Endnotes

(1) The author is an industry analyst in the Office of Coal, Nuclear, Electric and Alternate Fuels at the Energy Information Administration (EIA). He gratefully acknowledges the contributions of Russell Lee of the Oak Ridge National Laboratory. Comments may be directed to Mr. Carlin at 202-287-1734.

(2) U.S. Department of Energy, National Energy Strategy, DOE/S-0082P (Washington, DC, February 1991), p. 2.

(3) Public Law 102-486, 42 U.S.C. 13201, "Energy Policy Act of 1992" (Enacted October 24, 1992).

(4) Public Law 101-549, 42 U.S.C. 7401, "Clean Air Act Amendments of 1990" (Enacted November 15

(5) Public Law 91-604, 42 U.S.C. 1857, "Clean Air Act" (Enacted December 31, 1970).

(6) B. Nebel, Environmental Science: The Way the World Works (Englewood Cliffs, NJ: Prentice Hall, 1990), p. 307.

(7) IEA Coal Research, Coal SpecificationsþImpact on Power Station Performance, IEACR/52 (London, England, January 1993), p. 21.

(8) Particulate, CO, and VOC emissions are much more significant at biomass electric generating plant.

(9) U.S. Environmental Protection Agency, National Air Pollutant Emission Trends, 1900-1993, EPA 454/R-94-027 (Research Triangle Park, NC, October 1994), Table A-4.

(10) Energy Information Administration, Emissions of Greenhouse Gases in the United States 1987-1992, DOE/EIA-0573 (Washington, DC, November 1994), Tables 4 and 5.

(11) National Air Pollutant Emission Trends, Table A-2.

(12) These emission data are specific to particular technologies and locations and provide only rough estimates of emission levels. For example, the coal-fired plants are assumed to be 500-megawatt facilities, each with a capacity factor of 75.0 percent and an efficiency rating of 34.5 percent. Also assumed is the use of electrostatic precipitators to control particulates (99.5 percent effectiveness), scrubbers to control SO2 emissions (90 percent effectiveness), and low-NOx burners to control emissions of oxides of nitrogen. The coal used in the East is assumed to have a sulfur content of 2.1 percent by weight, while that used in the West is assumed to contain 0.7 percent sulfur by weight.

(13) Environmental Science, p. 324.

(14) U.S. Environmental Protection Agency, Energy Efficiency and Renewable Energy; Opportunities from Title IV of the Clean Air Act, EPA 430-R-94-001 (Washington, DC, February 1994), p. 8.

(15) National Acid Precipitation Assessment Program, 1992 Report to Congress (Washington, DC, June 1993), p. 6.

(16) NAPAP 1992 Report to Congress, p. 5.

(17) Energy Efficiency and Renewable Energy, p. 10.

(18) NAPAP 1992 Report to Congress, p. 90.

(19) National Research Council, Rethinking the Urban Ozone Problem in Urban and Regional Air Pollution (Washington, DC: National Academy Press, 1992), pp. 31-33.

(20) Ibid., p. 37.

(21) Ibid., pp. 11 and 12.

(22) Energy Information Administration, Emissions of Greenhouse Gases in the United States 1985-1990, DOE/EIA-0573 (Washington, DC, September 1993), p. 1.

(23) D.J. Wuebbles and J. Edmonds, Primer on Greenhouse Gases, (Chelsea, MI: Lewis Publishers, Inc., 1991), p. 33.

(24) National Association of Regulatory Utility Commissioners, Environmental Externalities and Electric Utility Regulation (Washington, DC, September 1993), p. 3.

(25) This discussion focuses on electric utilities. Under the provisions of the CAAA, control of emissions from nonutility generators may vary from State to State and according to facility size and startup date.

(26) The sections of the CAAA that address urban air quality and acid rain also have indirect impacts on greenhouse gases. However, those impacts are not discussed in this article.

(27) Energy Information Administration, Acid Rain Compliance Strategies for the Clean Air Act Amendments of 1990, DOE/EIA-0582 (Washington, DC, March 1994), Table 2.

(28) Energy Information Administration, Annual Energy Outlook, with Projections to 2010, DOE/EIA-0383(95) (Washington, DC, January 1995), p. 30.

(29) Specifically, a unit affected by Phase I requirements is allocated allowances equal to its annual average fuel consumption during the period 1985 through 1987, multiplied by an emissions rate of 2.5 pounds of SO2 per million Btu. Phase II allowances are computed by using the same fuel consumption number multiplied by an emissions rate of 1.2 pounds of SO2 per million Btu.

(30) Energy Efficiency and Renewable Energy, p. 9.

(31) Low-sulfur coal is defined as coal that, when burned, meets an emission standard of 1.2 pounds or less of SO2 per million Btu.

(32) A.D. Kissam, "Pollution Control for Cash," Independent Energy, Vol. 25, No. 1 (January 1995), pp. 52-54.

(33) Acid Rain Compliance Strategies, pp. x-xi.

(34) EIA forecasts that approximately 20 percent (net) of the West's allowances will be transferred to eastern facilities in 2005. See the Supplement to the Annual Energy Outlook 1995, DOE/EIA-0554(95) (Washington, DC, February 1995), Detailed Tables 54 through 66.

(35) Energy Information Administration, U.S. Coal Reserves: An Update by Heat and Sulfur Content, DOE/EIA-0529(92) (Washington, DC, February 1993), Table 8.

(36) U.S. coal producing regions are defined as follows: The Western Region is Alaska, Arizona, Colorado, Montana, New Mexico, North Dakota, Utah, Washington, and Wyoming. The Interior Region is Arkansas, Illinois, Indiana, Iowa, Kansas, western Kentucky, Louisiana, Missouri, Oklahoma, and Texas. The Appalachian Region is Alabama, eastern Kentucky, Maryland, Ohio, Pennsylvania, Tennessee, Virginia, and West Virginia.

(37) EPA has set the ozone standard at 0.12 parts per million daily maximum one-hour average concentration, not to be exceeded more than once per year.

(38) U.S. Environmental Protection Agency press release R-255, "EPA report shows continuing progress in cleaning Nation's air," October 19, 1994.

(39) The CAAA established the Ozone Transport Commission (OTC) to coordinate the efforts of States in the Northeast to solve their ozone problems. State-level coordination is necessary because ozone and its precursors, VOC's and NOx, can be transported over long distances by winds. The OTC includes 12 Northeastern and mid-Atlantic States, the District of Columbia, and the EPA.

(40) U.S. Environmental Protection Agency, Implementing the 1990 Clean Air Act: The First Two Years, EPA-400-R-92-013 (Washington, DC, November 1992), pp. 66-67.

(41) Readers interested in more detail on State IRP planning and externality considerations may wish to consult a recent EIA report, Electricity Generation and Environmental Externalities: Case Studies. DOE/EIA-0598 (Washington, DC, September 1995). See also the following: a recent unpublished report from Oak Ridge National Laboratory entitled The Impact of Environmental Externality Requirements on Renewable Energy (Oak Ridge, TN, July 1994) (contact Mr. Carlin for more information); National Association of Regulatory Utility Commissioners, Environmental Externalities and Electric Utility Regulation (Washington, DC, September 1993); and National Renewable Energy Laboratory, Issues and Methods in Incorporating Environmental Externalities into the Integrated Resource Planning Process, NREL/TP-461-6684 (Golden, CO, November 1994).

(42) Oak Ridge National Laboratory, The Impact of Environmental Externality Requirements on Renewable Energy, unpublished report prepared for the Energy Information Administration (Oak Ridge, Tennessee, July 1994), Table A-1.

(43) McGraw-Hill/Utility Data Institute, U.S.-EC Fuel Cycle Externality Study, Volumes I-VII (Washington, DC, 1994-95).

(44) See Office of Technology Assessment, Studies of the Environmental Costs of Electricity, OTA-ETI-134 (Washington, DC, September 1994) for discussion.

(45) One commissioner advocated a þpurerþ model of direct access that omitted the pool.

(46) D. Wagman and J. Simpson, "Retail Wheeling Opponents Join Forces," Fortnightly, Vol. 38, No. 8 (April 15, 1994), p. 7.

(47) The reductions for 1999 are limited to fossil fuel-fired boilers and other heat exchangers with 250-million-Btu/hour heat inputs and with a potential to emit about 250 tons per year of NOx at a 50-percent capacity factor and an emission rate of 0.5 pounds of NOx per million Btu.

(48) The cutoff point for 1999 reductions does not apply (see previous footnote).

(49) Memorandum of Understanding Among the States of the Ozone Transport Commission on Development of a Regional Strategy Concerning the Control of Stationary Source Nitrogen Oxide Emissions (September 27, 1994).

(50) "Eastern Utilities Say OTC NOx Plan Compliance Would Run Into Millions," Electric Utility Week (October 17, 1994), p. 12.

(51) For more information concerning these "piecemeal problems," see National Association of Regulatory Utility Commissioners, Environmental Externalities and Electric Utility Regulation (Washington, DC, September 1993) and National Renewable Energy Laboratory, Issues and Methods in Incorporating Environmental Externalities into the Integrated Resource Planning Process, NREL/TP-461-6684 (Golden, CO, November 1994).