Comments on Proposed Rule: Emissions Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Generating Units

The US Environmental Protection Agency’s (EPA) Emissions Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel Fired Existing Generating Units proposes emission rate standards for different source categories of coal and natural gas plants. This proposal defines the Best System of Emissions Reductions (BSER) that undergirds the emissions rate standards for coal-fired generators based on fuel, capacity factor, and committed retirement dates. For coal plants, the most stringent requirement, installation of carbon capture and storage (CCS), is only required of plants that are still in service after 2040. Units that plan to retire before 2032 face no additional requirements to control CO2, and plants that plan to retire between 2032 and 2039 face requirements that depend on their average capacity factor.

In this comment, we summarize the announced retirement plans for coal-fired power plants that are reflected in the EPA National Electric Energy Data System (NEEDS) data with some updates from our reviews of press announcements and other sources. Our objective is to summarize how much capacity is currently expected to retire or repower with natural gas on certain timelines for coal producing firms of various sizes and types. This analysis estimates how much coal capacity could be affected by EPA’s proposed standards if these announced plans are implemented in the future. Note that history (and EPA’s analysis of the proposed rule) suggests that new environmental regulations and changing economics may increase coal retirement beyond stated plans, although in some specific cases announced retirement dates have also been delayed.

At a high level we find that:

• Roughly 50 percent of total coal capacity online as of the end of 2022 plans to retire or repower using natural gas before 2032 and thus faces no requirement or else is regulated under the natural gas new source performance standard for greenhouse gas emissions.
• Roughly 37 percent of coal capacity online in 2022 has made no announcement about retirement or repowering before 2040 and thus is potentially subject to the CCS retrofit requirement included in EPA’s proposal.
• The remaining 14 percent of coal-fired capacity may be subject to the gas cofiring standard if operated at a sufficiently high capacity factor and if retirements comport with existing announcements.
• The highest rate of announced retirements or repowerings is for capacity owned by investor-owned utilities, leaving only 27 percent of the investor-owned utilities’ 2022 coal capacity online by 2040. This higher propensity to announce future plans may reflect their involvement in publicly vetted integrated resource planning exercises that focus on investment needs for the future to meet both anticipated energy and reliability needs as well as state policy requirements.
• The top 10 companies in each of the four top ownership categories (IOU, independent power producers, municipals, and cooperatives) collectively account for nearly 73 percent of coal capacity in 2022 and roughly 72 percent of capacity remaining online in 2040. Retirement and repowering plans vary across categories of companies and across companies within each category.

This comment first describes the proposed BSER for existing coal capacity. The methodology used to put together our data follows. Next, we present the aggregate results for all coal plants and results for the top 10 coal-owning entities in each of four categories: investor-owned utilities (IOUs), independent power producers (IPPs), municipal utilities (munis) and rural cooperatives (coops). Then, we explore capacity and announced retirement and repowering plans by time frame by state. The final section offers concluding observations.