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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