The state of Georgia, which has already been shutting coal-fired capacity lately in favor of cleaner energy sources, sees a number of issues with the U.S. Environmental Protection Agency’s proposed Clean Power Plan, including the fact is doesn’t credit the state for in-construction nuclear capacity at the Vogtle power plant.
Mary Salmon Walker, Assistant Director/Chief Operating Officer for the Georgia Environmental Protection Division (GEPD), testified March 11 at a Federal Energy Regulatory Commission technical conference on the Clean Power Plant and its potential impacts on grid reliability in the eastern U.S.
“Georgia has taken significant early action to reduce CO2 emissions from the electricity generation sector,” Walker noted. “In Georgia, 3,332 MW of coal-fired generation has either retired or been announced for retirement since 2010. In addition, almost 700 MW of coal-fired generation will be converted to natural gas by 2016. Georgia’s utilities have invested in air pollution controls for the remaining coal units to comply with Georgia’s Multipollutant Rule, the federal Mercury Air Toxics Standards (MATS), and Cross State Air Pollution Rule (CSAPR). The accompanying reductions in sulfur dioxide, oxides of nitrogen, and mercury have resulted in significant improvements in air quality for ozone, fine particulate matter, and regional haze.
“Utilities have also invested in heat rate improvement projects at the remaining coal units to optimize their efficiency for their remaining useful life. CO2 mass emissions in Georgia declined 33% between 2005 and 2012 as a result of the retirements, conversions, and investments in Georgia’s energy sector. Unfortunately the Clean Power Plan as proposed fails to give Georgia credit for the early action taken to reduce CO2 emissions in Georgia.”
Walker said the division’s key concerns and recommendations for improving the Clean Power Plan include:
- EPA’s handling of under-construction nuclear generation capacity (Vogtle Units 3 and 4) in the proposed Clean Power Plan is a critical issue to Georgia. Vogtle Units 3 and 4 are a long-term investment to satisfy Georgia’s future energy needs and to reduce the need for future carbon-emitting generation. EPA assumes that the project will be completed prior to the 2020 interim compliance deadline under the Clean Power Plan and gives Georgia no credit for the CO2 emission reductions that will occur as a result of this project.
- EPA included under-construction nuclear generating capacity in the CO2 reduction goals of only three states: Georgia, South Carolina and Tennessee. This imposes an unfair and unequal burden on the citizens of these three states.
- Building Block 1 requires heat rate improvements of 6% at coal-fired power units. This across-the-board heat rate improvement goal is unlikely to be attainable in Georgia.
- EPA based the southeastern states’ renewable energy (Building Block 3) target of 10% on North Carolina’s Renewable Energy and Energy Efficiency Portfolio Standard (REPS). The Georgia division contends that EPA misinterpreted North Carolina’s REPS when setting the renewable energy target for Georgia and other southeastern states. Georgia’s renewable energy target should be no more than 7.5% by 2030.
- The proposed rule penalizes states that took early action to reduce greenhouse gas emissions. EPA uses a baseline year of 2012 in the proposal. Significant CO2 emission reductions occurred prior to 2012 in Georgia. The baseline year should be set somewhere in the 2005-2007 timeframe to give Georgia and many other states credit for early action. This baseline period is also more appropriate because it pre-dates the 2008 economic recession and would be more reflective of normal energy demand.
- EPA set the CO2 reduction requirement of each state as rate-based goal. For example, Georgia’s goal is 834 lbs CO2/MWh. EPA proposes methodology to translate the rate-based goal to a mass-based goal. EPA’s proposed methodology is flawed. EPA should correct the methodology for the rate-based to mass-based goal translation so that both approaches result in a similar level of actual CO2 mass emission reductions from the baseline.
- The division does not support the alternative method for calculating states’ goals suggested in the Notice of Data Availability issued in October 2014. That calculation methodology only serves to make the ambitious goals of the original proposal even more stringent and much more difficult to achieve. Electricity generated from fossil fuels in Georgia would be reduced 83% from 2012 levels.
- EPA’s proposal establishes an interim CO2 emission reduction requirement for the 2020- 2029 time period. EPA should replace the 2020-2029 interim emission rate requirement with a non-enforceable state developed glide path. If the interim goal is retained, the start date of the interim period should be pushed back from 2020 to five years after EPA’s approval of the state plan.
“GEPD encourages EPA to structure the final rule in a way that rewards states that have taken early action to reduce CO2 emissions, and encourages innovative approaches towards the goal of reducing CO2 emissions from EGUs,” Walker wrote. “EPA estimates the proposed rule will achieve annual CO2 emission reductions of 26%-30% below 2005 levels. This is approximately 600-700 million metric tons of CO2 reductions per year. Given the ‘big picture’ of massive CO2 emission reductions over a 15-year period, GEPD urges EPA to focus on the goal of achieving those reductions, and encouraging and enabling the use of all available tools that states can use to meet their targets. Overly prescriptive administrative and regulatory processes can create obstacles and disincentives to deploy certain approaches and also burden states and the affected EGUs with unnecessary monitoring, recordkeeping and reporting requirements.”