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)
The most important existing fleet characteristics and emission control opportunities are these:
n The mix of fossil fuel–fired steam generators and natural gas combined-cycle plants differs from state to state, varying from almost entirely coal to almost entirely natural gas.
n Compared with other categories of industrial sources, the power plant fleet is operated to a unique extent as an integrated system on a state or regional basis, with interdependent management decisions on when to operate, build, upgrade, and retire individual units.
n Depending on their type and starting point, existing generating units can reduce their own CO2 emission rates by improving generation efficiency (improving heat rates) or by switching to or co-firing with lower-emitting fuels (e.g., natural gas or biomass).
n Covered units within a state or group of states can reduce their average emission rates through additional tools, including dispatch shifts (e.g., running lower-emitting plants more and higher-emitting plants less).
n Covered units can reduce their emissions by increasing generation from renewable and other non-emitting plants.
n Covered units can reduce their emissions by increasing end-use electrical energy efficiency.