Geoscience Reference
In-Depth Information
a future state of the world that deviates from the core parameter estimates
that underlie the AEO reference case. Even under alternative scenarios
where assumptions might improve the relative economic value of
building new coal-fired power plants, the AEO 2011 does not project new
coal capacity being built through 2025, beyond the coal capacity already
planned outside of the modeling. Relevant scenarios include higher
economic growth forecast, lower cost of coal supply, lower capital costs
of fossil fuel-fired energy technologies, and less optimistic natural gas
supply.
26
Should EPA Have Proposed Separate Standards for Coal- and
Gas-Fired Units?
New Source Performance Standards promulgated previously for
conventional pollutants (such as sulfur dioxide) emitted by electric generating
units have generally distinguished coal- and gas-fired units. As EPA notes in
the preamble to the proposed standard, in setting standards for conventional
pollutants or air toxics, it was not appropriate to combine coal-fired and gas-
fired units in a single category, because ―although coal-fired EGUs have an
array of control options for criteria and air toxic air pollutants to choose from,
those controls generally do not reduce their ... emissions to the level of
conventional emissions from natural gas-fired EGUs.‖
27
Critics of the GHG proposal have taken EPA's statement a step further,
stating frequently that combining coal-fired and gas-fired units in a single
category is ―unprecedented.‖
28
This is not actually the case: in 1998, EPA
promulgated NSPS for emissions of nitrogen oxides (NOx) that imposed a
single emission standard on all fossil-fueled EGUs.
29
In
Lignite Energy
Council v. U. S. EPA
,
30
the D.C. Circuit Court of Appeals squarely addressed
the argument that a single fuel-neutral standard was impermissible and
rejected it.
Is the Standard Barred by Statutory Language?
Critics of the proposed standard maintain that in setting the standard at
1,000 lbs CO
2
/MWh, EPA would effectively require coal-fired power plants to
add CCS to any new unit. They maintain that such a requirement violates
Section 111(b)(5) of the Clean Air Act, which states that unless he determines
