Scraping the "Bottom of the Barrel" for Power: Why there is No Need to Relax Clean Air Safeguards on Dirty Power Plants to "Keep the Lights On"

The Clean Air Task Force argues that the National Coal Council's claim that 40,000 MW of capacity could be recovered from old coal plants by relaxing New Source Review (NSR) rules is flawed. The report asserts that a boom in new natural gas generation—estimated at 260,000 MW likely to come online by 2005—negates the need for such recovery. It further claims that recovering capacity from old plants would be expensive and difficult, as most deratings occur in small increments across 1,200 units. Finally, it argues that NSR enforcement provides far greater emission reductions than the efficiency (heat rate) improvements proposed by the industry.

• The claim that 40,000 megawatts of capacity can be recovered from old coal plants is based on flawed methodology, including an unsupported assumption that nameplate capacity could be increased by 20,000 MW. An independent analysis by MSB Energy Associates estimated the recoverable capacity at 35,000 MW, consisting of 28,500 MW in deratings and 6,500 MW in shutdowns.
• Recovering capacity from deratings would be difficult and expensive because the potential gains are small and widespread, averaging 24 megawatts per unit across more than 1,200 units. This would require coordinating repair outages at approximately two-thirds of the nation's generating units, potentially challenging system reliability.
• There is no nationwide electricity reliability crisis justifying the relaxation of clean air safeguards. Plant developers announced over 400,000 MW of new capacity for 2000-2005, with a realistic estimate of 260,000 MW likely to be operational by 2005, representing a 30 percent increase over current U.S. installed capacity.
• Meeting peak summer demand (estimated at 100 hours per year) with recovered old coal capacity would produce significantly more pollution than using new combined cycle natural gas plants. Specifically, coal would produce 20,000 tons of sulfur dioxide, 9,000 tons of nitrogen oxides, and 3.8 million tons of carbon dioxide, compared to 0 tons of SO2, 3,000 tons of NOx, and 1.3 million tons of CO2 from gas.
• Environmental benefits from New Source Review (NSR) enforcement far outweigh those from the heat rate (efficiency) improvements suggested by the industry. For example, NSR enforcement at 51 cited plants would reduce SO2 by 2.8 million tons, which is over 12 times the 218,000 tons that would be removed via heat rate improvements across all coal-fired plants.
• The report argues that the push to relax NSR requirements is a strategic effort by the coal industry to protect market share against new gas-powered competition and maintain a "pollution subsidy" valued at over half a cent per kilowatt hour by avoiding modern pollution controls.

APA

Schneider, C. (2001). Scraping the "Bottom of the Barrel" for Power: Why there is No Need to Relax Clean Air Safeguards on Dirty Power Plants to "Keep the Lights On". Clean Air Task Force. https://cdn.catf.us/wp-content/uploads/2019/10/21093517/Scraping_the_Bottom_of_the_Barrel_for_Power.pdf

Chicago

Schneider, Conrad. Scraping the "Bottom of the Barrel" for Power: Why there is No Need to Relax Clean Air Safeguards on Dirty Power Plants to "Keep the Lights On". Clean Air Task Force, 2001. https://cdn.catf.us/wp-content/uploads/2019/10/21093517/Scraping_the_Bottom_of_the_Barrel_for_Power.pdf.

Wikipedia

{{cite report |last1=Schneider |first1=Conrad |title=Scraping the "Bottom of the Barrel" for Power: Why there is No Need to Relax Clean Air Safeguards on Dirty Power Plants to "Keep the Lights On" |publisher=Clean Air Task Force |date=8 November 2001 |url=https://cdn.catf.us/wp-content/uploads/2019/10/21093517/Scraping_the_Bottom_of_the_Barrel_for_Power.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{schneider2001scraping, author = {Schneider, Conrad}, title = {{Scraping the "Bottom of the Barrel" for Power: Why there is No Need to Relax Clean Air Safeguards on Dirty Power Plants to "Keep the Lights On"}}, institution = {Clean Air Task Force}, year = {2001}, month = nov, url = {https://cdn.catf.us/wp-content/uploads/2019/10/21093517/Scraping_the_Bottom_of_the_Barrel_for_Power.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }