WASHINGTON, D.C. – The U.S. Environmental Protection Agency’s (EPA) proposal to amend the 2015 New Source Performance Standards (NSPS) for new coal-fired power plants is an important return to a sound and lawful standard that clears the way for the utilization of advanced technologies that reduce emissions while maintaining the diversity of the U.S. electric grid, the National Mining Association (NMA) said today in a public hearing on the proposed rule.
Katie Sweeney, NMA Senior Vice President, Legal Affairs, and General Counsel testified the 2015 rule imposed a “de facto moratorium on construction of new coal-fired power plants. The proposed revisions are necessary to allow construction of new, highly efficient coal units, particularly if regulations and fuel markets change and eliminate the current barriers on the construction of new, lower emitting coal-fired units.”
The 2015 NSPS aimed to make it all but impossible to build a new coal plant in the United States. The standard established partial carbon capture and storage (CCS) along with supercritical pulverized coal as the best system of emission reduction (BSER). At the time of the rule-making, no end-to-end CCS technologies had been demonstrated at scale for coal-fired baseload electricity generation. This technology was unproven and its cost exorbitant and unreasonable. CCS should have been disqualified as BSER for baseload power plants. Its inclusion for coal-based electricity generating units was arbitrary and unreasoned.
At the time of the 2015 rulemaking, NMA argued that EPA should adopt a sound and balanced standard aligned with emission performance of new, highly efficient supercritical and integrated gasification combined cycle technologies. These technologies were proven, commercially offered and capable of achieving real and substantial emissions reductions 20 percent lower than the average emissions rates of subcritical plants that dominate the current coal fleet.
The Value of Coal
Increased deployment of advanced coal plants in the U.S. will be essential to preserve the dispatchable fuel diversity that has long been a strength of the U.S. electricity system. Over-reliance on natural gas, dependent on just-in-time fuel delivery, poses a threat to reliability and affordability. Through diversification, price increases or supply disruptions in any one fuel can be offset by another. An IHS Markit study from 2017 found that eroding diversity in the U.S. power grid will result in greater price fluctuations, higher power bills and compromise the reliability of electricity supply.
A January 2019 study conducted by Wood Mackenzie found that Japan, Western Europe and China are currently leading the world in the use of HELE technologies that reduce emissions, highlighting the significant opportunity for deployment in the U.S. Improving the average efficiency rate of coal-fired power plants from 33 to 40 percent by using these affordable, commercially-proven technologies could cut U.S. coal-plant emissions by up to 21 percent. While the U.S. currently trails these and other countries in using the most advanced coal technologies, EPA’s efforts to amend the NSPS standards are a key step in encouraging innovation in the U.S.
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