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PCCA Journal|1

st

Quarter 2015

27

“The Ameren plan would save our

customers billions of dollars while help-

ing avoid substantial economic costs and

consequences related to the potential

degradation of electric reliability, long

a bedrock component of America’s

economic prosperity and widely admired

standard of living,” said Warner Baxter,

Ameren’s chairman, president, and chief

executive officer. “Ameren’s solution

also substantially reduces greenhouse

gas emissions and will, in the long run,

achieve the same emission reductions

as EPA’s proposed rule at a significantly

lower cost while safeguarding our cus-

tomers’ electricity supply.”

Recognizing that the CPP will be sub-

ject to legal challenges, Ameren believes

that the EPA could greatly enhance the

adaptability and effectiveness of its CPP

proposal with a few common-sense

modifications:

s฀

2020 Targets:

Replace EPA’s interim

target goals beginning in 2020 with a

more flexible approach that provides

states greater leeway in determining

the proper glide path to achieve the

agency’s final GHG goals by 2030.

s฀

Interim Reporting:

The EPA should

establish enhanced interim reporting

requirements by the states to facilitate

monitoring and to ensure progress is

being made to achieve the final 2030

targets.

s฀

Performance Metrics:

Revise the

compliance formula to provide proper

credit under EPA’s rate-based method

for retiring, and not replacing, existing

coal-fired power plants with fossil gen-

eration—thus giving full credit where

credit is due.

s฀

Graduation Dates:

Offer states the

flexibility to extend the 2030 deadline if

a clear path to meaningful reductions is

evident in a reasonable time frame.

Under the Ameren GHG strategy, by

2035 Ameren would retire more than

1800 MW (about one-third) of its coal-

fired fleet, add approximately 500 MW

of renewable generation, extend the

license of its 1200 MW Callaway Nuclear

Energy Center, add a 600 MW natural

gas combined-cycle unit, and continue to

offer robust energy efficiency programs.

“Ameren has developed a clear path to

significantly cut greenhouse gas emis-

sions without inflicting needless pain

upon our customers,” Baxter said. “The

modifications we propose to the EPA’s

Clean Power Plan reflect midwestern

values of prudence and practicality and

create a more workable alternative to

the agency’s proposed rule by offering

a solution to help address unreason-

Continued on page 28

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