APPA Response to EPA's Re-proposed Rule Curbing GHG Emissions for New Coal-fired and Natural Gas-fired Power Plants
January 8, 2014
The American Public Power Association (APPA) is extremely disappointed with the re-proposed New Source Performance Standard for new coal and natural gas-fired power plants published in the Federal Register by the U.S. Environmental Protection Agency (EPA) today. In our view, this re-proposed rule effectively precludes coal going forward as a resource for electricity generation. This will limit our future resource options and could likely lead to higher electricity rates in the coming years.
EPA is inappropriately mandating that utilities wanting to invest in new coal-fired generation utilize carbon capture and sequestration (CCS) technology to reduce carbon dioxide (CO2) emissions based on four CCS projects that are not currently operational and that have not been commercially demonstrated. According to several APPA studies, it is unlikely these projects will be commercially demonstrated anytime soon given the myriad of regulatory hurdles impeding the sequestration of CO2 in the U.S. In addition, all of these projects are tied to enhanced oil and gas recovery (EOR), which will not be an option for most new coal-fired power plant locations.
EPA’s Science Advisory Board (SAB) will convene a meeting via conference call on January 21, 2014, to further discuss whether the re-proposed NSPS is based upon peer reviewed science. It will also investigate whether EPA failed to look at water use, water access, and other liability issues related to sequestration. APPA has repeatedly communicated with EPA regarding the many obstacles to commercial demonstration of sequestration for power plants in non-EOR locations and looks forward to the upcoming review by the SAB.