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	<title>Comments on: New Source Performance Standards for Greenhouse Gas Emissions From New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units</title>
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	<link>https://www.frackcheckwv.net/2023/06/20/new-source-performance-standards-for-greenhouse-gas-emissions-from-new-modified-and-reconstructed-fossil-fuel-fired-electric-generating-units/</link>
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		<title>By: Jim Kotcon</title>
		<link>https://www.frackcheckwv.net/2023/06/20/new-source-performance-standards-for-greenhouse-gas-emissions-from-new-modified-and-reconstructed-fossil-fuel-fired-electric-generating-units/#comment-449363</link>
		<dc:creator>Jim Kotcon</dc:creator>
		<pubDate>Tue, 20 Jun 2023 18:19:23 +0000</pubDate>
		<guid isPermaLink="false">https://www.frackcheckwv.net/?p=45815#comment-449363</guid>
		<description>
strong&gt;PROPOSED NEW EPA GREENHOUSE GAS RULE ~&lt;/strong&gt;

This is the new Greenhouse Gas rule that is intended to replace the Trump-era Affordable Clean Energy Rule which replaced the Obama-era Clean Power Plan.  The proposed rule requires a tiered approach, mandating 90 % Carbon Capture and Sequestration for fossil-fuel plants running after 2040 (Longview?) and requiring co-firing with green hydrogen for baseload plants running after 2035 (e.g., Harrison?).  These would need to be installed by 2030.  The rule is complex, with various categories of plants assigned based on capacity factor and other factors.

The rule is estimated to save 1300 lives per year just from the health benefits.  The health impacts result in a net economic benefit estimated at over $5 billion per year.

Since both the CPP and ACE were overruled by the courts, this rule appears to be focused on &quot;inside the fence&quot; approaches.  Note that WV Attorney General Morrissey opposed the CPP because it included &quot;outside the fence&quot; approaches that would save money.  But requiring inside-the-fence technologies means that CCS has been defined as the &quot;Best System of Emissions Reduction &quot; (BSER).  I will argue that Morrissey&#039;s lawsuit may actually have backfired, because the CPP rules were much more favorable for fossil fuels (especially gas) than this proposed rule.

The comment period was extended to August 8, and EPA expects to finalize a rule early next year.

Full details at:
https://www.epa.gov/stationary-sources-air-pollution/greenhouse-gas-standards-and-guidelines-fossil-fuel-fired-power#rule-summary

Jim Kotcon, WV Sierra Club, Morgantown, WV

P.S.  Note that the Sierra Club&#039;s position is generally supportive of the proposed rule, but we urge that it be implemented sooner.  There are also concerns that mandates for CCS will extend the life of plants, leading to continued mining and drilling impacts.</description>
		<content:encoded><![CDATA[<p>strong>PROPOSED NEW EPA GREENHOUSE GAS RULE ~</p>
<p>This is the new Greenhouse Gas rule that is intended to replace the Trump-era Affordable Clean Energy Rule which replaced the Obama-era Clean Power Plan.  The proposed rule requires a tiered approach, mandating 90 % Carbon Capture and Sequestration for fossil-fuel plants running after 2040 (Longview?) and requiring co-firing with green hydrogen for baseload plants running after 2035 (e.g., Harrison?).  These would need to be installed by 2030.  The rule is complex, with various categories of plants assigned based on capacity factor and other factors.</p>
<p>The rule is estimated to save 1300 lives per year just from the health benefits.  The health impacts result in a net economic benefit estimated at over $5 billion per year.</p>
<p>Since both the CPP and ACE were overruled by the courts, this rule appears to be focused on &#8220;inside the fence&#8221; approaches.  Note that WV Attorney General Morrissey opposed the CPP because it included &#8220;outside the fence&#8221; approaches that would save money.  But requiring inside-the-fence technologies means that CCS has been defined as the &#8220;Best System of Emissions Reduction &#8221; (BSER).  I will argue that Morrissey&#8217;s lawsuit may actually have backfired, because the CPP rules were much more favorable for fossil fuels (especially gas) than this proposed rule.</p>
<p>The comment period was extended to August 8, and EPA expects to finalize a rule early next year.</p>
<p>Full details at:<br />
<a href="https://www.epa.gov/stationary-sources-air-pollution/greenhouse-gas-standards-and-guidelines-fossil-fuel-fired-power#rule-summary" rel="nofollow">https://www.epa.gov/stationary-sources-air-pollution/greenhouse-gas-standards-and-guidelines-fossil-fuel-fired-power#rule-summary</a></p>
<p>Jim Kotcon, WV Sierra Club, Morgantown, WV</p>
<p>P.S.  Note that the Sierra Club&#8217;s position is generally supportive of the proposed rule, but we urge that it be implemented sooner.  There are also concerns that mandates for CCS will extend the life of plants, leading to continued mining and drilling impacts.</p>
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