In a recent letter to the D.C. Circuit Court of Appeals, Troutman Sanders attorney Peter Glaser argues that “EPA far understated the effects of the Clean Power Plan (CPP) by exaggerating the amount of coal generation that will retire even without the rule.” Ironically, the smoking gun evidence is in the agency’s updated modeling, which now tallies with U.S. Energy Information Administration (EIA) data.
Here’s how the numbers break down.
In EPA’s “base case” for the CPP, the agency assumed that in 2016, almost 20 percent of coal capacity would disappear even if the rule were not adopted, reducing coal generation to 214 gigawatts (GW).
EPA’s new estimate for 2016 is now roughly in line with Energy Information Administration (EIA) data. EIA’s Electric Power Monthly shows 272 GW of coal capacity in service as of August 2016.
EPA estimates coal generation capacity under the Power Plan will decline to 174-183 GW by 2030 (Regulatory Impact Assessment, Table 3-12).
Bottom line: To comply with the CPP, U.S. coal generation will have to decline by about one third.