The U.S. Environmental Protection Agency (EPA) has begun to regulate greenhouse gas emissions from electric generating plants under the Clean Air Act. There are three parts to this regulation.
- Regulation under plant permits. As of January 2011, greenhouse gas emissions from many new and some modified fossil fuel power plants are regulated under the New Source Review program of the Clean Air Act. This program evaluates the plant’s greenhouse gas emissions and processes before the plant can receive a permit to operate.
- Regulation of new plants. In April 2012, EPA proposed to regulate carbon dioxide from new power plants under Section 111 of the Clean Air Act, the New Source Performance Standards (NSPS). The proposed NSPS rule requires all new steam and combined-cycle electric generating plants, regardless of fuel type, to meet a standard that today can be achieved only by a new natural gas combined-cycle generating plant. The rule allows construction of new coal plants only if owners commit to install carbon capture and storage (CCS) technology within 10 years. Because CCS is not yet commercially available for coal plants, the regulation may eliminate the construction of new coal plants at least for the next few years.
- Regulation of existing plants. While EPA has not yet proposed regulation for existing plants, they have announced the intent to regulate greenhouse gases from existing generating plants under Section 111(d) of the Clean Air Act. They may adopt a variety of approaches to regulate these emissions, including a stack-by-stack emission limit. However, the Clean Air Act also gives flexibility to states to adopt other programs to achieve equivalent or better greenhouse gas reduction.
While Xcel Energy has no plans to develop new coal plants, we do not support regulation that prohibits new coal. Our experience shows that, with the right policy, it is possible to construct new, more efficient coal plants without carbon capture and storage technology and still reduce overall emissions.
We support and are advocating for a state clean energy program alternative for regulating and reducing greenhouse gas emissions under the Clean Air Act. The Clean Air Act provides for this option, which from experience we know can achieve significant, cost-effective emission reductions.
Why we like the state clean energy program alternative:
- A unit-by-unit Section 111(d) program can achieve only limited emission reductions through generating plant efficiency improvements. It ignores the system-wide emission reduction benefits associated with renewable energy, customer energy-efficiency programs and plant retirements.
- State clean energy programs achieve significantly greater greenhouse gas reductions. These programs include initiatives such as state renewable energy standards, energy conservation policies and comprehensive utility emission-reduction programs.
- Through our experience with clean energy programs in Minnesota and Colorado, we estimate that our greenhouse gas reductions by 2020 will be three to four times greater than if we had retained all of our aging coal-fired generating plants and maximized their efficiency under Section 111(d) regulation.