We recently worked with
a company to obtain an air permit for a combined-cycle power plant.
These combined-cycle plants use gas turbines that are inherently very
clean. They are fueled with natural gas, a clean (but expensive) fuel
and use dry-low NOx combustors. These pollution-prevention devices
result in low oxides of nitrogen (NOx) emissions. In addition, the
combined-cycle arrangement is very efficient, resulting in 50 percent
more power produced per unit of energy when compared to a traditional
coal-fired power plant. This is late 20th century technology,
not late 19th century technology. Nevertheless, these
turbines still need to compete with the old-technology coal plants.
An emission rate
comparison in terms of pounds of emissions produced per megawatt hour of
electricity generated (lbs/MWH) is presented below:
deregulation and “wheeling,” the market sets the price of power.
Buyers don’t care whether the power comes from an old coal plant or a
clean new plant. If environmental degradation is not included as a cost,
a coal plant can generate power for a fraction of the cost of a clean
In years past, the EPA
was concerned about particulate emissions from coal plants, then with
sulfur dioxide emissions. Many of these plants have been retrofitted
with upgraded control equipment. This year, the EPA wants to regulate
these old plants again to limit the amount of NOx emitted.
Rather than adding
another layer of bolt ons that commit us to 30 more years of burning
coal, doesn’t it make sense to invest in new technology? How do we
encourage this new technology? Does New Source Review and Best Available
Control Technology (BACT) fit into this? How should regulators use their
discretion to interpret BACT? Should they add cost and reduce the
viability of this new technology, or should they interpret the
regulations to fully take into account the impact of added control?
Are there significant
unintended consequences to adding controls on combined-cycle plants? Are
secondary particulate formation, emissions of climate-change gases and
additional emissions of biologically available nitrogen important? Is it
possible that some existing power producers are using the BACT process
to make the cost of combined cycle plants more expensive? By increasing
the cost to competitors, are they extending the life of their old
plants? Is the EPA being shortsighted to insist on adding controls to
this already clean technology, thereby potentially inhibiting the
investment in new power plants?
should make sure that their emission standards are technology enabling.
Overly extreme emission standards may unintentionally raise barriers to
better environmental quality.