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Re: OPKOHEALTH2022 post# 4343

Friday, 10/13/2017 9:02:57 PM

Friday, October 13, 2017 9:02:57 PM

Post# of 59675
So much misinformation about repealing the Clean Power Plan

Repost

The EPA's Repeal of the Clean Power Plan, (CPP) is VERY good for (Coal) and FCEL, if you take the time to read it.

From: The Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units

TWO AREAS AT ISSUE: CLEAN POWER PLAN & CLEAN AIR ACT

CAA (CLEAN AIR ACT) section 111(d) requires the EPA to promulgate emission guidelines for existing sources that reflect the “best system of emission reduction” (BSER) under certain circumstances. Notwithstanding the CPP, all of the EPA’s other CAA section 111 regulations are based on a BSER consisting of technological or operational measures that can be applied to or at a single source.(1)

The CPP departed from this practice by instead setting carbon dioxide (CO2) emission guidelines for existing power plants that can only realistically be effected by measures that cannot be employed to, for, or at a particular source. Instead, the CPP encompassed measures that would generally require power generators to change their energy portfolios through generation-shifting (rather than better equipping or operating their existing plants), including through the creation or subsidization of significant amounts of generation from power sources entirely outside the regulated source categories, such as solar and wind energy.

This raised substantial concerns that the CPP would necessitate changes to a State’s energy policy, such as a grid-wide shift from coal-fired to natural gas-fired generation, and from fossil fuel-fired generation to renewable generation.

(1) This is true not only for all of the handful of existing 111(d) regulations issued prior to the CPP, but also of the much larger set of new-source performance standards issued under CAA section 111(b), which are predicated on the same key statutory term “best system of emission reduction.”

http://i2.cdn.turner.com/cnn/2017/images/10/07/epa.proposed.repeal.of.cpp.-.undated.leaked.100617.pdf
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