On August 21, 2018, the U.S. Environmental Protection Agency (EPA) proposed the Affordable Clean Energy (ACE) rule which would establish emission guidelines for states to develop plans to address greenhouse gas (GHG) emissions from existing coal-fired power plants. http://www.epa.gov/sites/production/files/2018-08/documents/ace_overview_0.pdf
The Indiana Energy Association in conjunction with the Indiana Electric Cooperatives and the Indiana Municipal Energy Association offer the following thoughts on the proposed Affordable Clean Energy rule:
Trends in CO2
Trends in emissions reductions inform the design of reasonable and effective regulation. Emissions from the electric power sector have been rapidly declining due to various factors including fuel switching, retirements, and increased deployment of natural gas and renewable resources. The trend away from a direct relationship between electric generation and emissions is shown in Figure ES-8. “Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990 – 2016,” EPA 430-R-18-003, p. ES-14. Emissions decreased approximately 24 percent from 2005 to 2016 while overall electric generation remained flat, and the carbon intensity of the electric power sector is expected to continue to decline.
Plan Submittal, Review, and Federal Action
IEA supports the EPA proposal to allow states up to three years after the notice to adopt and submit a state plan; provide timing of EPA action to be 12 months from the completeness determination, rather than 4 months; and to provide for the promulgation of a federal plan in two years rather than 6 months if a state were to fail to submit. CAA 110(c) supports these proposals.