Comments on EPA’s Proposed Carbon Pollution Standard for New Power Plants

Resources for the Future Discussion Paper No. 12-31

17 Pages Posted: 19 Jul 2012

See all articles by Dallas Burtraw

Dallas Burtraw

Resources for the Future

Arthur G. Fraas

Resources for the Future

Karen L. Palmer

Resources for the Future

Nathan D. Richardson

University of South Carolina - Law Library; Resources for the Future

Date Written: July 13, 2012

Abstract

The U.S. Environmental Protection Agency’s (EPA) proposed greenhouse gas (GHG) performance standards for power plants are an important step forward in regulating GHGs in terms of both their substantive impact and legal precedent. Nevertheless, we have some concerns with the proposal, which we discuss in the following comments submitted to the agency. The majority of our comments are directed to ways that EPA can increase certainty for the industry — reducing costs and, possibly, improving environmental outcomes. We highlight two specific areas of concern. First, the current proposal contributes to the significant uncertainty facing existing sources. Second, EPA’s proposed averaging option for new facilities that will install carbon capture-and-storage (CCS) technology in the future, although intended to create a flexible pathway, unfortunately creates some new regulatory uncertainty. We also comment on EPA’s decision to combine most coal and gas generators into a single source category. We believe this decision is legally valid and practically important, and that EPA should resist pressure to reconsider.

Keywords: greenhouse gas emissions, performance standards, new source review, carbon capture and storage technology, U.S. Environmental Protection Agency, uncertainty

Suggested Citation

Burtraw, Dallas and Fraas, Arthur G. and Palmer, Karen and Richardson, Nathan D., Comments on EPA’s Proposed Carbon Pollution Standard for New Power Plants (July 13, 2012). Resources for the Future Discussion Paper No. 12-31. Available at SSRN: https://ssrn.com/abstract=2113234 or http://dx.doi.org/10.2139/ssrn.2113234

Dallas Burtraw (Contact Author)

Resources for the Future ( email )

1616 P Street, NW
Washington, DC 20036
United States
202-328-5087 (Phone)

Arthur G. Fraas

Resources for the Future ( email )

1616 P ST, NW
Washington, DC 20036
United States

Karen Palmer

Resources for the Future ( email )

1616 P Street, NW
Washington, DC 20036
United States

Nathan D. Richardson

University of South Carolina - Law Library ( email )

1525 Senate Street
Columbia, SC 29208
United States

Resources for the Future ( email )

1616 P Street, NW
Washington, DC 20036
United States

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