Kendra Abkowitz & Quincy Styke III

Transcription

1 Kendra Abkowitz & Quincy Styke III

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3 Developed with input from TCCI Air Quality Subcommittee s and letters sent to all Title V sources Proposed - September 11, 2015 Public Hearing November 2, 2015, 9:30 am Tennessee Tower, Nashville Board Adoption November 12, 2015 Proposal and Draft Workload Analysis available at:

4 $60.00 $50.00 $40.00 $30.00 $20.00 $10.00 $39.00 $43.00 $28.50 $32.50 $56.00 $49.50 $45.50 $39.00 existing proposed $0.00 non-egus actuals non-egus allowables EGUs actuals EGUs allowables

5 Eliminate $7500/year base fee Replace with $7500 minimum fee $20,000 $18,000 $16,000 $12,000 $10,000 $14,000 $12,000 $10,000 $8,000 $6,000 $4,000 $2,000 $0 $7,500 $10,000 Base Fee $8,000 $6,000 $4,000 $2,000 $0 $7,500 $10,000 Minimum Fee

6 Entities may choose to pay on Calendar Year basis or state Fiscal Year Basis Beginning with calendar year 2016 (the fee due July 1, 2017) Current rule specifies Fiscal Year, this will remain the default May elect to pay on actual basis, allowable basis, or mixture Must notify Division of accounting period and fee basis in writing by December 31st of accounting period Default is basis specified in permit If not specified in permit, default is allowable deadline for choosing Dec Jan Feb Mar April May June July August September October November December January February March April May June July Calendar Year Basis Fiscal Year Basis

7 No fee for greenhouse gases (GHG) solely because a pollutant is a GHG Revising allowable limit for fee purposes: Removed requirement to meet with Division Submit request in writing at least 90 days before due date Must specify method for determining compliance with limit

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9 CAA requires EPA to set national ambient air quality standards (NAAQS) for pollutants considered harmful to public health and the environment, to periodically review these standards to ensure that they provide adequate health and environmental protections, and to update standards as necessary. October 1, 2015 EPA lowered primary (health-based) ozone standard from ppm (75 ppb) to ppm (70 ppb). Form of standard remains 3-year average of 4 th highest 8-hour daily average. EPA set secondary (welfare-based) ozone standard to be identical to the primary ozone standard. Standards for ground-level ozone were initially set in 1971; revised by EPA in 1979, 1997, and 2008.

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11 Preliminary Design Values Preliminary Ozone Design Values

12 *2015 data is preliminary

13 *2015 data is preliminary monitor operated by the state of KY

14 *2015 data is preliminary

15 *2015 data is preliminary

16 *2015 data is preliminary critical value shown is from a monitor operated by the state of AR

17 *2015 data is preliminary

18 *2015 data is preliminary

19 *2015 data is preliminary

20 Timeline: Revised NAAQS Promulgated 10/1/2015 State recommendations of attainment areas will be due ~ October 2016 based upon data. EPA final designations should occur October 2017 EPA will use ozone data State SIPs are due: ~ October 2018 for the infrastructure SIP for entire state ~ October 2020 for the attainment SIP for nonattainment areas (moderate and above)

21 CSA or CBSA is presumptive boundary Nine factors evaluated: Air Quality Data Traffic and Commuting Patterns Emissions Data Growth Rates and Patterns Population Density and Meteorology Degree of Urbanization Geography and Topography Jurisdictional Boundaries Level of Control of Emission Sources

22 Source: U.S. EPA Office of Air and Radiation

23 All areas currently meeting standard Likely one more ozone season before designations Critical Values for 2016 have been calculated

24 The Air Quality Index (color codes) giving qualitative characterizations to have new cut points delineating the color bands of the index. There are miscellaneous changes to ambient ozone monitoring requirements. PSD Grandfathering for in the pipe applications processed under the 2008 ozone NAAQS rather than the 2015 NAAQS.

25 TN OZONE SITE REFERENCE TABLE

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27 EPA issued on August 3, 2015: Final Clean Power Plan Establishes CO 2 emission performance rates for two subcategories of fossil fuel-fired electric generating units (EGUs): fossil fuel-fired electric steam generating units and Natural Gas Combined Cycle (NGCC) units States with affected EGUs (existing power plants that began construction on or before 1/8/2014) required to create and submit plan for compliance with standards Final New Source Performance Standards (NSPS) for New sources that commenced construction after 1/8/2014 Unit that is Modified (with physical or operational changes that increases maximum hourly emission rate) after 6/18/2014 Unit that is Reconstructed after 6/18/2014 Proposed Federal Plan and Model Rules for state Clean Power Plan

28 Compliance timeline begins in 2022 instead of 2020 Eliminated under-construction nuclear and demand-side EE (Proposed Building Block 4) from BSER (both still included as compliance measures) Best System of Emission Reduction (BSER) building blocks applied regionally, i.e., to each of three interconnections, to create two category specific performance rates instead of developing state-specific rates BSER phased in gradually throughout compliance period; states may determine own glide path

29 Goals provided in alternative forms, which states may opt to use for compliance demonstration: Blended state rates Mass-based limits for existing EGUs Mass-based limits for existing & new EGUs Trading-ready compliance options Reliability considerations must be factored into state plans Clean Energy Incentive Program for qualified RE and low-income demand-side EE in 2020 and 2021 Meaningful engagement with disadvantaged communities

30 BSER applied on interconnection basis and set at least stringent rate Same category-specific performance rates applied across all states Individual State blended rates based on generation mix (e.g., TN blended rate = 1211 lb/mwh) EPA calculates state mass goals based on state blended rates 2030 Final Rate Fossil steam (lb/mwh) NGCC (lb/mwh) Eastern Western ERCOT

31 Interim Update Source: Nicholas Institute for Environmental Policy Solutions

32 Emission Standards Plan Rate-Based Source Specific (final goals = 1305 lb/mwh for fossil steam; 771 lb/mwh for NGCC) Intra-state or interstate trading ready Blended (final goal = 1211 for TN) Not trading ready Mass-Based EPA-calculated for each state Trading ready Must address leakage Include new units under mass limit with new source complement (calculated by EPA) Allocation method that counteracts leakage Other methods demonstrated by state to prevent leakage State Measures Plan Mix of state measures that are not federally enforceable components (e.g., RPS, energy efficiency programs, etc.), but which may include federal emission standards to meet goal Must have a federally enforceable backstop Must be mass-based

33 2012 Baseline Emissions 2020 EPA Projections (without CPP) for Existing Units RATE-BASED (lb/mwh) 2,015 41,222,026 1,517 44,738,549 MASS-BASED (Short Tons) Proposed Final Proposed Final Existing Only Final Existing & New Interim Goal ,254* 1,411 24,624,000 31,784,860 32,143,698 Step 1 ( ) 1,531 34,118,301 34,265,552 Step 2 ( ) 1,380 31,079,178 31,575,934 Step 3 ( ) 1,275 29,343,221 29,812, and Beyond Final Goal 1,163 1,211 22,837,000 28,348,396 28,664,994 *proposed interim goal was for

34 New & Reconstructed Natural Gas 1000 lb/mwh-gross* Modified Natural Gas Not finalized, proposal withdrawn Electric Utility Steam Generating Units (generally coal) 1400 lb/mwh-gross Modified Coal Larger modifications (increase of hourly CO 2 >10%): best annual performance level during 2002 time of modification Standard for smaller modifications (increase of hourly CO 2 10%) was not finalized, proposal withdrawn Reconstructed Coal Units > 2000 MMBtu/hr: 1800 lb/mwh-gross Units 2000 MMBtu/hr: 2000 lb/mwh-gross *CPP goals are in lb/mwh-net

35 Comment period ends 90 days after publication in FR EPA intends to finalize model rules in summer 2016 Two Model Rules presumptively approvable Mass-Based Rate-Based Federal plan proposals similar to model rules, but less flexible EPA intends to finalize a single approach for Federal Plan (mass or rate) Will only be finalized when and if a state fails to submit an approvable plan State can submit partial plans to take over any part of Federal Plan (e.g., allowance allocations)

36 Final Clean Power Plan Final goal slightly less stringent EPA heard several of Tennessee s more significant concerns Removal of under-construction nuclear and existing biomass from BSER Delay in start of compliance period Gradual glide path Extension option for final plan submittal Evaluating various compliance options and impact on electric system generation in Tennessee Seeking input from affected utility (i.e., TVA) Formal public outreach likely to commence Spring 2016 Will likely seek 2-year extension Proposed Model Rules and Federal Plan Currently reviewing proposal Determining areas of concern or support Likely to submit comments

37 Jimmy Johnston Deputy Director TDEC Division of Air Pollution Control