Abby L. Harvey
GHG Monitor
10/3/2014
Due to an overly aggressive timeline and flawed targets, the Environmental Protection Agency’s proposed carbon emission standards for existing coal-fired power plants cannot feasibly be implemented, Mark McCullough, Executive Vice President for Generation with American Electric Power said during the United States Energy Association’s Annual Energy Supply Forum this week. “We strongly support efforts to reduce the environmental impact of generation and delivery of electricity, but we’re here to say that it must be done in a way that recognizes the balance needed of affordability, reliability, cost impacts to our customer and the robustness for the future of the grid. EPA’s proposal—it’s not striking the balance that is needed as it’s designed today and we’d suggest that the design, while it attempts to give states flexibility though the four building block model, in engineering speak, it doesn’t solve,” McCullough said.
The regulations in question set carbon emission reduction targets for each state and require states to develop their own plans to meet their targets by 2030. The regulations propose four “building blocks,” or categories of emissions reductions, which apply both “inside the fence” like increasing the efficiency of power plants, and “outside the fence” like fuel switching to natural gas, increasing use of renewable and nuclear energy and promoting demand-side energy efficiency. Problems exist within the structure of the rule that must be addressed if EPA wants to achieve the kind of reductions the regulations call for, McCullough said. “As we take a deeper and deeper look at each of the building blocks we find issues, we find errors and flawed assumptions that won’t result in the kind of reductions that are assumed,” he said.
Timeline Insufficient for Well-Developed Planning
First, McCullough said, the timeline for the regulations is too aggressive to be realistic. “The ultimate reduction targets are set for 2030, but there’s a clear recognition that compliance starts in 2020 with some pretty high targets … that are difficult—I would even say impossible to meet,” he said. “State implementation plans to achieve those targets won’t be finalized until maybe 2018 or 2019, giving us a very short time period to make any infrastructure adjustments or asset improvements to comply by 2020,” he said.
Even if individual states were to succeed at putting plans in place, this could end up causing issues relative to the grid if not enough time is allowed for states to work together to ensure that their actions do not end up causing overall grid reliability issues. This could happen, McCullough said, due in part to the interconnectivity of the system. “Our transmission system has really been customized over 100 years. The generation is placed, by design, where it’s at according to the load disputes,” he said. “We have this 11 state territory, you can take any one of those states and say a plan that state submitted, if it involves retirement or new generation popping up, it affects all the states around the perimeter."
Targets Unrealistic
Further, McCullough said, the targets themselves are flawed as they are riddled with errors about the current coal fleet. “There are a number of flaws and assumptions about when unites were built, which ones will be in service in 2020 and a number of those kind of things,” he said also noting that while the plan calls for efficiency improvements at plants, it underestimates what improvements many plants have already undergone, making further efficiency improvements difficult to achieve.
