STATES ASK EPA FOR ‘FLEXIBLE’ RULES ON GHGS FROM EXISTING PLANTS

Karen Frantz
GHG Monitor
12/20/13

A group of environmental and energy agency leaders and public utility commissioners from 15 states asked the Environmental Protection Agency this week for “a stringent but flexible framework” as it develops new rules for reducing greenhouse gas emissions from existing coal-fired power plants. The Dec. 16 petition outlines a variety of state programs that it says are achieving carbon emissions reductions from the power sector and urges the EPA to develop a emission reduction standard and guidelines that are “based on a ‘best system of emission reduction’ that reflects the full range of approaches that states have successfully demonstrated’”; that “equitably [recognize] the different starting points and circumstances of different states”; and that “allow for a variety of rigorous state compliance options, including options for compliance through participation in regional emission budget trading programs and state portfolio programs”—such as California’s AB 32 and the Regional Greenhouse Gas Initiative.

“Our states—along with others—have developed a variety of state programs that achieve substantial, cost-effective carbon emission reductions and improvements in net carbon emission rates,” the letter said. “Through market-based programs, renewable portfolio standards, energy efficiency resources standards and funding commitments, utility planning and other efforts, our states have reduced carbon pollution from the electricity sector by 20 percent from 2005 to 2011, and similarly improved our net carbon emission rate 19 percent over the same time period, from 941 to 759 pounds CO2 per megawatt hour of electricity produced (Lbs Co2/MWh). … Our state programs have been developed through substantial democratic processes, and reflect the different on-the-ground experience of our states, including differences in the structure of energy markets and market participants. Taken together, these approaches are driving improvements and innovation through the electricity system, leading to a cleaner and more efficient system overall.”

Carbon Capture and Sequestration Programs and Policies

The petition outlines a number of measures states have already taken to reduce carbon emissions, including market-based approaches, renewable portfolio standards, energy efficiency standards and programs, state and utility planning efforts and programs, combined heat and power incentives and state new source performance standards. It also points to state carbon capture and storage programs, saying such projects and policies “can play an important role in achieving reductions from the existing fossil fleet.” In particular it highlighted Illinois, which passed the Clean Coal Portfolio Standard Law that requires new coal-fired power plants to “capture and store more than half of the carbon emissions that the facility would otherwise emit,” and which also has provided support to the FutureGen CCS project.

CCS also made a notable appearance in a section in the petition detailing state initiatives that identify the “Best System of Emission Reduction.” In outlining state programs that can reduce emissions, it pointed to “changes at individual covered sources,” which included CCS as one such technological method and “implementing advanced systems for combustion and dispatch optimization, or oxy-combustion systems” as others. The EPA identified carbon capture and storage as the BESR for achieving greenhouse gas emissions limits from new coal-fired power plants in proposed rules, which was met with intense criticisms from many legislators from coal states and some industry leaders who say the technology has not been adequately demonstrated on a commercial scale.

But the petition also says that best emission reduction systems shift the electricity grid away from fossil fuels and “high-carbon sources” by adding renewables and energy efficiency. “As state experience has shown, reducing demand for fossil generation or providing alternative, cleaner, sources of supply achieves emissions reductions far beyond the level that can be achieved by improving the operations of individual fossil plants,” the petition said.