The EPA proposed Clean Power Plan rule is premised on a straight-forward concept: to identify the best system of emission reductions (BSER) that can be implemented to reduce carbon emissions from existing power plants. To the EPA, the BSER is composed of the four building blocks of the Plan:
- Improve the heat rates at existing fossil fuel plants.
- “Re-dispatch” existing natural gas combined cycle (NGCC) power sources, which means to dispatch them more often in order to increase their utilization up to an average 70% utilization rate.
- Increase use of low- and zero-emitting power sources through policies and market mechanisms such as renewable portfolio standards and incentives.
- Decrease electricity demand by increasing use of demand-side energy efficiency programs.
These building blocks are state specific. If a state has no coal fired generation then the first building block would not apply. This has direct consequences for how the state emission targets were set. The EPA applied these four building blocks to each state and came up with what it considered to be commonsense targets for carbon emissions by 2030. Therefore, the targets in the CPP are heavily dependent on the existing generation mix within each state.
Percent Reduction in Carbon Emission Rates from 2012 Levels to Meet 2030 CPP Target