Whether a unit’s emission rate or its total emissions over a specified time should
be used to determine if an efficiency improvement project increases emissions.
NETL further stated that several developments since the passing of the 1977 Clean Air Act
Amendments have failed to clarify these issues and made efficiency improvements risky and less
appealing to plant operators. On the other hand, NETL also stated that “[u]nder future scenarios,
the added value of higher efficiency in meeting GHG emissions limits, may prevent the NSR
from being utilized as a barrier to capital investments aimed at improving power plant
efficiency.”50
Fuel Prices for Electricity and Regulatory Uncertainty
Increases in the domestic production of natural gas (primarily due to hydraulic fracturing of gas
shales) are causing a dramatic change in electric power production decisions. A recent decline in
natural gas prices has come with increased production of natural gas, and the resulting decline in
coal consumption for power generation. In April 2012, for the first time in U.S. history, the
amount of electricity generation from natural gas equaled that of coal, according to EIA statistics,
with each representing about 32% of the market.