In accordance with President Obama’s Climate Action Plan, the U.S. Environmental Protection Agency (EPA) has re-proposed New Source Performance Standards for carbon dioxide (CO2) for new electric generating units (EGUs), while simultaneously withdrawing the standards it previously proposed in April 2012. If adopted as proposed, the standards would impose emissions limits of 1,100 pounds of CO2 per megawatt-hour (lbs/MWh) on new fossil fuel-fired boilers and integrated gasification combined cycle (IGCC) units, and 1,000 or 1,100 lbs/MWh (depending on size) on new natural gas-fired combustion turbines.
The proposed 1,100 lbs/MWh standard for new fossil-fuel fired boilers and IGCC units is based on partial implementation of carbon capture and storage. Compliance would be determined on a 12-operating-month rolling basis, though sources would have the option to alternatively meet a more stringent standard of 1,000-1,050 lbs/MWh on an 84-operating-month rolling basis. The proposed 1,000 and 1,100 lbs/MWh standards for new natural gas-fired combustion turbines are based on the use of combined cycle technology, with compliance determined on a 12-operating-month rolling basis. As proposed, the standards would apply to facilities that supply more than one-third of their potential electric output and more than 219,000 MWh net electric output to the grid per year. While most simple cycle combustion turbines do not exceed this applicability threshold, any that do would be subject to the proposed standards. EPA’s previous proposal explicitly excluded simple cycle combustion turbines regardless of usage.
A public hearing on the proposal will be held on February 6, 2014, and comments are due by March 10, 2014. EPA is accepting comment on all aspects of the proposal, and has specifically solicited comment on the appropriateness of each of the proposed emissions limits and the proposal’s application to simple cycle combustion turbines. While the proposal only addresses new EGUs, standards for existing and reconstructed/modified EGUs are expected to each be proposed by June 1, 2014 and finalized within a year thereafter. For additional information, contact Andrew Holway.