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Upstream Implications of Coal to Gas Switch Under CATF’s 111(D) Proposal

The Clean Air Task Force and The NorthBridge Group recently analyzed two existing fossil power plant emissions scenarios for 2020, with and without a new policy under Clean Air Act Section 111(d).1 Without the proposed new policy, they predict 1,553 Tg CO2 emissions from coal EGUs, and 484 Tg CO2 from gas-­‐fired plants. With the proposed new policy, they predict 1,069 Tg CO2 from coal EGUs, and 659 Tg CO2 from gas plants. This paper considers the projected marginal emissions of methane and CO2 from the production, processing, and transmission of gas, and from the production and transport of coal, which would result from the CATF proposed policy.

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