110 likes | 235 Views
EPA Rules Scenario Development. Joe Chaisson Clean Air Task Force December 7, 2010 www.catf.us. Assessing upcoming EPA rule impacts. CATF is assessing potential impacts from the upcoming group of EPA rules
E N D
EPA Rules Scenario Development Joe Chaisson Clean Air Task Force December 7, 2010 www.catf.us
Assessing upcoming EPA rule impacts • CATF is assessing potential impacts from the upcoming group of EPA rules • We are using several analytic tools in our assessment work including a unit dispatch model, EPA’s version of the IPM model and other methods • Central to this process is developing plausible scenarios bounding final rule outcomes • This presentation will review key scenario factors for each rule
Key EPA rules • Clean Air Transport Rule (CATR) • Power plant hazardous air pollutants (MACT) • Clean Water Act § 316(b) cooling water intake structures • NSPS? • Coal ash? • Other?? Slide 2
Process – develop scenarios to model • Develop parameters for each key EPA rule that influence the boundaries (mild vs. aggressive) of plausible final rule outcomes • What questions/issues are important to defining rule outcomes? • Define other key factors – • Natural gas prices • Compliance technology costs • Model the plausible final rule outcomes to assess potential results, for example • Unit retirements • Emissions reductions • Costs, electricity rate impacts, etc.
CATR • Relatively straightforward scenario options • EPA’s proposed rule • CATF’ proposed alternative (contained in rule comments by CATF and five other environmental groups) – • Reduces SO2 emissions by 29% and NOx emissions 16% by 2015 • Compliance technology costs may not be a significant factor as EPA’s proposed CATRprimarily locks in existing commitments made to comply with the final CAIR rule • EPA’s proposal requires 14 GW of additional FGDs • CATF’s proposal increases the need for additional FGD’s to 30 GW Slide 4
HAPS/MACT • Little EPA legal flexibility • Clear statutory and case law requirements bound setting emissions rates (“floors”) • “hard” compliance deadlines, etc. • Key scenario factors: • MACT “floors” • As proposed for industrial coal boilers? • Alternative floors based on review of complete and quality controlled ICR data (when available)? • Availability/applicability of dry sorbent injection? • Wet flue gas desulfurization (FGD) costs • Reflect recent “systems” installations costs?; or • 30-40% higher in anticipation of substantial, near-term market demand?
CWA § 316(b) • EPA has broad flexibility in setting rule provisions • Key scenario questions: • Availability of reliable and complete information on existing power plant cooling systems and cooling water use? • Design withdrawal threshold for rule applicability? • Design withdrawal threshold for meeting a cooling water performance standard? • 50 MGD? • Higher design withdrawal flow?
CWA § 316(b) – continued • Criteria for alternative compliance methods of meeting a performance standard? • Alternative compliance path requirements – • Variable speed pumps plus operating practices? • Screens, etc? • Compliance technology costs – • NERC cooling tower cost assumptions? • Upcoming EPRI study? • Variance/exemption provisions?
CWA § 316(b) - summary • Developing plausible “bounding” final § 316(b) rule outcome scenarios before EPA issues a proposed rule may not be practical given EPA’s flexibility • EPA’s § 316(b) rule flexibility suggests that provisions to address any potential reliability issues could probably be included in a final rule.
GHG NSPS • Given the NSPS process and EPA’s considerable flexibility in setting both new and existing source GHG NSPS standards, it will be challenging to develop plausible final rule boundaries
Summary • Rule impacts can probably best be understood today by exploring the plausible boundaries of potential outcomes (where this is practical), rather than simply analyzing “worst case” outcomes • Key analysis factors include – • Plausible final rule requirements • Compliance technology costs • Future natural gas prices • Given EPA’s broad rulemaking flexibility under § 316b and GHG NSPS, “plausible boundary” scenarios are difficult to develop before EPA issues proposed rules