Overview of MISO’s Analysis of
the EPA’s CSAPR Update Rule
October 2016
Overview
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Why am I here?
What is CSAPR?
What have we done so far?
Where are we now?
Overview of MISO’s study of the CSAPR Update Rule
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Proposed CSAPR Update Rule
More stringent seasonal NOx emissions
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EPA proposed Cross State Air Pollution Rule (CSAPR) Update (80
FR 75705; December 3, 2015)
Interstate transport (or “good neighbor”) requirements come from the
Clean Air Act and states must prevent emissions which:
– Contribute significantly to nonattainment, or
– Interfere with the maintenance of the NAAQS, in any other state
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The following measures implementable in 23 states (11 states in
MISO) effective May 1, 2017
– Fully operate/optimize exiting control technologies (SCRs or SNCRs)
that are installed and operational but underutilized or idled
– Install modern combustion controls (e.g. low NOx burners + over-fire air)
– Shift generation to lower NOx emitting units
– Displace coal by dispatching in-state natural gas e.g., increase
utilization of natural gas combined cycle (NGCC)
Overview of MISO’s study of the CSAPR Update Rule
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MISO’s study of the proposed CSAPR
Update Rule
• PLEXOS model, which produces optimal hourly
economic dispatch considering generation,
transmission, and environmental constraints
– Focused on 2017 scenario, also performed 2025 and 2030
– Scenarios ranged from one in which states must meet their
budget alone with no emission trading and another in which all
Eastern Interconnection states can trade emission allowances
• Major modeling assumptions:
- Includes only currently used emission control technology
- Compliance achieved through energy and emission trading only
• Takeaways
– In 2017, the seasonal NOx budget can be met in MISO states
through redispatch (IA and AR have toughest compliance)
– Regional energy and emission trading eases implementation of
the CSAPR update in MISO
Overview of MISO’s study of the CSAPR Update Rule
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Final Rule Updates
STATE
North Carolina
Wisconsin
Tennessee
Virginia
Iowa
West Virginia
Arkansas
Alabama
Pennsylvania
Illinois
Louisiana
Ohio
New York
Mississippi
Missouri
New Jersey
Kentucky
Maryland
Texas
Kansas
Michigan
Indiana
Oklahoma
CHANGE*
LESS STRINGENT
• The Final Rule’s
seasonal NOx limits
are overall less
stringent than
originally proposed,
but individual state
impacts may vary
• North Carolina no
longer has a seasonal
NOx budget under the
Final Rule
MORE STRINGENT
*Percentage change in reference to proposed budget
Overview of MISO’s study of the CSAPR Update Rule
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Energy changes lessen in MISO under final
CSAPR Update Rule
• Individual states like MI and IN now have more
stringent seasonal NOx targets
% Change in MWh
May 1 – Sep 30
Proposed
CSAPR Update
Final CSAPR
Update
IN
-2.6
-3.0
MI
+6.1
-1.7
MISO states
+3.6
+2.6
– Energy changes indicate potential compliance pathways with
emission trading (changes are greater with no emission trading
but compliance is still achievable)
– Compliance achieved through shifting coal to gas, increasing
import from non-CSAPR states
• Major model assumption: only currently utilized
emission control technology included
– Emission production rates based on historical performance
Overview of MISO’s study of the CSAPR Update Rule
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Contact
• Jordan Bakke [email protected]
• Jesse Phillips [email protected]
Overview of MISO’s study of the CSAPR Update Rule
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