The Need for Sensible EPA Rules

As a leading advocate for the U.S. coal fleet and its supply chain, America’s Power (AP) understands the essential role that coal plays in our nation’s energy mix. That is why we and others are alarmed to see that new EPA regulations threaten the reliable supply of electricity upon which every American depends.

These EPA’s rules – revised Coal Combustion Residuals Rule, finalized Good Neighbor Rule, proposed revised Effluent Limitations Guidelines, revised Mercury and Air Toxics Standards, Clean Power Plan 2.0 (CPP 2.0), and the Regional Haze Rule – will force the retirement of more coal plants, especially between 2026 and 2030.

Today, the coal fleet totals 188,000 megawatts (MW), a sharp decline from more than 300,000 MW in 2010. EPA projects, however, that the coal fleet will total only 58,000 MW by 2030 because of the Inflation Reduction Act and four EPA rules, including CPP 2.0. EPA’s projections, which we believe understate future coal retirements, show that the nation’s coal fleet will be dangerously small by 2030, if not sooner.

CPP 2.0 is arguably the worst of these rules. Intended as a replacement for the original Clean Power Plan, which was struck down by the U.S. Supreme Court as an overreach by EPA, CPP 2.0 also exceeds EPA’s legal boundaries. The proposal would require compliance by the end of 2029. By the time EPA finalizes the rule and states develop implementation plans, the coal fleet would have less than three years to comply.

The ridiculous compliance deadline will cause more premature coal retirements and increase the odds of electricity shortages. For example, coal plants that want to continue operating longer than EPA prefers would be required to install carbon capture and storage (CCS) technology within less than three years. Putting aside the fact that the technology is not yet economically feasible for most coal plants to use, it can take nine years or more to install CCS, and the technology can cost $2 billion or more for an average coal plant.

While CPP 2.0 is intended to help decarbonize the U.S. electric grid and presumably mitigate the effects of climate change, the proposal would reduce global greenhouse gas emissions by less than one percent. At the same time EPA and the administration attempt to eliminate the U.S. coal fleet, China continues to aggressively expand its own coal fleet. China has also announced or has under development almost 366,000 MW of new coal-fired generating capacity, which is more than twice the size of the existing U.S. coal fleet.

We can achieve environmental progress without causing an electricity crisis. All it takes is sensible EPA rules.