Key Concerns About New Source Performance Standards

Posted by Darian Ghorbi at 9:42 am, February 06, 2014

Today, the U.S. EPA held a public hearing on their proposed New Source Performance Standards (NSPS) for new coal- and gas-fueled power plants.  This proposed rule sets unachievable limits based on yet-unproven carbon capture and storage, or CCS, technology for new coal power plants.   Requiring CCS makes new coal plants prohibitively expensive to build, regardless of how clean and efficient they are. Eliminating the option to build new coal plants discourages fuel diversity, which is important to protecting electricity consumers.

I outlined five key concerns of ACCCE to EPA today:

  • First, NSPS is inconsistent with EPA’s statutory authority which requires standards to be set based on technology that is “adequately demonstrated.”
  • Second, CCS is neither viable nor cost effective based on the criteria used by EPA.  In fact, significant financial, technological and regulatory barriers to CCS exist, and costs are exorbitant right now.
  • Third, EPA’s standard will stall CCS development in the United States because it will prohibit new coal power plants from being built.  New plants are essential to continued demonstration of CCS technology.
  • Fourth, EPA inappropriately relied on federally subsidized demonstration projects to set this standard.  None of these projects are yet operational in the United States.
  • Fifth, EPA failed to consider the significant challenges associated with long-term storage of CO2 which is hampered by geographical and geological constraints and are subject to regulatory uncertainty.

CCS is an important greenhouse gas mitigation technology.  Many stationary sources of CO2 emissions may consider CCS a primary option to significantly reduce emissions.  Although important, CCS is not yet available for new coal power plants in the United States, and can cost upwards of $1 billion extra for a typically-sized power plant.  ACCCE urges EPA to set an NSPS based on new, highly efficient coal power plants without CCS.  This will allow CCS to continue to develop and allow coal to continue to produce affordable and reliable electricity.


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