Public Power: EPA’s New Source Performance Standards Won’t Work in the Real World
May 9, 2014
Washington, D.C., May 9, 2014 – The American Public Power Association (Public Power) today called on the Environmental Protection Agency (EPA) to withdraw its re-proposed standards of performance for carbon dioxide emissions, a greenhouse gas, from new fossil fuel-fired power plants.
Public Power is concerned that EPA’s proposed new source performance standards (NSPS) for greenhouse gases will effectively eliminate coal from the nation’s future electricity generation sources, which will lead to risky overreliance on natural gas and increased costs for electric customers. This result contradicts the Obama Administration’s assertion of support for a diverse, “all-of-the-above” approach to the generation mix. Public Power urges EPA to set the emissions standard at 1,950 lbs. CO2/MWh, a rate attainable by the most advanced coal technology currently available.
“Since 2007, the electric utility industry’s carbon dioxide emissions have fallen by more than 12 percent. Public power is proud of the steps it has taken—and will continue to take—to curb greenhouse gas emissions. At the same time, we need to be able to rely on a truly diverse set of resources to serve our customers affordably and reliably,” said Public Power President and CEO Sue Kelly. “Unfortunately, this new source mandate from EPA won’t work in the real world given current technology.”
By requiring the application of carbon capture and sequestration (CCS) technology, EPA continues to ignore the facts on the ground. Nothing in the record, the proposal, or the supporting technical documents substantiates EPA’s claim that CCS is the Best System of Emissions Reduction (BSER) adequately demonstrated as required by the Clean Air Act. EPA concedes that CCS is not in commercial use at any existing electric utility in the country but relies on a handful of pilot projects to assert that CCS is BSER. Moreover, the standard for coal relies on the ability of utilities to inject carbon dioxide into the ground and keep it there for hundreds of years—a process that—again—has not been adequately demonstrated.
None of the projects that EPA references as “demonstrated projects” are even operating. “Public power is having a tough time understanding how something can be demonstrated if it doesn’t yet exist,” said Kelly.
EPA completely ignored stakeholders’ calls to address the injection practice’s environmental impacts on water and soil, as well as a host of related state legal issues that pose substantial barriers.
Public Power also comments that the standard for new combined cycle natural gas plants is too restrictive. Due to the variable nature of many renewable resources, natural gas plants are often used to “fill in the gaps.” This ramping up and down in support of renewables such as wind and solar increases carbon dioxide emissions as the natural gas plants age.