Full Title: Greenhouse Gas Emission Reductions From Existing Power Plants: Options to Ensure Electric System Reliability
Author(s): Susan F. Tierney, Ph.D.
Publisher(s): Analysis Group, Inc.
Publication Date: 5/2014

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In June 2014, the U.S. Environmental Protection Agency (“EPA”) is expected to propose guidance to the states for reducing greenhouse gas (“GHG”) emissions from existing fossil-fuel power plants. Final guidance is expected a year later, with requirements that each state develop and submit a state implementation plan (“SIP”) for how the state would prefer to achieve such emissions reductions at the power plants in its state. While the Clean Air Act’s Section 111 identifies many criteria for setting the emissions standard and for states’ development of SIPs to achieve it, an important additional objective not mentioned in the Act but still important for the nation is assuring that such plans will not jeopardize electric system reliability.

This paper addresses whether EPA’s actions to regulate GHG emissions from existing power plants will give rise to electric system reliability problems, and explains why it will not. Industry participants have often raised concerns about potential electric system reliability impacts from major new EPA regulations affecting power plants. This was a major issue in 2010 to 2012, for example, in many parties’ comments on EPA’s proposals to control mercury and air toxic emissions (the “MATS” rule). Reliability concerns have already been raised in relation to EPA’s upcoming regulation of GHG emissions from existing power plants.