Timely information on the implications of USEPA's two new regulations for greenhouse gas emissions from power plants.

1. © 2015 CH2M HILL
Final CO2 Regulations for the Electric Power Industry
Electric power generation contributes to approximately 40% of U.S. emissions of carbon
dioxide (CO2). In August 2015, the U.S. Environmental Protection Agency (EPA) released
two Final regulations associated with CO2 emissions from electric utility generating units
(EGUs).
The first regulation, the Clean Power Plan (CPP), is associated with CO2 emissions from
affected fossil fuel–fired existing EGUs. The second regulation, the Carbon Pollution Standards,
is associated with New Source Performance Standards (NSPS) for emissions of CO2 from newly
constructed, modified, and reconstructed affected fossil fuel–fired EGUs.
Summary of Regulations
Clean Power Plan for Existing Power Plants. Implementation of the CPP for existing power
plants will result in CO2 emission reductions from the power sector of approximately 32% by 2030,
as compared to 2005 nationwide CO2 emission levels. It is the single most important component to
meeting the Administration’s goal of reducing greenhouse gas emissions 26–28% by 2025, as
submitted to the UNFCCC.
Under this plan, States have been assigned their own CO2 interim and final reduction goals, and they
have the flexibility to decide how to meet their goals, with EPA’s approval.
Carbon Pollution Standards for New, Modified, and Reconstructed Power Plants.
This rule consists of NSPS for new, modified, and reconstructed fossil‐fueled fired EGUs, which must
obtain permits under the Clean Air Act’s New Source Review (NSR) program. Depending on the
category of construction, the standards set for natural gas are reflective of modern combined cycle
plant efficiency or the use of clean fuel, and the standards set for coal are reflective of modern
design plus partial carbon capture and storage (CCS), or the most efficient generating
technology/equipment upgrades for coal.
Who Is Affected and What Are the Requirements?
Clean Power Plan for Existing Power Plants. The CPP applies to States with fossil fuel–fired
EGUs whose construction began on or before 1/8/2014 and meet the applicability criteria under 79 FR 1430; January 8, 2014. EPA is also
setting emission standards for affected EGUs on three Indian reservations. Vermont and the District of Columbia (DC) do not have affected
EGUs; in addition, EPA is not setting CO2 emission performance goals for Alaska, Hawaii, Guam, and Puerto Rico in the final rule at this time.
Development of State-specific Goals: EPA determined the 2012 average emission rates for coal/oil steam plants and natural gas combined
cycle plants across three regional electricity interconnects: Western, Eastern, and the Electric Reliability Council of Texas. EPA then
determined to what degree these emission rates could be reduced by employing feasible coal plant efficiency improvements, load shifting
from coal to natural gas generation, and development of additional renewable generation capacity. The least stringent/most achievable rates
across the three regional interconnects (Eastern) became country-
wide uniform CO2 emission performance rates: 1,305 lb CO2/MWh
for fossil steam EGUs and 771 lb CO2/MWh for natural gas
combined cycle EGUs. All State emission rate targets in 2030 fall
between these two values.
Specifically, final 2030 State emission rate targets were calculated
based on a 2012 weighted average of the States’ baseline fossil fuel
mix (percentage of natural gas combined cycle plant generation
and percentage of fossil steam generation) and the uniform
emission performance rates. The States’ interim rate was derived
by averaging annual adjusted emission rates for 2022–2029. EPA
also developed mass-based goals for the States.
Meeting State-specific Goals: States have various flexibilities under
the guidelines, such as:
 Achieving their goals by employing federally enforceable source-specific requirements on affected EGUs, including emissions trading, or
by employing a mixture of non-federally enforceable (e.g., improving residential energy efficiency) and federally enforceable source-
specific requirements with a federally enforceable fallback plan
 Choosing among CO2 emission reduction standards: (1) State rate-based goal in lb CO2/MWh, (2) State mass-based goal in total short
tons of CO2, (3) State mass-based goal with a new source complement (to account for new sources) in total short tons of CO2, or (4) CO2
emission performance rates for each type of fossil fuel-fired EGU in lb CO2/MWh
 Achieving their goals on an individual state or regional basis
Upcoming Deadlines Related to the
Clean Power Plan (Existing Power
Plants):
 September 6, 2016—States submit
either a final plan or an initial submittal
with a request for an extension
 September 6, 2018—States submit final
plan (those that requested an
extension)
 January 1, 2022—Compliance period
begins for Interim CO2 emission goals
 January 1, 2030—Final CO2 emission
goals target date
More information can be found at:
http://www2.epa.gov/cleanpowerplan/cle
an-power-plan-existing-power-plants
Carbon Pollution Standards for
New, Modified, and
Reconstructed Power Plants
 In effect for new power plants built
after January 8, 2014 and plants
reconstructed or modified after June,
18, 2014
More information can be found at:
http://www2.epa.gov/cleanpowerplan/car
bon-pollution-standards-new-modified-
and-reconstructed-power-plants
Final State Emission Rate Targets
Source: http://www.c2es.org/federal/executive/epa/carbon-pollution-standards-map

2. © 2015 CH2M HILL
Final CO2 Regulations for the Electric Power Industry
Interim CO2 performance rates have to be met between 2022 and 2029, and the final CO2 emission performance rates have to be met by
2030. The States have to submit a Draft and a Final Plan to EPA that, among other requirements, details how they will meet their goals while
maintaining electric system reliability and engaging with communities.
Industry Planning/Early Involvement: Utilities should advocate for the most economically advantageous plan with their State regulatory
agency, and monitor their State’s plan development in order to strategize and account for future generation mix.
Carbon Pollution Standards for New, Modified and Reconstructed Power Plants. The following table summarizes the
applicability/associated NSPS requirements that are in place for EGUs, including the Best System of Emission Reduction (BSER) that each NSPS
was based on.
Types of EGU Construction NSPS/BSER: Natural Gas–Fired EGUs NSPS/BSER: Coal-Fired EGUs
New
Any newly constructed fossil fuel‐fired
power plant whose construction began
on or after January 8, 2014.
NSPS for base load units*: Can emit no more than
1,000 lbs of CO2 per MWh of electricity produced
BSER: Latest combined cycle technology
NSPS for non‐base load units*: heat input based
standard of 120 lb CO2/MMBtu)
BSER: Use of natural gas with a small allowance for
distillate oil
NSPS: Can emit no more than 1,400 lbs CO2/MWh
BSER: The use of highly efficient supercritical pulverized
coal (SCPC) units with partial (20%) carbon capture and
storage (CCS) technology
Reconstructed
A unit that replaces components to
such an extent that the capital cost of
the new components exceeds 50% of
the capital cost of an entirely new
comparable facility.
Applies to units that reconstruct on or
after June 18, 2014.
Same requirements as for new units NSPS for sources with heat input greater than
2,000 MMBtu/h: Required to meet an emission limit of
1,800 lb CO2/MWh
NSPS for sources with a heat input of less than or
equal to 2,000 MMBtu/h: Required to meet an
emission limit of 2,000 lb CO2/MWh
BSER: The performance of the most efficient generating
technology for these types of units
Modified
Any physical or operational change to
an existing source that increases the
source’s maximum achievable hourly
rate of air pollutant emissions.
Applies to units that modify on or after
June 18, 2014.
The proposal associated with modified natural gas-
fired EGUs is being withdrawn by EPA for the time
being
Applies to those EGUs resulting in an increase of hourly
CO2 emission of more than 10% relative to the
emissions of the most recent 5 years from that unit
NSPS: These units will be required to meet a standard
consistent with its best historical annual performance
during the years from 2002 to the time of modification
BSER: Using a combination of equipment upgrades and
best operating practices
*Base load or non–base load is determined by a “sliding scale” approach that considers both design efficiency and sales; the dividing line between base
load and non–base load will change depending on a unit’s nameplate design efficiency.
How We Can Help
CH2M HILL is experienced with environmental quality/planning, air quality, and climate change compliance elements. Call one of our experts
today to discuss your specific situation. CH2M HILL can help you:
 Understand the rule requirements and specific impacts of the regulations/State plans on your current and future operations
 Identify areas of improvement, efficiency, and process changes that may be needed for you to comply (e.g., changes in generation
strategy/fleet)
 Understand what you should be advocating for with your State regulatory agency
 Develop long-term strategies to ensure compliance with regulatory requirements
 Establish required monitoring systems, record keeping, and reporting procedures
 Evaluate your current carbon footprint
Contact Us
Don Caniparoli
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Portland, OR 97201-4973
Phone: 503.235.5022
Don.Caniparoli@ch2m.com
Doug Huxley
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Englewood, CO 80112-5946
Phone: 720.286.5503
Doug.Huxley@ch2m.com
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