Geoscience Reference
In-Depth Information
The RIA argued the case for the rule as a backstop, in case its projections
of market conditions are inaccurate:
This NSPS provides legal assurance that any new coal-fired plants
must limit CO2 emissions. Rather than relying solely on changeable
energy market conditions to provide low emissions from new power
plants in the future, this rule prevents the possible construction of
uncontrolled, high-emitting new sources that might continue to emit at
high levels for decades, contributing to accumulation of CO
2
in the
atmosphere.... In addition, EPA intends this rule to send a clear signal
about the future of CCS technology that, in conjunction with other
policies such as Department of Energy (DOE) financial assistance, the
agency estimates will support development and demonstration of CCS
technology from coal-fired plants at commercial scale....
18
Thus, the agency maintained that the proposed rule would assist in the
deployment of CCS technology, noting that regulatory uncertainty may have
hindered its deployment. The proposed rule's preamble noted, for example,
American Electric Power (AEP)'s recent deferral of a large-scale
CCS retrofit demonstration project on one of its coal-fired power plants
because the State's utility regulators would not approve CCS without a
regulatory requirement to reduce CO2. The standard established in this
proposal would help create the regulatory certainty that CCS is the path
forward for new coal-fired generation.
19
In addition, the promulgation of New Source Performance Standards, even
if the standards have little or no effect on those new sources, serves as the
precondition for standards affecting existing units. The latter are described in
Section 111(d) of the Clean Air Act as ―standards of performance for any
existing source ... to which a standard of performance under this section would
apply if such existing source were a new source.‖
K
EY
Q
UESTIONS
R
EGARDING THE
2012
P
ROPOSED
R
ULE
Many in the electric power and coal industries view the standard proposed
in 2012, if finalized, as effectively prohibiting the construction of new coal-
