ACE Rules

贡献者:Nicky 类别:英文 时间:2020-02-21 16:39:48 收藏数:5 评分:-1
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A.Background
The Affordable Clean Energy Rules (ACE) is aimed to repeal the 2015 Clean Power Plan (CPP)
which has been stayed by the Supreme Court. The EPA has provided a series of regulatory as
well as cost-benefit analysis in favor of the ACE over the CPP. The major takeaway of the ACE
is that it will give states a lot of flexibility in determining performance standard of emission
reduction by allowing states to choose from a list of “candidate technologies” to develop and
submit their plan based on their respective circumstances and the regulated sources operated
there. Furthermore, the ACE rule has also revised rule regarding the determination of “major
modification” under New Source Review(NSR) of Clean Air Act 111(d) which will allow states
to adopt an alternative “hourly emissions test” that will incentivize efficiency improvement at
existing power plants.
B.Major Components of ACE:
1.Determination of the Best System of Emission Reduction (BSER)
ACE defines BSER as being limited to emission reduction measures that can be applied to or
at an individual stationary source. This includes measures based on a physical or operational
change to a building, structure, facility, or installation at that source. ACE proposed such
definition as an “inside the fence-line” approach as opposed to the “outside the fence-line”
approach adopted by CPP.
ACE proposes that the “heat rate improvement” addressing the efficiency of power generation
on site is the BSER for GHG emissions from coal-fired power plants and provides a list of
candidate technologies for states to evaluate.
2.Process for submitting a State plan establishing performance standard
Within 3 years from the final rule, states should develop and establish standards of performance
through the application of the BSER and determine which candidate technologies to be applied.
EPA will have 12 month to evaluate and approve state’s plan after the submission. If EPA does
not approve, then EPA will have 2 years to develop a federal plan for the state.
3.Revision to the NSR permitting program
To prevent the triggering of “major modification NSR” review in the application of the heat rate
improvement under ACE, EPA revise the NSR permitting program and establish a new preliminary
applicability test through which sources would first look to see whether a physical or operational
change made to an electric utility generating unit (EGU) would result in an increase in that EGU’s
hourly emissions rate instead of actual annual emissions.
C.Major takeaways of ACE
1.Less stringent for emission reduction requirements
As opposed to CPP, the ACE adopts the inside of fence-line approach. In other words, the new legal
structure allows states to develop a performance standard that targets only on the improvement of
efficiency on site of the existing power plants.
2.No requirement for the cleaner energy source
Unlike CPP that requires the change of energy portfolio, the emission reduction that can be
achieved under ACE rules is presumably lower than if switching to cleaner energy as proposed
by CPP.
3.States have gained more authority in establishing performance standard
The ACE does not set any reduction target or goals for the state. Instead, the states have
plenty of flexibility to choose from the “candidate technologies” to develop its own standard
for individual facilities. Furthermore, ACE allows states to take the facilities’ “remaining useful
like” into account when setting standard. It will possibly result in a much weaker standard as
developed by the states.
4.Modified 'Major NSR' could result in a loophole for clean air
Under ACE, states have option to adopt “hourly emission” approach that makes the triggering
of Major NSR much more difficult. It could encourage coal-fired power plant to increase their
emissions, regardless how energy efficiency is improved, without a stringent regulatory constrain.
Consequently, there may be a “rebound effect” where coal-fired plants may be called upon to run
more hours, thus increasing the total amount of CO2 generated
5.ACE will possibly invite more litigations regarding EPA’s authority to come
It can be expected that more litigations will come after the finalization of the rules.
Possible issues will involve EPA’s authority toward CAA 111(d), rationale in determining BSER,
modification of NSR permitting program, and state’s implementation that is in contrary to the
essences of the CAA, especially when current administration replaced by another.
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