Ameren Corp., a coal-reliant electric utility in the Midwest (70 percent of its power comes from coal-fired generation), has made a formal move to encourage the EPA to revise its interim targets. The utility recently released a white paper requesting the EPA to replace the interim goals that would begin in 2020 with a more flexible glide path and let states extend their final 2030 deadline if a "clear path to meaningful reductions is evident within a reasonable timeframe." Ameren wrote that it could meet the EPA’s carbon emission goals by 2035 and that this extension would also help to alleviate reliability concerns related to early closures of coal plants. (Another key aspect of the white paper is Ameren’s request to allow states to receive credit for shutting down coal plants.
As the CPP is currently proposed, Ameren’s concern is that a state could shut down a coal plant and not see a reduction in its emissions rate because both the emissions and the amount of power produced would decline). Right now, Ameren’s carbon emissions must be reduced 62% by 2020, as part of the Missouri state targets. Would the EPA reduce this target for the state of Missouri if specific Ameren coal plants were to be shut down? Using the Ameren situation as an illustration of how other load-generating entities could be impacted, the question of whether or not emissions targets would be reduced due to closed facilities is a significant concern for many impacted parties.
Ameren’s comments are consistent with the approach that the Missouri Public Service Commission is taking (Ameren is based in St. Louis, MO). In public filings to the EPA, the Missouri Commission focused heavily on the impracticality of the rule's interim goals and its timeline for meeting final targets in comments to the EPA. "To the extent substantial savings can be achieved by allowing a modest extension of the compliance deadline, while achieving the same level of reduction, the EPA should consider allowing such an extension," said Missouri PSC Chairman Robert Kenney.
The Ameren plan is expected to be supported by the Edison Electric Institute (EEI), the national trade group for investor-owned utilities. EEI is lobbying the EPA for changes to make the rule more workable—focusing heavily on replacing the interim compliance period that would begin in 2020).
However, not everyone agrees that Ameren, or other utilities or impacted load-generating entities, need an extension. Holly Bender, deputy director of the Sierra Club's Beyond Coal campaign, said Ameren's position marks a transition for the utility, and it will be interesting to see if others follow suit. Bender, however, disagrees that Missouri needs more time to comply. "From where we sit, Missouri does not need more time to comply with the Clean Power Plan [and can comply] fairly easily based on things that have already happened or will happen by 2030," Bender said. "I understand Ameren's perspective on its fleet alone, but it's not relevant to whether Missouri can comply with the targets."