In as recent letter to the D.C. Circuit Court of Appeals, Troutman Sanders attorney Peter Glaser argues that “EPA far understated the effects of the Clean Power Plan (CPP) by exaggerating the amount of coal generation that will retire even without the rule.” The smoking gun evidence is in the agency’s updated modeling, which now tallies with U.S. Energy Information Administration (EIA) data.
Here’s how the numbers break down.
However, EIA’s Electric Power Monthly shows 272 GW of coal actually in service as of August 2016.
So there you have it. EPA’s “base case” for calculating how much coal generation will have to decline to meet CPP requirements is now virtually identical to EIA’s.