{"id":107,"date":"2012-01-11T22:49:42","date_gmt":"2012-01-12T04:49:42","guid":{"rendered":"https:\/\/allenergyconsulting.com\/blog\/?p=107"},"modified":"2012-01-24T07:36:39","modified_gmt":"2012-01-24T13:36:39","slug":"cross-state-air-pollution-rule-csapr-halted-moral-hazard","status":"publish","type":"post","link":"https:\/\/allenergyconsulting.com\/blog\/2012\/01\/11\/cross-state-air-pollution-rule-csapr-halted-moral-hazard\/","title":{"rendered":"Cross State Air Pollution Rule (CSAPR) Halted \u2013 Moral Hazard"},"content":{"rendered":"

Though I may not always agree in the merit of the various environmental regulations, I do believe the courts <\/span>halt of CSAPR rule<\/span><\/a> was out of line.\u00a0 The rationale of the court and the plaintiff was the regulation was going to wreak havoc on the economy and the reliability of the system.\u00a0 I contend the stay may result in greater havoc for our economy.\u00a0 The utilities arguing for this under the merit of timing are somewhat disingenuous.<\/span><\/span><\/p>\n

The EPA attorneys should note CSAPR is a modified Clean Air Interstate Rule (CAIR).\u00a0 CAIR was issued on March 10, 2005. CAIR was then vacated\/remanded in late 2008. The irony is the vacature came from the environmentalist.\u00a0\u00a0 The environmentalist did not like the fact trading could result in creating hot spots of emissions and could result in no change in downwind states emissions.\u00a0 EPA had to go back and modified the rule so there would be limits on trading, so downwind states will actually see reductions regardless of trading.\u00a0 Utilities expecting CAIR to disappear when it was vacated would have been very foolish.\u00a0 In fact, that is not what occurred.\u00a0\u00a0\u00a0 Over the last few years, we saw significant changes to the coal fleet with significant control equipment installation.\u00a0\u00a0 As noted in <\/span>AEP sustainability report<\/span><\/a> \u2013 \u201c<\/span>Since 2004, AEP invested more than $5 billion to install state-of-the-art environmental controls that have resulted in significant reductions in regulated emissions from our power plants\u201d \u00a0I can tell you AEP did not do this for the press release or the sustainability report, but for preparing for CAIR and MACT \/MATS along with NSR settlement.\u00a0 The excuse of not having enough time cannot be legitimately used given when CAIR was issued and the fact CSAPR allows significant trading for the first two years.\u00a0\u00a0 Given a well-designed trading strategy even those ill-prepared plants such as Monticello can continue to run.<\/span><\/span><\/p>\n

There are many assets that have threatened to retire.\u00a0 \u00a0I would like to call the bluff on many of those.\u00a0 In fact many coal plants, I suspect the owners have financial concerns versus implementation concerns.\u00a0\u00a0 The best bet for those owners would be to place those assets for sale and \/ or develop a very aggressive emissions trading program versus retiring, but the threat of retiring allows them to sustain the status quo.<\/span><\/span><\/p>\n

In terms of reliability concern, I would have really liked the courts to have waited for real proof.\u00a0\u00a0 If they observed brown outs in January or in any other time period, I would have no issue for the court to stay the decision. \u00a0This premature stay is not conducive for the economy.\u00a0 The court has created a moral hazard.\u00a0 They are making our economy to be reactive not proactive.\u00a0\u00a0 Those who moved forward and thought ahead and planned are now being punished.\u00a0 Those who waited and did nothing are being rewarded.\u00a0\u00a0 I understand policies and regulation will likely never be perfect, but if we cannot implement and learn we will never progress.<\/span><\/span><\/p>\n

 <\/p>\n

I have evaluated every environmental program to hit the power sector over the last 10 years.\u00a0 Please do keep All Energy Consulting in mind for your consulting needs. Let us write you a proposal.<\/p>\n

Your Energy Consultant,<\/p>\n

David K. Bellman<\/a><\/p>\n

 <\/p>\n","protected":false},"excerpt":{"rendered":"

Though I may not always agree in the merit of the various environmental regulations, I do believe the courts halt of CSAPR rule was out of line.\u00a0 The rationale of the court and the plaintiff was the regulation was going to wreak havoc on the economy and the reliability of the system.\u00a0 I contend the […]<\/p>\n","protected":false},"author":1,"featured_media":46,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1,6],"tags":[32,10,5,12,30,35,29,36,11],"class_list":["post-107","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-market-insights","category-power","tag-coal","tag-cross-state-air-pollution-rule","tag-csapr","tag-emissions","tag-epa","tag-mact","tag-mats","tag-retirement","tag-trading"],"_links":{"self":[{"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/107","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/comments?post=107"}],"version-history":[{"count":7,"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/107\/revisions"}],"predecessor-version":[{"id":111,"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/107\/revisions\/111"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/media\/46"}],"wp:attachment":[{"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/media?parent=107"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/categories?post=107"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/allenergyconsulting.com\/blog\/wp-json\/wp\/v2\/tags?post=107"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}