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A Wee Bit of Clean Power Plan Knowledge

By January 25, 2016November 7th, 2021Energy Rant
clean power plan

Everyone reading this knows about the EPA’s Clean Power Plan (CPP). You probably know the final rule was released in August 2015, and the plan calls for reducing CO2 emissions by 32% from a baseline of 2005 to the goal-achieving euphoria in 2030. From there, I’ll bet a survey for CPP knowledge falls like a Wile E Coyote Acme anvil.

Answers to basic questions are very hard to find. The EPA’s website mainly provides fluff and spin describing how great the plan is and how flexible and easy it will be to “glide[1]” to success.

Instead, I conducted my research from other sources with g-o-o-g-l-e. This fine blog post from NRDC forms most of the basis of this post. The NRDC boiled hundreds of pages of documents and many huge worksheets down to a svelte 4,000 words.

Where Does it Apply?

One very basic question that comes to mind: Does the law apply to where the energy is consumed or where it is generated? For example, what if my state imports lots of “dirty” electricity from outside the state? Living a few miles from the Mississippi between Wisconsin and Minnesota/Iowa, this question comes to mind pretty quickly. Thousands of MW of generation use the Mississippi for a heat sink, and they send energy in both directions to multiple states.

I will make a leap of legal faith to answer my own question. It applies to the point of generation because the EPA cannot regulate “outside the fence lines” surrounding stationary sources of power generation. This, by the way, is why building block four, for energy efficiency, was dropped from the final plan. Energy efficiency occurs outside the fence and therefore, leaving it in the plan posed a point blank target to legally sink the plan.

Building Blocks Minus One

Speaking of building blocks, this is something most readers probably know too, but I will list them anyway. The three ways the CPP suggests as means to reach targets include:

  • Source efficiency
  • Use lower-emitting natural gas combined-cycle plants more
  • Build zero emission sources like wind, solar, and nucular [sic]

By the way, about that source efficiency: A year ago in The Clean Power Plan and the Heat Rate Fairy, I indicated that the originally proposed plan to improve heat rate (efficiency) by 6% was impossible. The final plan chopped this exactly in half to be from 2.1% to 4.3%. As we used to say in the basketball game, h-o-r-s-e, it ain’t braggin’ if you call it.

Doesn’t it make you wonder if this humble author can spot something so glaring with virtually no research at all – what the heck else is dorked up in the plan?

50,000 Foot Methodologies

The CPP allows for two ways to score your (each state) progress while “gliding” into euphoria: (1) rate approach and (2) mass approach.

Rate Approach

The rate approach essentially divides all CO2 emissions by megawatt-hour consumption. There is no way of getting around it, electricity crossing state lines is going to result in situations described by the old adage: some states are treated more fairly than others.

This approach sets goals of 1,305 pounds of CO2 per MWh for “steam generators” and 771 pounds CO2 per MWh for gas-fired turbines.


Presumably, the term “steam generators” in this context is code for coal-fired plants. Steam generators are also used in combined cycle natural gas plants and, of course, nuclear power plants.

Presumably, the term “gas-fired turbines” covers combined cycle power plants, which include steam generators on the bottoming cycle of those. A cartoon of a combined cycle plant is shown nearby.


According to eGrid data, coal plants emit about 2,200 pounds of CO2 per MWh and natural gas plants emit about 1,000 pounds of CO2 per MWh. Therefore, the rate goals above are cardboard cutouts of faux coal and gas-fired power plants. The reality is MWh used for the 1,305 and 771 numbers above include all MWh regardless of source.

Mass Approach

The mass approach uses the same 1305 and 771 numbers to peg a total annual mass cap for CO2 emissions from power plants. The EPA has factored in some projection of economic and load growth for calculating the target numbers.

State Choices

States can choose either path, but all states that have signed on to the plan thus far have chosen the mass approach.


Either option allows trading with other states. The rate option has emission rate credits while the mass option has emission allowances. Mass states can only trade with other mass states, and the same goes for rate states.

Comment: and regulators absolutely resist fuel switching and cross-subsidization within a state? The CPP would have Missouri (an example) subsidizing Kansans or Texans or Ohioans. Smithereens.

To Be Continued

There is plenty more to write about, and I am sure I will. In the meantime, this will drive regulators and utilities crazy. Whereas normal efficiency plans blanket entire service territories, under the CPP, why would you do that? Target the customers that actually get their electricity from a coal power plant: not fair to some customers or the utility. Build more clean energy rate base: not fair to customers.

Duke it out amongst yuhselves.

[1] The EPA calls annual incremental tightening of carbon emissions a glide path; you know, easy, like gliding through the marathon in an Ironman.

Jeff Ihnen

Author Jeff Ihnen

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