By Corina Rivera
Linares, Senior Analyst, TransmissionHub
As the Dec. 1 deadline for the comment period on the U.S. Environmental Protection Agency’s proposed Clean Power Plan approaches, the agency continues to gather information on the proposal, Sarah Dunham, director, Office of Atmospheric Programs with the EPA said on Oct. 14.
The EPA released the plan last June and is currently going through a process to move forward with finalizing it, before turning it over to the states to implement it, Dunham said during her presentation at the Maryland Clean Energy Center’s 2014 Maryland Clean Energy Summit held in Hyattsville, Md.
President Barack Obama, in the summer of 2013, announced his climate action plan, one component of which was a directive to the EPA to use its existing Clean Air Act authority to move forward with setting up guidelines to the states that would require greenhouse gas emission reductions from power plants, Dunham noted.
The EPA used a specific provision of the Act that “envisioned a partnership between the federal government and state government,” in which EPA identifies the target that states have to meet and the states design the programs, “telling power plants exactly what they need to do in order to achieve those reductions,” she said.
When fully implemented, the plan aims to achieve an about 30 percent reduction of carbon dioxide emissions from existing power plants by 2030, according to TransmissionHub.
“[T]his wasn’t about shutting down power plants and turning off the lights,” she said. “In fact, we had to have a … proposal that ensured that there would be a maintained, reliable source of energy with diverse fuels across the country that recognized the unique mixes of fuel that are in different pockets of this country,” Dunham said. “[E]very state is different – we had to recognize all of that in putting forward guidelines so that they would be achievable, but still get significant reductions, which we think are necessary.”
At the same time, she said, the plan is not just about reducing greenhouse gas emissions as the actions taken by power plant owners to reduce the plants’ emissions also result in reductions of other pollutants that can have human health benefits.
“[T]his really intersects directly with clean energy and energy investments and the energy economy,” she said.
Creating a framework that incentivizes investments in clean energy, in renewable energy and in energy efficiency is “the way to achieve these significant reductions cost effectively,” Dunham said.
Noting that the EPA had about a year of extensive outreach before putting forth its proposal, she said the agency wants to continue the dialogue, hold discussions in the agency and hearings around the country, “so that we can continue to hear about what folks think about the proposal and make sure that we’re folding in the great ideas that we know are out there.”
In developing its proposal, the EPA calculated a goal, essentially an emission rate target that was unique to every state, Dunham said. The EPA used a formula for calculating that goal, based on baseline information from all of the states, using 2012 data, or the most recent complete set of data at the time.
“[W]e did a couple of things – we made the existing power plants more efficient, that was folded into the equation, [and] we increased the use of high-efficiency natural gas combined-cycle units,” she said. “We increased the use of zero- or low-emitting generation, so increased use of renewable generation, increased use of nuclear generation, and … the fourth building block, as we call them … was basically increasing demand side energy efficiency.”
The agency recognizes that every state and utility across the country is in different place with respect to each of those building blocks, so EPA tried to build off of where states and utilities are today and apply a reasonable rate of progress to reach the eventual targets, she said.
While some states, like Maryland, have already been leaders in emissions reductions and energy efficiency initiatives, others have not yet developed infrastructure and made investments in such matters like energy efficiency and renewable energy. Dunham added that there are opportunities for every state to move forward and reduce their emissions.
“[B]ecause this is very much a partnership, we’re not saying to states, ‘You have to do exactly the way we calculated the goal,’” she said. “What we said is, we know that there’s any number of ways to reduce emissions from the power generation sector, beyond just what we assumed in calculating the state goals, and we don’t want to act as a barrier to those other investments, to moving the markets forward [and] to having other ideas that can be generated for reducing emissions from the power sector.”
The EPA’s target should just be seen as a target, but the states should come in with their plans and figure out ways to get there using anything at their disposal, Dunham said.
Things that the EPA considered included options to reduce emissions through changes at existing fossil fuel plants, with the agency assuming a particular percentage increase in efficiency, she said. There are a number of best practices that the agency is aware of, that a lot of power plants are already doing, but there are others that have not yet made such investments in things like co-firing for lower carbon fuels.
Such resources as biomass, as well as carbon capture and increased use of existing utility-scale renewables can play roles, she said.
On demand side energy efficiency measures, she said that the EPA looked at what leadership states were doing on that front, but did not prescribe a specific kind of energy efficiency program.
The agency hopes that efforts done in such leadership states as Maryland can be used as models for other states around the country. Those efforts range from utility-run programs to building codes, smart grid-enabled strategies, transmission improvements to reduce line losses and investments through energy service companies, she added.
The EPA also recognizes that states’ regulatory mechanisms vary and that some states, like Maryland, participate in such programs as the Regional Greenhouse Gas Initiative and have developed multi-state arrangements. “[W]e’ve tried to provide this framework that recognizes where some of the states that have already been investing and working in these areas are,” she said.
EPA proposed a timeframe for achieving the reductions over 2020 to 2030, Dunham said. One of the things that the EPA has heard as it participates in meetings involves concerns about timing, and that 2020, which is the first target date for EPA’s guidelines, is not very far away, she said.
“[T]o some extent if you don’t get enough time to invest in different types of programs, that, folks said, leads to certain directions,” she said. “It’s easier to say that you’re going to do something at the plant, than it is to pass legislation that invests in energy efficiency and ramps up over time, and so, that’s some of the things that we’re taking feedback on and we love to hear the perspectives of folks who are working on these programs.”