TransActions – July/August 2014
EPA’s Highly Anticipated “Carbon Pollution Emissions Guidelines
On June 2, 2014, the EPA released its highly anticipated, “Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units,” its preliminary regulations for greenhouse gas (GHG) emissions from existing power plants. Relying on language in Section 111(d) of the 1990 Clean Air Act Amendments, the EPA determined that the “best system of emission reduction” should not encompass just traditional “sources” (power plants), but the emissions of an entire state. With a target CO2 emission reduction of 30% from 2005 levels by 2030, the EPA set individual state emission reduction targets varying from 10.6% in North Dakota to 71.6% in Washington based on the viability of applying four “building blocks” in a bottom-up approach which considered each state’s existing generating fleet.