The EPA has announced a proposed rule called the Carbon Pollution Standard. While sounding innocuous, the new regulation would effectively ban construction of new coal-fired power plants. Requiring emissions to be so low that “no existing coal power plants come close; even the most efficient,” new power generation is likely to come from natural gas power plants.
Back in March of 2011, the EPA said they wouldn’t be forcing anyone to switch from coal to natural gas, but with this new rule, they have accomplished their long term goal of making coal extinct. In 2008, a candid candidate Obama said that “if somebody wants to build a coal plant, they can, it’s just that it will bankrupt them…” Since coming into office, President Obama and his radical EPA have been trying to eliminate out coal fired plants with regulations like the Utility-MACT.
The Carbon Pollution Standard may be among the weirdest regulations ever proposed. This dubious distinction is no doubt related to the fact that the EPA is attempting to regulate GHGs through a statute neither designed nor intended for that purpose. The proposal is bizarre in at least five ways.
(1) The EPA classifies natural gas combined cycle — a type of power plant — as a “control option” or “system of emission reduction” for coal-fired power plants.
The EPA picked 1,000 lbs CO2/MWh as the “standard of performance” for new fossil-fuel EGUs because that is the “degree of emission limitation achievable through natural gas combined cycle generation.”20 But consider how the CAA defines “standard of performance” *CAA § 111(a)(1)]:
The term “standard of performance” means a standard for emissions of air pollutants which reflects the degree of emission limitation achievable through the application of the best system of emission reduction which (taking into account the cost of achieving such reduction and any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated.21
Performance standards are supposed to reflect the best “system of emission reduction.” But natural gas combined cycle is not a system of emission reduction. It is a type of power plant. EPA is not proposing that new coal power plants install emission reduction systems that have been “adequately demonstrated.” Rather, EPA is proposing that new coal power plants be new natural gas plants.
The Carbon Pollution Standard is another market distorting regulation that will inevitably increase natural gas consumption, causing the price of the fuel to rise. While America is endowed with enormous natural gas reserves, we have even more coal. It would be wise to develop and utilize both resources, if only the EPA would let us.