DEP Submits White Paper To EPA On Regulating CO2 Emissions From Existing Power Plants

On Thursday the Department of Environmental Protection submitted a white paper containing comments to the U.S. Environmental Protection suggesting a new framework for regulating carbon dioxide emissions from existing coal-fired power plants under Section 111(d) of the federal Clean Air Act.

“Under Gov. Tom Corbett’s leadership, Pennsylvania is continuing to make great progress in its efforts to position the state as a world leader in the new energy economy while ensuring that we continue improving our air quality and protecting public health,” DEP Secretary Chris Abruzzo said. “A key part of this plan is maintaining the stable and diverse supply of electricity vital to our economy and national security.”

“Pennsylvania is committed to achieving the goals that would be established under a flexible CO2 program in a fashion that allows us to best serve the needs of our citizens,” Abruzzo said. “We believe the best way to achieve these goals is to implement a plan that focuses on state leadership, provides flexibility and takes advantage of a wide range of energy sources and technologies towards building a cleaner power sector.”

Specifically, DEP requested EPA to:

— If EPA develops emissions guidelines, it should be done under Section 111(d) of the Clean Air Act;

— Emissions guidelines should be developed in close consultation with the states;

— EPA should establish targets for reductions, rather than mandate pathways to achieve them;  

— States must be allowed to join with other states in multi-state or regional programs;

— EPA should recognize the different makeup of existing power generation fleets in each state;

— EPA should recognize the differences inherent in regulated versus competitive energy markets and the need to provide for electric grid reliability; and

— Changes to major New Source Review regulations should be considered to encourage efficiency improvements.

In his letter to EPA, DEP Secretary Chris Abruzzo said--

“Pennsylvania is making great progress in its efforts to position the state as a world leader in the new energy economy. A key part of this plan is maintaining the stable and diverse supply of electricity that is vital to our economy and national security.

“To that end, I am pleased to provide you with a copy of a new Pennsylvania white paper that presents an innovative and flexible framework for achieving lower carbon dioxide (CO2) emissions from existing fossil fuel-fired power plants.

“At the heart of this plan is the preservation of states’ authority and discretion in the development and implementation of flexible emission control programs. EPA should establish targets for reductions, rather than mandate pathways to achieve them. A flexible approach avoids picking “winners and losers” and empowers states to design the most cost-effective compliance options for their constituents.

“As stated in our white paper, Pennsylvania believes that a key to the success of any effort to reduce CO2 is optimizing and maximizing the benefits of energy efficiency projects. For that to occur, it is critical for EPA to endorse, adopt and implement our proposal to modify the New Source Review applicability test. If this change is made, a paradigm shift would be accomplished that would result in considerable investment in energy efficiency efforts not just in the fossil fuel-fired electric generating sector but throughout the entire U.S. economy.

“Companies paying to make energy efficiency improvements would benefit economically through lower operating costs, which results in lower prices for consumers while achieving lower CO2 emissions. This change would provide an incentive to companies to make investments that would result in emissions reductions, including CO2, from all emitting sources without the need of a regulation to force the reduction.

“Pennsylvania is committed to achieving the goals that would be established under a flexible CO2 program in a fashion that allows us to best serve the needs of our citizens. We look forward to hearing your feedback on our proposal and pledge our commitment to work in partnership with your staff as you craft a plan to meet President Obama’s directive to build on state leadership, provide flexibility and take advantage of a wide range of energy sources and technologies towards building a cleaner power sector.”

Click Here for a copy of the DEP White Paper.  Click Here for a copy of DEP’s letter.

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