EPA’s Projected Impacts of the CPP on the Coal Fleet
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•In assessing the impacts of the final CPP, EPA assumes that a much smaller coal fleet will remain in the near future ("base case") than EPA assumed in last year’s analysis of the proposed CPP. EPA is now assuming that there are will be far fewer coal units by 2020, even without the CPP.• By assuming a "base case" with more coal retirements, EPA is able to claim that the final rule does less harm to coal because there are fewer coal units to be harmed.
• Compared to the proposal, the final rule assumes that 1/3 of the coal fleet (approximately 100 GW) will have retired by 2020 even without the CPP. This is considerably more than EPA projected for the proposed CPP (66 GW), more than EIA projects (55 GW), and more than ACCCE’s announced retirements (68 GW).
• The projected impacts of the final CPP — i.e., the harm to coal — would have been greater if EPA had used the same "base case" as the proposed CPP:
Electricity generation from coal declines by 22% under the final rule in 2030. This would have been a 31% reduction if EPA had used the base case from the proposed CPP.Coal consumption declines by 21% (181 million tons) under the final rule in 2030. This would have been a 29% (282 million tons) reduction if EPA had used the base case from the proposed CPP.
