Abby L. Harvey
GHG Monitor
12/5/2014
As the public comment period for the Environmental Protection Agency’s proposed carbon emissions standards for existing coal-fired power plants came to an end this week, several environmental and industry groups released their final comments on the proposed rule, raising questions on, among other things, the proposed timeline for the implementation of the plan. The proposal, which was announced in June, would set state-specific emission reduction goals and requires the states to develop action plans to meet those goals. At issue with several interested parties is a portion of the second “building block” of the regulation that would set an interim goal. “It is unlikely that new infrastructure would be available to support the ramp up of natural gas fired units by 2020, thereby putting pressure on states and utilities to achieve more drastic emission reductions in later years of the interim compliance period to comply with the interim average emissions goal,” the American Coalition for Clean Coal Electricity said in comments submitted this week.
This “cliff” has been questioned by many state and industry officials with arguments that 2020 is too soon for such large emissions cuts to be made given the significant amount of time which would have to go into infrastructure expansion to facilitate an increased use of natural gas combined cycle (NGCC) plants. “The significant shift EPA contemplates from coal to natural gas would require significant investment in gas pipeline infrastructure to accommodate the increased demand for natural gas. Gas pipeline construction and upgrades require permits and approvals at the federal, state, and local levels that can take five years or more to secure and put in place. The timeframe that EPA has allowed for this Building Block does not recognize the extended period of design, permitting, and construction that would be required to increase the utilization of existing NGCCs,” the ACCCE wrote.
Phased Schedule Suggested
In late October, the EPA released a Notice of Data Availability addressing the 2020 interim goals that asked for suggestions for an alternative and noted several which had already been received, such as a phase-in schedule. In comments submitted this week, the Center for Climate and Energy Solutions (C2ES) supported this option. “Easing the emissions glide path in the first few years of the interim compliance period gives states time to focus on long-term infrastructure needs. Although EPA has determined that, on an average basis, many states have significant excess capacity at existing natural gas plants, this may not necessarily mean all of this capacity is available to displace coal-fired electricity on a year-round basis,” the comments say, noting seasonal shifts in generation needs in different regions of the country. “These concerns are surmountable with new or upgraded infrastructure, but this will take time to deploy. Building block [two] should be shaped in a way that accounts for this time,” the Center for Climate and Energy Solutions said .
C2ES also said that a phase-in plan would allow for states to widen their focus in developing their plans. In the currently proposed timeline, an initial focus is placed heavily on increased use of NGCCs, if that focus could be softened, C2ES suggested, states could shift some focus on other measures which could be taken to lower carbon emissions. “If states are forced to move too quickly to comply with a strict interim target, they are likely to prioritize solutions that are faster than large-scale renewable generation deployment, such as the construction of new natural gas power plant capacity. While new natural gas capacity would be preferable to coal, forcing this type of investment too quickly in order to meet the interim target may deter consideration of investment in zero-emitting capacity in later years, and thereby reduce the lasting impact of the Proposal,” the group said.
NRDC Calls for Five-Year Goals
At the opposite end of the spectrum is the Natural Resources Defense Council, which argued in the comments it submitted this week that the interim targets are necessary and achievable. “Recognizing that strong interim targets are essential in order to deliver near-term reductions in carbon pollution, states can scale up energy efficiency, coal-to-gas conversions and redispatch, and other actions achievable in the next five years. Concurrently, states and grid operators can begin the process of identifying longer lead-time resources such as new transmission needed for expansion of wind and solar power. With this combination of short- and near-term compliance strategies, together with continuing technology advances and falling costs, states are well-positioned to meet the standards while preserving grid reliability,” the group said.
Further, the NRDC suggested setting additional goals at five-year intervals. “EPA has proposed a ten-year averaging period between 2020 and 2029 for states to achieve the interim emission rate target. However, to ensure that states are making appropriate progress towards the interim target, EPA should instead provide two five-year interim compliance periods,” the group said. "You always hear a lot of hype about the timetable of EPA regulations, and we think that the timetable is already generous in that compliance is, with the first target in 2020, still more than five years away," David Doniger, policy director for NRDC’s climate and clean air program, told reporters during a press call this week.
EPA Remains Confident in June Deadline for Final Rule
When proposed, the regulations were set to have a 120-day comment period, which would have ended in October. However, the EPA extended the comment period in September to “give those entities wishing to submit comments the time they need to engage with us,” acting EPA Assistant Administrator for Air and Radiation Janet McCabe said at that time. According EPA spokeswoman Enesta Jones, more than 1.6 million comments were received and entered into the docket. The EPA still plans to have a final rule by June 2015, Jones told GHG Monitor this week.
