Earlier this week a group of Senate Republicans penned a letter to the U.S. Environmental Protection Agency (EPA) requesting that carbon emission caps proposed in May for natural gas and coal plants be withdrawn.
According to the agency’s proposal coal plants would have to capture 90% of their carbon dioxide emissions by 2030, while natural gas units have a bit more leeway and would have until 2035 to capture the same amount of CO2, include hydogen or reduce their output.
The ambitious targets are part of the Biden administration’s push to slash the economy’s carbon intensity, while transitioning it to renewables and possibly nuclear energy. But this particular drive from the EPA to reduce emissions has generated pushback from multiple directions.
Republicans claim that the EPA simply doesn’t have the authority to mandate any reductions, as the previous set of rules – the Clean Air Act and more specifically its 2014 Clean Power Plan – was challenged legally and the Supreme Court ruled in West Virginia v. EPA that the agency can’t direct plants on the energy source they utilize.
An industry organization representing utility companies called Edison Electric Institute (EEI) has also indicated that it opposes the current set of proposals. The companies represented by this group supply energy to 250 million customers nationwide.
Relevant: US Supreme Court Limits EPA’s Ability To Reduce Emissions
According to a report in Reuters, the EEI stated that “there are significantly fewer levers for technical and technological improvement for natural-gas based units when compared to coal-based units,” in a white paper published in April.
These concerns are echoed by analysis from BTU Analytics, a FactSet company, which shows that the proposed standards would impact far more natural gas plants than initially expected.
“[The EPA] provide carrier model plants that have detailed characteristics, including location and details about grid interconnections and capacity. [With these characteristics] we were able to figure out which real world plants these model plants were connected to,” explains Nick Jones from BTU Analytics.
The initial analysis by the EPA (and largely confirmed by BTU Analytics) identified 36.8GW of capacity that would need to enact changes.

But an update to the guidance was issued on June 12th and changed the picture. The EPA clarified that a turbine’s size will be determined by its nameplate combustion turbine capacity to which a prorated amount of steam generating capacity will be added.
The author of the research Jonathan Crawford concludes that this would almost double the capacity affected by the regulations “…the draft rule, as written today, would require a significant portion of gas-fired capacity to adjust behavior. At least 79 units, representing 72.5 GW and 44% of modeled baseline natural gas combined cycle generation in 2035, would meet enforcement criteria once a prorating methodology is applied in calculating turbine capacity.”

One of the other interesting findings from BTU Analytics’ research (that doesn’t deviate from the EPA’s own projections) is the low percentage of plants that are likely to deploy carbon capture – just 11%. Though not a forecast per se, the number does seem low when interpreted as an indicator of the potential adoption rate by different plants and units.
All stakeholders have just several days until August 8 to submit comments on the proposed rules with the final guidelines slated for release in 2024. Given that Republican’s description of carbon capture and hydrogen blending as “…nascent and not yet been adequately demonstrated,” a legal challenge that could prevent the EPA carbon emission regulations from being enacted might already be in the works.
Read more: Republicans Release Draft Pipeline Expansion Policy With Carbon Capture Included