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The fight over the EPA's Clean Power Plan (CPP), is on going, and with the recent Supreme Court ruling, putting a temporary freeze on the plan [1], questions about it eventual implementation are growing. This comes just weeks after the DC Circuit Court of Appeals denied a stay on the CPP, making the Supreme Court ruling even more surprising. Opponents of the plan will present their arguments to the Supreme Court on June 2nd. The CPP is an Executive Order so if the next Administration is Republican it most  likely will be killed. However, if it is killed, the EPA is still faced with having to comply with the Supreme Court ruling, in Massachusetts v. EPA [3], that stated Greenhouse Gas (GHG) air pollutants could be covered by the Clean Air Act, and in short requires the EPA to make a decision on this matter. Subsequent Supreme Court rulings have supported the EPA's authority to regulate GHG emissions from direct (stationary) emitters. Since the CPP is reasonable, with many States and Power Companies well on their way to complying, it is hard to see the Supreme Court being the cause of its death. But who knows? If the next administration attempts to kill it, or just ignore it, there is a strong legal history to bring lawsuits and force some type of action. Furthermore, with the passage of the Paris Agreement [4], at COP21, there is now an  international agreement on GHG reductions, so the EPA may have even more power to regulate GHG [5], and  if they do not use that power, we should expect international lawsuits. Even if the CPP survives there still are question about how enthusiastically States and Power Companies will embracing it. That in turn will determine if it becomes the catalyst of change that is required to lower GHG emissions even further to truly deal the Climate Change.

The CPP originally was composed of four building blocks, or best system of emission reduction (BSER) [6]:

  1. Make fossil fuel power plants more efficient, for example improve heat rate (HR).
  2. Use low-emitting power sources more, for example natural gas combined cycle (NGCC).
  3. Use more zero- and low-emitting power sources, for example Solar Photo-voltaic (PV).
  4. Use electricity more efficiently, for example LED light bulbs

In the latest edition, of the CPP, building block four was dropped, with much speculation that it was done for legal reasons [7]. Opponents of the plan have been arguing that the EPA only has legal authority to regulate generating units, so the idea that encouraging more efficient use of energy in people's homes and work, is a legitimate way of States decreasing GHG emissions, seems a step to far. Ironically, this is by far the best way of reducing emissions, and shows the legal quagmire we are in. North Carolina is a great example of this quagmire. 

The CPP was thoughtfully designed to give State Regulators and Power Utilities the flexibility to design a plan that deals with specific issues in their State. Unfortunately, this very rational approach is being used against the plan by claiming the EPA is over stepping its authority by trying to regulate everything. This is the approach Governor McCrory, of North Carolina, is taking, along with his head of Department of Environmental Quality, Donald R. van der Vaart, who denied the existence of climate change during a Congressional hearing on the CPP. The State, which is required to cut emissions by 36 percent, has had success in developing solar energy, and is currently ranked 7th in the nation in the percent of its energy produced from solar [8]. It is 25th in the percent of energy produced from coal, and has no economically viable coal, or other fossil fuel, resources of its own. There is no doubt that the State would benefit, economically, by reducing its reliance on fossil fuel. Its only politics that stands in the way.

NC Power Plants GHG Emissions

Electricity, in North Carolina, is produced primarily from coal (33%), nuclear (32%) and natural gas (28%). However, coal power plants produce over 75 % of its CO2 emission, from electricity generation, with the bulk of that coming from three big plants [fig. 1]; Roxboro (26%), Belews Creek (24%) and Marshall (18%). The CPP provides two ways to calculate GHG emission performance standards, a rate-based method and a mass-based method. In the rate-base approach the EPA has set emission rates, of pounds of CO2 per megawatt hour (CO2lbs/MWh), for coal (1,305 lbs/MWh) and gas (771 lbs/MWh) generating units, that have to be achieved by 2030. The mass-based approach is similar except the EPA has allocated the total amounts of CO2 (CO2lbs) a unit is permitted to release annually. The EPA provides interim rates that need to be achieved by the 2022-2024, 2025-2027 and 2038-2029 time periods. Figure 2, shows the percent decrease in emissions, relative to 2012, the three big plants in North Carolina have to achieve for the interim periods and and final goal. By 2022-2024 the plants have to achieve a 17 percent decrease, on average, while by 2030 they need to have reduced there CO2 emission rate by 35 percent, on average.

NC Big Three Power Plants Rate Reduction

This is a significant goal, but the direction of evolution taking place in the Power Industry, and architect of the CPP, will make it a very achievable goal. The most important thing to understand about this evolution is that it is leading to a far more decentralized power production and distribution system. A good analogy is what happened to the telephone network, with the development of the internet and mobile phone network. It has become much more distributed, and multi-layered. Power production, in the future, will be far more diverse, with the development of renewables, such as wind, solar and biofuels, and its generation will be more geographically distributed, and smaller in scale, especially in the case of solar which can be done at the point of demand. The development of micro-grids will aid this decentralization, by enabling local grids to operate more independently, at times of higher local energy production, but still send and receive electricity to the larger grid. This will make the grid more resilient, efficient and versatile.

In this new environment large centralized power production facilities will become dinosaurs, unless they become far more efficient. This is why the goals in the CPP for power plants make sense, not just from an environmental perspective, but also an economic one. The CPP actually provides Power Companies a good model on how to adapt to this new environment. In the case of old very large generating facilities the best approach may be to retire them or convert them. Spending excessive amounts of money on a facility that does not fit the new more distributed power production model, of the future, may not make sense. Converting older coal burning facilities to NGCC is becoming common place, however, this method makes most sense for small to mid-size facilities [9]. Another approach for improving the efficiency of facilities is combined heat and power (CHP), where the excess heat from the boiler is used in some other process, such as an anaerobic digester in waste treatment. But again this is a technology best applied to small and mid-size power plants. For large coal burning power plants the best approach may be a step-wise one, that improves the efficiency of the plant, while paying for itself over a relatively short period of time. 

Augmenting existing coal fired steam electric plants with solar thermal, is away Power Companies can reduce emissions from coal plants in a relatively short period of time (18 months) [10]. There are two approaches, the first is to use the steam, produced from solar, to help heat feedwater to the plant. Feedwater is usually heated by steam produced from burning coal [11], so replacing that process with solar thermal can reduce emissions, and improve efficiency of the plant by 3% to 7% [12]. The pay of period is 5 to 10 years. The second approach is for the steam, from solar, to be used directly in the steam turbine. This approach has been studied by the National Renewable Energy Lab (NREL), where they examined the potential of augmenting coal, and gas steam power plants, in the US, with solar thermal [13]. The Roxboro Steam Plant was one of the plants that passed their examination, with a 'fair' grade [14], warranting a more comprehensive examination.

By far the most cost effective way to reduce GHG emissions is through demand side efficiency [15]. The CPP enables states to include that approach in their plan, reducing the need to shutdown plants because they can make a legitimate argument that those plants would be used less. Renewable energy is also a very cost effective way of reducing GHG emissions [16], and coupled with the reduced cost of electric storage [17], it is revolutionizing the power industry. The CPP provides a method for Power Companies to invest in renewables, and then use that electricity as credits to offset GHG emissions. These approaches along with others, in the CPP, make its implementations very achievable and affordable. The opposition wants to focus on the electric generating unit, making such reductions much more difficult and expensive. However, even in the case of the generating unit, substantial improvements in efficiency can be made, especially if you augment it with renewables. 

As mentioned above, the power industry is changing, and not just because of environmental regulation. It is arguable that the main drivers to this change are technology and deregulation, the later is only occurring in parts of the US. North Carolina has not deregulated electric utilities, and since the merger of Duke Energy and Progress Energy it has become even more centralized. The most visible example of this, is that third party solar is still not permitted by the state [18], so even though the state is 7th in the nation in solar, most of it comes from utility scale solar in rural areas. Third party solar would increase commercial roof top, and parking lot solar, generating the electricity at the point of demand, and reducing the need for distribution and transmission. This decentralized approach coupled with localized storage of electricity, is far more resilient and efficient. The CPP can enable this approach to be implemented sooner, but if the CPP is killed, this transition will still take place.




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