The Clean Power Plan: Unpacking the Generation Shifting Issue

The U.S. Environmental Protection Agency's (EPA's) Clean Power Plan (CPP) relies, in part, on a pollution reduction strategy - generation shifting - that is at issue in the ongoing lawsuit over the rule. Generation shifting involves increasing use of relatively clean natural gas and renewable energy and reducing use of relatively dirty and expensive coal-fired power plants. Although the technique has lowered power plant emissions significantly in recent years, opponents of the CPP have argued in legal briefs that section 111 of the Clean Air Act precludes relying on generation shifting to reduce carbon dioxide emissions. They claim the technique somehow does not lead to reductions at a pollution source, but their argument doesn't hold up under scrutiny. Generation shifting does reduce emissions at each pollution source that takes advantage of the technique and therefore passes muster.