Texas Public Utility Commissioner Kenneth W. Anderson Jr. told the House Energy and Power Subcommittee that the proposal unfairly burdens Texas–which the state predicts will be responsible for 18 to 25 percent of the country’s carbon emissions reductions.
Texas is disproportionately affected by the United States Environmental Protection
Agency’s (EPA) proposed Section 111(d) Clean Power Plan rule. The rule as proposed raises
substantial questions around fairness (EPA proposes that Texas should account for 18% to 25%
of national CO₂ reduction), cost, implementation alternatives, system reliability and whether
compliance is even physically possible, at least within the timelines proposed by the EPA. The
EPA compliance building blocks actually work at cross purpose, at least in Texas…
Anderson argues it will be impossible to comply with the EPA’s second building block and run natural gas plants at 70 percent capacity while complying with the agency’s third building block, which asks Texas to get 20 percent of its power from renewable energy.
Putting aside the timing, cost, and reliability issues, relying on this compliance alternative will likely shut down all other generation during certain times of the day, including nuclear. This creates a paradox. Texas cannot achieve both a 70% capacity factor for gas combined cycle plants and 20% renewable energy production without increasing CO₂ emissions.