Today:

1

• Today
• Clean Air Act regulatory scheme, as it applies to
  coal-fired power plants
• Presentation Future of coal-fired power in
  Germany
• Monday
• Global warming and GHG emissions from fossil fuel
  combustion
• Can/must the EPA regulate CO2 emissions under the
  Clean Air Act?

2
Source CERES, Benchmarking Utility Emissions
(2001)
3
COAL PLANTS AND THE CLEAN AIR ACT
SO2, PM, NOx, CO2, Hg

• Traditional CAA regulation
• Tradeable permits

4

• Clean Air Act Regulatory Scheme Jargon
• NAAQS for conventional pollutants (SO2, NOx, PM)
  ? Section 109 (protect public health with an
  adequate margin of safety)
• Permitting for new and modified sources of
  conventional pollutants
• Emissions standards in attainment areas (PSD)
• Emissions standards in nonattainment areas
• New Source Performance Standards (NSPS backstop
  emissions standards)
• Toxic or hazardous pollutants (Hg) emissions
  standards for all sources

5
COAL PLANTS AND THE CLEAN AIR ACT
Clean Air Act
Federal NSPS Regulations
Tech-based standards
permit
State Agency
6
SOURCE TCEQ
7

• Clean Air Act Modified sources and new source
  review
• Modified physical change increase in
  emissions
• EPA using 2 different ways of measuring
  increases one in their NSPS program, and
  another in their PSD permitting program
• EPA flip-flopping Bush Administration vs.
  Clinton Administration
• Duke Energy case (USSC 2007)

8
The Acid Rain Program
9
The Acid Rain Program
Goal reduce emissions by 40 TPY. Each firm
emits 100 TPY
CONTROL COSTS 5/ton 4/ton
3/ton 2/ton
10
Clean Air Act Results