ESAI Power’s latest Emissions Watch update provided subscribers with ESAI’s analysis of the four final rules issued by the US Environmental Protection Agency (EPA).  The four rules are:

  1. Greenhouse Gas Rule (GHG)
  2. Updated Effluent Limitation Guidelines (ELGs)
  3. Updated Mercury and Air Toxics Standards (MATS)
  4. Coal Combustion Residuals Rule (CCR)
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Greenhouse Gas Rule 
ESAI analyzed the Greenhouse Gas Rule (GHG) issued by the US Environmental Protection Agency (EPA) in April 2024. The GHG establishes emissions standards for existing coal and other steam electric generating units (EGUs) and New Source Performance Standards (NSPS) for new natural gas combustion turbine EGUs. The EPA issued a Final Rule to limit carbon dioxide CO2 emissions from new gas-fired and existing coal-fired power plants under Section 111 of the Clean Air Act (CAA). The emissions standards are most stringent for coal plants scheduled to operate after December 31, 2038 and the most heavily utilized new gas-fired combustion turbines (CTs), which will both be required to meet standards consistent with installing carbon capture and storage (CCS) to capture nearly all of their CO2 emissions by 2032. We are also issuing a data supplement for this rule, assessing potential compliance obligations for the PJM coal fleet using data from our Generation Asset Monitor (GAM).

Effluent Limitation Guidelines
We also analyzed the Effluent Limitation Guidelines (ELGs) issued by the EPA. The updated ELGs finalize stricter wastewater discharge standards for coal-fired EGUs. Specifically, the agency established “zero discharge” limits for three types of wastewater.

Mercury and Air Toxics Standards
Our recent Emissions Watch report also provides market analysis of the updated Mercury and Air Toxics Standards (MATS) issued by the EPA in April. EPA’s final rule strengthens the 2012 National Emissions Standards for Hazardous Air Pollutants (NESHAP) for coal and oil-fired steam electric generating units (EGUs), commonly known as Mercury and Air Toxics Standards (MATS). The updated MATS rule revises the current emissions limits for non-mercury hazardous air pollutants (HAP) metals from existing steam plants and establishes new requirements for EGUs using lignite coal.

Coal Combustion Residuals
We also provided a market analysis of the Coal Combustion Residuals (CCR), which was issued by the EPA in April. The CCR rule establishes requirements for the safe disposal of CCR for inactive surface impoundments at inactive power plants. In April 2015, EPA issued a final rule establishing requirements to ensure the safe disposal of CCRs (or coal ash) from coal-fired power plants. This 2015 final rule did not impose any requirements on inactive facilities. On August 21, 2018, the U.S. Court of Appeals for the District of Columbia Circuit vacated the exemption for inactive surface impoundments at inactive facilities, otherwise referred to as “legacy surface impoundments,” and remanded the issue back to EPA. In April 2024, EPA issued a final rule establishing requirements for inactive surface impoundments at inactive electric power plants (legacy impoundments) and for CCR management units (CCRMUs).

To learn more, visit our Emissions Watch page to learn more and to become a client.

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ESAI Power is a market research and consulting firm that delivers focused analysis of the wholesale power markets: PJM, NYISO, ISO-NE and MISO. To become a client, click here.

Learn About Emissions

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ESAI Power closely follows carbon market developments at the federal, regional and state levels that impact the Emissions markets. At the federal level, ESAI Power reports on changes to existing regulations (i.e., Mercury & Air Toxics and CSAPR Rules) as well as analyzing the potential impacts of new and proposed regulations. In addition, ESAI provides price projections for SO2 and NOx (annual and seasonal) allowances.

Learn About Emissions Watch

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Emissions WatchTM is our quarterly publication contains ESAI Power’s outlooks and views on the emissions markets. ESAI provides regular updates and analysis on developments in the SO2, NOx and CO2 emissions markets as well as price forecasts for state and regional markets. In addition, regular updates are provided on the RGGI program as well as other state-specific emissions programs. At the federal level, ESAI Power reports on changes to existing regulations (e.g., Mercury & Air Toxics and CSAPR Rules) and analyzes the potential impacts of new and proposed regulations. In addition, ESAI provides price projections for SO2 and NOx (annual and seasonal) allowances.