The CP’s performance standard substantially reduces carbon emissions and boosts a mix of investments in energy efficiency and renewables
Lashof, 12 – director of the climate and clean air program at the Natural Resources Defense Council (Daniel, “Closing the Power Plant Carbon Pollution Loophole: Smart Ways the Clean Air Act Can Clean Up America’s Biggest Climate Polluters” December, http://www.nrdc.org/air/pollution-standards/files/pollution-standards-report.pdf)
NRDC has conducted an analysis of how CO2 pollution standards for existing fossil fuel–fired power plants under Section 111(d) could affect the power sector, emissions levels, and electricity costs for consumers. The policy proposal set forth in this reportwill decrease levels of CO2 emissions and encourage the power sector’s transition to cleaner, lower-emitting generation with increased deployment of both supply- and demand-side energy efficiency. NRDC proposes that EPA set state-specific performance standards for existing power plants, using national average emission rate benchmarks and the state-specific generation mix in a baseline period to produce state average fossil fuel emission rate standards. Each of these standards—called an “emission guideline” under EPA’s Section 111(d) regulations—would serve as a template for acceptable state plans, a yardstick to evaluate alternative plans that states may propose, and an advance notice of the federal plan that EPA must issue if states do not submit approvable plans.¶ NRDC’s performance standard proposal begins with determining each state’s generation mix during a baseline period (we used the average for 2008 through 2010 in this analysis). Then a target fossil-fleet average emission rate for 2020 is calculated for each state, using the state’s baseline coal and oil/gas generation fractions and an emission rate benchmark of 1,500 lbs/MWh for coal-fired units and 1,000 lbs/MWh for oil- and gas-fired units on a net basis. States with more carbon-intensive fleets would have higher target emission rates but greater differentials between their starting and target emission rates. NRDC’s proposal is designed to give power plant owners freedom to choose how they would achieve the required emission reductions, giving credit for increases in energy efficiency and electricity generation using renewable sources and allowing emission-rate averaging among fossil fuel−fired power plants. States would also have the freedom to design their own approach, as long as it achieved equivalent emission reductions.¶ NRDC compared this performance standard with a Reference Case representing expected trends in the absence of such standards. NRDC also tested the sensitivity of the electric power grid’s response to the stringency of emission rate targets and energy efficiency penetration in two additional scenarios.¶ The analysis demonstrates that this recommended approach would reduce power plants’ carbon pollution in an efficient and affordable way. It would reduce CO2 emissions from the fossil generating fleet by 26 percent from 2005 levels by 2020, with annualized costs of approximately $4 billion in 2020 and benefits of $25 billion to $60 billion. The benefits come from saving lives and reducing the risks of catastrophic climate change. Reducing carbon pollution is valued at $26 to $59 per ton; reducing sulfur dioxide and oxides of nitrogen emissions beyond the levels that would be reached under other standards is valued by using an EPA-approved model of the health benefits on a regional basis. Thisrecommended proposal can deliver thehealth and environmental benefitsof reducing emissions from power plants without interfering withreliable and affordable electricity supplies. Establishing such CO2 emission standardsnow will boost investmentsin energy efficiency andwill givethe power industry the investment certaintyit needs to avoid billionsof dollars of stranded investmentin obsolete power plants.
The CP is the best of all worlds – it achieves emissions reductions through a mix of consumer electricity efficiency, generation efficiency, co-firing, and new renewables – the mix reduces emissions more than any one technology can achieve on its own