CC-16-002: NCASI Comments on the Proposed Federal Plan Requirements for Greenhouse Gas Emissions from Electric Utility Generating Units Constructed on or Before January 8, 2014

On August 3, 2015, the EPA Administrator signed The Clean Power Plan (CPP). The CPP establishes final guidelines on the emissions of CO2 from existing electric generation units. On the same day, the Administrator proposed a model federal plan for implementing the CPP in states that fail to develop their own plans. The model plan raises a number of issues important to the forest-based industry and could influence the approaches used to implement the CPP in states developing their own implementation plan. On January 21, 2016, NCASI submitted comments to EPA on the model federal implementation plan. NCASI’s comments focused on a number of issues related to the role of biomass fuels, especially those sources of biomass directly or indirectly derived from the forest, and the role of biomass-powered combined heat and power from industrial facilities. The comments are briefly summarized in this memorandum. The approaches used by states to implement the CPP are likely to affect energy costs. To the extent that wood and wood fiber are used as sources of biomass under the CPP, the demand and costs for fiber could also be affected. The approaches used to implement the CPP will also define the opportunities for the forest-based sector to sell biomass fuels and emission credits to the electric power industry. In the longer term, the CPP may set precedents for greenhouse gas limits that EPA could conceivably propose for industrial facilities. Accordingly, this material will interest all NCASI member companies.