The proposed requirements, which are limited to “new sources,” would require new fossil fuel-fired EGUs greater than 25 megawatt electric (MWe) to meet an output-based standard of 1,000 lb of CO2 per megawatt-hour (lb CO2/MWh), based on the performance of widely used natural gas combined cycle (NGCC) technology, according to the EPA. The agency said new coal- or petcoke-fired units could meet the standard either by employing carbon capture and storage (CCS) of approximately 50% of the CO2 in the exhaust gas at startup, or through later application of more effective CCS to meet the standard on average over a 30-year period. Readers can see the entire proposed regulation at: http://epa.gov/carbonpollutionstandard/pdfs/20120327proposal.pdf.

The proposed NSPS drew sharp criticism from the National Mining Association (NMA). “The EPA’s proposal for controlling GHG emissions from about half the nation’s electric power supply is a poorly disguised cap-and-tax scheme that represents energy and economic policy at its worst,” said NMA President and CEO Hal Quinn. “Requiring coal-based power plants to meet an emissions standard based on natural gas technology is a policy overtly calculated to destroy a significant portion of American’s electricity supply.” Quinn also pointed to higher utility costs for consumers and reduced grid reliability as other consequences of the rule.

While the EPA said the rule targets new plants and is “not intended” to affect existing facilities, many are concerned plant modifications required by other EPA rules will be deemed “major” and expose those operations to new source review requirements, including the proposed NSPS.