Email, Ilan Levin, associate director, Environmental Integrity Project, July 8, 2015

11:39 p.m.

The backup data are fine. EPA's model runs are standard and are normally used in these rulemaking procedures. I don't know where the PowerPoint comes from, but it clearly involves more than just CPP.

It is wrong to rely on the modeling data to say coal plants will retire. Here's why:

The data is from EPA's modeling files from the CPP rulemaking. These are used only to run various scenarios to see if, given certain assumptions (model inputs), we can achieve the reduction of power plant smokestack CO2 that EPA is proposing. The model just shows we can get there, and one scenario involves a significant drop in net electric generation from coal. But the CPP just assumes that increased natural gas power generation, increased efficiency, and a couple other factors will pick up the slack. EPA has no control over any of these factors and (more to the point) is certainly not requiring these things to happen in the CPP. The CPP simply sets goals and leaves it to the states on how to get there. It's premature to say the CPP eliminates coal plants.

There are certainly very realistic scenarios with retirements of many Texas coal plants in the next 15 years or so. But these are driven mainly by economics. Regulatory drivers, specifically EPA rules that will involve more costs to power plants, include a long list of anti- smog and mercury rules and clean water and waste rules  that have been in development for years if not decades. (I think the PowerPoint attachment actually backs this up.) So, CPP is an important rule, but it has not yet been implemented by the states, so all the details in terms of how it will get implemented have yet to be written. Based on the backup data, one can't  say CPP eliminates coal plants. You can say EPA predicts a drop in coal-based electricity by 2030.




ilan levin