THE EPA PROPOSED GREENHOUSE GAS STANDARDS: A GAS TURBINE FLEET IMPACT ANALYSIS

The EPA previously proposed new CO2 standards for both new and existing stationary combustion turbines under Section 111 of the Clean Air Act. At the time of writing, these standards would have had a have significant implications on the operation, capacity factor, reliability, availability, and performance of the gas turbine fleet within the U.S. power grid. The standards would impact the costs of operating the fleet which will impact fleet owners and operators and the public. The proposed standards limit CO2 emissions from new and existing sources and are justified with associated Best System of Emission Reductions (BSER) using Hydrogen-blended fuels or Carbon Capture and Storage. The paper shows that the BSER used to justify the proposed limits are insufficient (i.e., levels of Hydrogen and CCS required for rule compliance are beyond what is stated as BSER justification). Analysis is presented to consider the impact of the rules on the existing gas turbine fleet as operated including assessments of the amount of hydrogen required, number of plants that would be impacted, and projections of the required renewable generation required to replace non-compliant or curtailed gas turbines. The authors also discuss potential unintended incentivized actions based on the rules, such as early retirement of critical generation capacity, and minimizing plant capacity factors at the expense of total CO2 emissions. The methodology to assess the economy-wide impact of technology depends on the analysis's assumptions. Therefore, this analysis does not predict specific outcomes but offers insights into potential impacts under certain assumed conditions.