September 2015

Josh Elliott-Traficante

In July the EPA released the final rules for its Clean Power Plan. This plan, drawn up under the authority of the Clean Air Act and championed by President Obama, aims to cut carbon emissions from power plants by 32% by 2030. To achieve that goal, the EPA has assigned targets for each state to meet as part of that overall effort, and has given states two options how to reach them. The first imposes emissions standards on fossil fuel fired plant, called the Rate Based Goal, and the second is a complex formula based on current plants, improved efficiencies, and increasing renewable production called the Mass Based Goal. New Hampshire’s assigned target based on emissions standards would cut emissions by 23%, while the formula based reductions call for a 14% cut in emissions.  While either are a tall order, it is an improvement over the first draft of the rule, which expected the state to cut emissions by 46%.

In order to comply with these rules the state must either submit a plan to the EPA, or ask for an extension by September 2016. Mandatory reductions must begin in 2022.

The Rate Based Goal: Not All Power Plants are Created Equal

Under these rules, most of New Hampshire’s power plants are excluded. Of the 153 power generating units in the state, only eleven units located at five plants will be subject to this rule. Three of those plants, Merrimack Station, Schiller Station, and Newington Station are owned by the public utility Eversource Energy[i], while the other two, Newington and Granite Ridge are owned by private companies. Despite the rule only applying to those five power plants, they supply roughly half of the electricity generated in the state.

Power Plant Owner Generation

(Nameplate Capacity)

Fuel Source Location
Merrimack Station Eversource Energy 460MW Coal Bow
Schiller Station 100MW Coal or Oil Portsmouth
Newington Station 414MW Oil or Natural Gas Portsmouth
Granite Ridge Granite Ridge Energy 900MW Natural Gas Londonderry
Newington Essential Power LLC 605MW Natural Gas Newington


Under the rate based rule, by 2030 carbon emissions for coal fired plants would be capped at 1305 lbs/MWh[ii], while natural gas fired plants would be capped at 771 lbs/MWh.[iii] Based on the makeup of the state’s generation assets listed above, this gives the state a ‘blended’ rate of 858lbs/MWh.  As of 2012, carbon emissions for coal fired plants in the state averaged 2,382 lbs/MWh, while natural gas fired plants averaged 878lbs/MWh. If the state chose this option for complying with the rule, the state’s coal fired plants would need to reduce the carbon intensity of their emissions by 46% and natural gas plants by just over 12%.

In theory, to meet that goal, the state could require all of the coal fired plants to switch over to natural gas if they wanted to continue to operate, or shut down. Combined with small improvements to natural gas plant efficiency, that would be enough to meet the Rate Based goal. Whether or not the EPA would accept such a plan remains to be seen.

For those power plants not subject to this rule, such as the nuclear power plant in Seabrook, or any of the various hydroelectric dams scattered around the state, most are exempt because they do not emit carbon. Of those that do emit carbon, some will not be required to cut emissions either due to their size or the end use of the electricity, while others such as wood burning biomass are excluded because they are considered renewable.     

The Mass Based Goal:

The other option given to the states is the Mass Based Goal, where the state’s reduction goals, are expressed in terms of total emissions from generation of electricity. Under this framework New Hampshire will be expected to cut emissions by 14% by 2030, with an interim reduction of 8.6% achieved sometime between 2022 and 2029.

Using this method, rather than ordering reductions from specific power plants, emissions reductions are spread over all of state’s the power generation stations. The idea being that doing so further incentivizes the use of renewable energy and conservation, reducing the need for fossil fuel fired generation. Rather than the EPA telling a state where to cut, and by how much, this method gives the state a reduction target, and leaves it to the state to figure out how to get there.

Time Frame Carbon Emissions

(in short tons)


(over 2012)

2012 4,642,898 N/A
2022-2029 4,243,492 8.6%
2030 and Beyond 3,997,579 14%


How the state reaches that target could include everything from generating more electricity from nuclear, large scale hydro, renewables to conservation measures. As long as the amount of emissions declines, the state will be considered in compliance. 


As mentioned, the states have a decent amount of latitude when it comes to complying with these rules, including which path to take. However, if a state opts to use the Mass Based Goal, it must use as a fall back option the Rate Based Goal. This is because the Mass Based Goals would be impossible to enforce federally by their broad nature, while the Rate Base Goal, being defined, can be.  According to documents filed by the NH Department of Environmental Services to the EPA during the comment period[iv], the state intends to use participation in the Regional Greenhouse Gas Initiative (RGGI)[v] to meet these requirements, presumably under the Mass Based Goal approach. 


Despite the EPA repeatedly insisting that the states have choices when it comes to these new rules, the states still have to comply with the rules. In a parallel to Obamacare, it is like insisting there are choices when it comes to healthcare, while requiring people to purchase insurance. Like Obamacare, there are costs involved.

The forcible sidelining of coal, oil, and to a lesser extent natural gas fired power plants and replacing them with renewables will increase electric rates. If states did not have programs such as RGGI or renewable portfolio standards (RPS)[vi] that in-directly and directly mandated electric utilities buy renewable energy respectively, the utilities would not buy it. Not out of some devotion to fossil fuel fired generation[vii], but because those sources are far cheaper than renewables. If they were cheaper, electric utilities would be buying up as much of it as possible, without the government mandating they do so.

Free Market in Action:

Despite this big push by the EPA, carbon emissions have actually fallen by 16.4% since 2005, without government intervention. Why? Natural gas is cheaper than coal. The fracking boom has dramatically increased domestic supplies of natural gas, causing the price to fall. As such, it becomes cheaper create electricity by running natural gas fired power plants than coal plants. In addition, because of this dramatic decrease in price, along with ample supplies for the future, most newly constructed power plants use natural gas as their fuel source, further undercutting coal. In addition to being cheaper, natural gas also emits far less carbon per megawatt produced. A coal fired plant replaced by a natural gas fired plant producing the same amount of power emits far less carbon in the process.

This 16.4% reduction came about purely from free market forces, not government intervention. Unlike government intervention which increases costs, the free market accomplished this while also reducing energy costs. Using a lower cost fuel results in lower energy prices. By letting the free market work everyone wins. Environmentalists get their reduction in carbon emissions, while consumers get lower electricity rates. Rather than use force, let the free market continue to work.


[i] Assuming that the ‘Global Settlement’ is approved by the Public Utilities Commission, these plants will be put up for sale in the near future.

[ii] Pounds per megawatt hour is the measure of how much carbon is emitted per megawatt of electricity produced.

[iii] The difference in these rates is an acknowledgment that natural gas emits less carbon than coal does per megawatt produced.

[iv] LINK

[v] Regional Greenhouse Gas Iniative (RGGI) is a cap and trade program among nine northeastern states that applies to all power plants over 25MW. Carbon credits are purchased at auction, with the number of credits available reduced every year.

[vi] Renewable Portfolio Standards (RPS) are a set of standards set in state law that mandate certain percentages of the power used in the state come from renewable sources. These percentages are increased every year. If a utility fails to acquire enough renewable power, alternative compliance payments must be made.

[vii] There is something to be said about the inherent reliability of those types of plants. People and business still need power at night or when the air is calm. Solar plants can see their output reduced to a fraction just from a cloud passing overhead.

1 Response to “New Hampshire and the Clean Power Plan”
  1. 1Bill Fortune on Sep 11, 2015 at 10:41 am:

    Responses to “Massachusetts is gaining ground with its solar energy endeavors” and new EPA emission rules for NH
    1. WILLIAM FORTUNE Industrial Consultants Inc/ NHcleanenergy says:
    September 11, 2015
    Just goes to show how stupid politicians can be and how blind the Alternative Energy religious fanatics are.
    Solar is one of the most expensive ways to produce electricity. And there is no need to conserve because we are storing enough waste and generating enough waste to produce all the electricity needed for 100 years or more, at a cost equal to or less than today’s cost.
    The new power plant designs are very efficient, extremely safe and produce no CO2 or methane.
    Hint: If I were the President of MIT, I would move MIT out of the State of Mass. It’s a real slap in the face to have the Governor and others ignore the great work that MIT and others have done in designing a new power plant. I would swap UNH for MIT.
    All this talk about cutting emissions and the “cost of electricity” is just simply stupid talk ! It costs only about 4 cents/kwh to produce electricity and would cost even less if people spent their energy discussing building the new type power plants instead of trying to make obsolete technology comply with new standards.