Ameren Corp. has proposed an alternative to the Environmental Protection Agency's (EPA) Clean Power Plan, publishing a white paper asserting that constructive and common-sense alterations to the plan are needed to avoid the imposition of greater costs on utility customers and risks to electric grid reliability.
The company says its proposal would achieve the same final CO2 emission reduction goals as the EPA's own plan, while saving $4 billion in costs and avoiding grid reliability problems related to the premature closure of key coal-fired power plants.
The proposal says the EPA could greatly enhance the adaptability and effectiveness of its plan with a few modifications:
· 2020 Targets: The EPA should replace interim target goals beginning in 2020 with a more flexible approach that provides states greater leeway in determining the proper glide path to achieve the agency's final GHG goals by 2030.
· Interim reporting: The EPA should establish enhanced interim reporting requirements by the states to facilitate monitoring and to ensure progress is being made to achieve the final 2030 targets.
· Performance Metrics: The EPA should revise the compliance formula to provide proper credit under its rate-based method for retiring, and not replacing, existing coal-fired power plants with fossil generation.
· Graduation Dates: The EPA should offer states the flexibility to extend the 2030 deadline if a clear path to meaningful reductions is evident in a reasonable time frame.
Ameren says its proposed alterations to the plan would not simply benefit its interests, but would provide substantive benefits to facilitate cost-effective compliance with the plan for utilities around the country. Based on carefully calibrated projections of long-term regional supply-and-demand dynamics, Ameren's GHG strategy relies on a diverse mix of coal, nuclear, natural gas, and renewable energy resources, as well as the continuation of robust energy efficiency programs.
Under the Ameren GHG strategy, by 2035 Ameren would retire more than 1,800 MW (about one-third) of its coal-fired fleet, add about 500 MW of renewable generation, extend the license of its 1,200 MW Callaway Nuclear Energy Center, add a 600 MW natural gas combined-cycle unit, and continue to offer robust energy efficiency programs.