For Immediate Release
Contact: Nick Braden: 202-467-2952
Statement by the American Public Power Association on EPA Release of Emission Rules
for New Coal-Fired Power Plants
September 20, 2013
Washington, D.C. - As the national service organization representing the interests of nearly 2,000 notfor-profit state-and locally-owned electric utilities serving nearly 47 million consumer-owners, APPA has
a long history of working with its members to address climate change. Public power utilities’ primary
purpose is to provide reliable, efficient service to local customers at the lowest possible cost, consistent
with good environmental stewardship. As such, APPA supports several aspects of President Obama’s
proposal to address climate change, including his plan to increase energy efficiency efforts, streamline
hydropower and other renewable resource development, and increase our use of nuclear power. We also
support the President’s call for an “all of the above” strategy, including coal, when it comes to the fuels
we use to produce electricity.
But the Administration’s announcement today that the EPA’s New Source Performance Standard (NSPS)
for new coal-fired power plants will require the implementation of carbon capture and storage (CCS)
technology is unrealistic and does not in our view comport with the requirements of NSPS under the
Clean Air Act. It also runs counter to President Obama’s pledge to pursue an “all of the above” energy
strategy. APPA believes this is the case for several reasons:
First, the Administration continues to base its belief in the viability of CCS by citing two demonstration
projects, the Plant Ratcliffe in Kemper County, Miss., and the SaskPower plant in Canada that are in the
process of attempting to implement CCS. Though both projects are admirable for attempting to advance
the technology, neither of them has demonstrated that the technology is commercially viable.
Second, the Administration fails to mention that both the Kemper and SaskPower plants sit on or near oil
fields, the only areas where CCS has been demonstrated to work. Locations such as these that are suitable
for the injection of CO2 are very limited within the United States.
Third, because CCS is an unproven technology, the financing for both the Ratcliffe and SaskPower plants
required substantial government financial assistance. For a project to become commercially viable, it
must be financed on its own and given the high risk of financing such unproven technology, it is
extremely unclear where the funding would come from.
Fourth, the EPA has failed to answer the very important questions of regulatory treatment and liability for
CO2 once it has been captured by a plant. Is CO2 an acid gas subject to Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) litigation?
-more-
APPA EPA Statement
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September 20, 2013
Who owns and pays for the CO2 monitoring requirements 100 years after a power plant closes under the
Underground Injection Control (UIC) program?
Finally, APPA believes this rule is poor public policy because it requires technology that is unproven and
not commercially viable. Therefore, it will have the effect of precluding options for new coal plants in
the U.S. Taking coal off the table as an option for new plant investments, as this rule will do, will also
increase reliance on natural gas, which is already stressed as a fuel source. APPA is very concerned that
these developments will cause energy prices to increase considerably without new coal plants as a
resource option.
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Based in Washington, D.C., APPA is the national service organization for the nation's more than 2,000
community- and state-owned not-for-profit electric utilities serving 47 million customers.