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In June 2019, the EPA proposed the Affordable Clean Energy (ACE) program. The agency has challenged each state to develop their own Emission Guidelines for Greenhouse Gas Emissions from Existing Electric Utility Generating Units (EGU's). For ACE, the EPA determined the Best System of Emission Reduction (BSER) for existing coal-fired EGU's to be heat rate improvements (HRI, also referred to as “efficiency improvements”). Standards must be in the form of an emission rate e.g., pounds of CO₂ per megawatt hour (lb CO₂/MWh). 

States have until July 8, 2022 to develop their state-specific ACE plans and submit them to the agency for their review and approval. The EPA has six months from date of state plan submission to determine completeness of a state’s plan and another 12 months from completeness determination to approve a plan submission. Compliance schedules for designated facilities must initiate within 24 months after a state plan submission. This means these plans will go into effect some time in 2024.

To better understand today’s performance of their existing EGU’s, a number of companies have developed their own calculation methodologies to better understand their historical emission rates in lb CO₂/MWh. 

ESC Spectrum has already developed engineering standards in cooperation with a number of larger customers. The new standards follow the calculation specification for New Source Performance Standard (NSPS) reporting requirements for Subpart TTTT - Standards of Performance for Greenhouse Gas Emissions for Electric Generating Units. Subpart TTTT is a similar calculation and reporting program, specifically targeting new generating units. We can use our knowledge and experience to help you adjust these standards to meet your specific needs.

As states move forward and announce their calculation standards for their emission rate demonstration methods, we are ready to help you configure your Data Acquisition System (DAS) to generate data for understanding your historical emissions, determine your unit’s current emission rate, and how changes in a unit’s efficiency can reduce that emission rate.

If your company operates units in more than one state, you may be facing slightly different calculation protocols and the various state develop their plans. You may want to develop your calculation protocols now so that you can comment with experience during the rule-making process currently underway.

Contact Caroline Pena for more information on how we can help you understand how you will be impacted by your state’s ACE program.


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Jon Konings

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