States should take lead on carbon standards for existing power plants, APPA tells EPA
Originally published January 6, 2014
Since Congress has not addressed greenhouse gas emissions from power plants, state governments should take the lead on developing and implementing carbon emission standards for existing fossil fuel-fired power plants, APPA said in a Dec. 20 letter to the Environmental Protection Agency. "States are in the best position to determine how to most effectively reduce CO2 emissions from power plants while protecting the interests of electric consumers," APPA said in response to EPA’s request for comments in advance of an expected proposal to regulate existing power plant emissions under Section 111(d) of the Clean Air Act.
State regulators "have a greater ability to understand the unique issues facing utilities operating in their boundaries than EPA does," APPA said.
APPA is strongly concerned that a New Source Performance Standard (NSPS) for existing plants could harm residential, commercial, and industrial electric customers by significantly increasing electricity costs, as well as impact electric reliability in certain parts of the country. The likelihood of these negative impacts will increase substantially if the standard is based on non-commercial or undemonstrated technologies, such as carbon capture and storage, or if the standard is implemented too quickly, APPA said. For those and other reasons, states should have primacy in developing and implementing an NSPS for existing plants, the association said.
States should have maximum flexibility and be encouraged to use their own systems; EPA should not make approval of state implementation plans contingent on a "cookie cutter" approach, APPA said.
EPA should regulate CO2 emissions at the point of generation and any standards should be achievable by individual sources, not systems, APPA said. Each state should have the freedom to decide whether to participate in bilateral or multistate coordination or trading with other states. Although EPA has asserted in its proposed rule for new power plants that carbon capture and sequestration is adequately demonstrated, "this is not true," APPA said. APPA appreciates recent public comments by EPA Administrator Gina McCarthy that carbon capture and sequestration is not appropriate for existing power plants.
When setting carbon standards and related implementation deadlines, EPA and state regulatory agencies "should recognize the key characteristics of public power utilities, such as consumer ownership, not-for-profit operation, relatively small size, limited generation ownership, and other factors," APPA said.
EPA and state regulators should give electric utilities credit for their CO2 reductions that resulted from increased use of renewable energy resources, fuel switching to lower or non-emitting resources, and power plant closures, APPA said. APPA estimates that collectively, public power utilities have reduced their emissions by more than 39 million metric tons of CO2 since 2005.
APPA plans to file additional comments once EPA proposes a standard for existing power plants.
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