy efficiency requirements and programs;
  • Demand-side management programs.

And you may know your own state has many of these programs already in place. Demand-side options address actions that reduce electricity usage by reducing demand and improving the efficiency of energy-using devices.  This could include such things as improving insulation and reducing energy losses, reducing wasteful energy use, and replacement of old or inefficient appliances in favor of high efficiency appliances.  

Let me say again, that these are just some of the basic concepts that EPA is aware of that are being discussed among stakeholders – and these may be ideas that may fit under section 111(d).

This is an excellent description of the range of measures that NRDC believes EPA should consider when determining the 111(d) performance standards that should apply in each state, and that should be available to power generators for compliance. 

In fact, it’s an excellent description of the system-based approach in NRDC’s power plant proposal.  With these measures, as we’ve shown, we can cut power plant carbon pollution by more than a quarter, with huge climate and health benefits, and modest costs.

To be sure, there are many steps ahead to be sure that these standards are strong enough.  Meeting the president’s 17 percent national reduction target for 2020 is going to require power plants – the largest polluters and among the cheapest to control – to make considerably more than a 25 percent reduction from 2005 levels. Fortunately, they are a good way down from that starting point already, and NRDC’s plan shows the rest is well in reach.

Millions of people have raised their voices to call for curbs on power plants’ carbon pollution and to support the president’s climate action plan.  Click here to add your voice today. 

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Switchboard is the staff blog of the Natural Resources Defense Council, the nation’s most effective environmental group. For more about our work, including in-depth policy documents, action alerts and ways you can contribute, visit NRDC.org.

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