David C. Foerter Executive Director Institute of Clean Air Companies (ICAC) October 22, 2010

1. Clean Air Act Regulation, Technologies, and CostsNARUC/BPC/NESCAUMPower Sector Environmental Regulations Workshop David C. Foerter Executive Director Institute of Clean Air Companies (ICAC) October 22, 2010

2. Institute of Clean Air Companies ICAC - national association established in 1960 for air pollution control manufacturers and service providers 100 leading companies Emissions control and measurement technologies for electric power and industrial sectors OEMs, design and engineering, component and reagent suppliers Technology innovators for air pollution controls for over 50 years Cleaning the air we breathe

3. How did we get here? • Responded to health science but missed trends • PM – led to ESP, FF, mechanical collector, add PM control upgrades for PM2.5 • SO2 – 1st generation scrubbers, wet/dry system and reagent innovations • NOx – led to burner upgrades, SCR, SNCR, and SNCR/SCR hybrids • Mercury – optimized SCR/FGD, ACI and sorbents • Other HAPs – more scrubbers and injection of sodium bicarbonate, trona, lime • Condensables – polishing controls • The search for cleaner units is limited within existing fleet and hampered by lack of turnover to cleaner fleet

4. What’s next? • 1-hour NO2 NAAQS • effective April 12, 2010 • 1-hour SO2 NAAQS • first-time 1-hour SO2 standard • How big is your SO2 footprint? • attainment as early as 2017? • PM NAAQS by July 2011 • attainment as early as 2018? • More NOx and or SO2 controls? Direct PM controls? • Secondary NOx/SOx standards • ecological effects • Don’t ignore the trends

5. Still to come • Coal Combustion Residue (CCR) Regulation • GHG/CO2 “Tailoring” Rule • GHG BACT Permits • Fate of older uncontrolled and/or smaller units?

6. The Transport Rule • Once final, CATR will eclipse CAIR • CATR I is measured response to 1997 Ozone and 1997/2006 PM2.5 standards • Extra push for reductions of SO2 and NOx • Affects 240 GW of total 309 GW of coal capacity • 14 GW new FGD • 1-2 GW new SCR/SNCR • Compare to 80 GW FGD/SCR installed 2005-2010 and 90 GW of SCR/SNCR 2000-2005 • Soon new Ozone NAAQS and CATR II; attainment dates as early as 2017?

7. Utility MACT • What will the ICR data show? • Have taken major step introducing technologies with states Hg control and measurement programs • HCl removal dominating technology discussion and innovations; HF and dioxin not far behind • Likely need for combinations of PM upgrades, dry and wet systems and sorbents • Lessons learned from HAP control on Industrial boilers • Wet scrubbers a possibility but unlikely for unscrubbed units

8. Exceptional Power Plants • Exceptionally broad range of available and economically reasonable control technologies • Exceptional bang for the buck • Every dollar spent on control has a return of as much as 40 dollars in avoided health costs (premature mortality) • Every dollar spent is also plowed back into the U.S. economy as good and green jobs • Once requirements in place, power industry is exceptional in its timely compliance

9. Technology Costs and Availability • Tremendous experience with capital and labor intensive technology installations and meeting compliance deadlines • Ever broadening range of available technologies with lower capital cost and installation requirements • Once requirements in place, industries, including power sector, are extremely efficient in installing chosen control equipment • End users have utilized cost reducing and implementation efficiency strategies including continuous planning, applying design templates and aggregating resources for efficient deployment

10. Its been an interesting ride so far CAIR Phase I NOx SIP Call

11. An uncanny ability to see both where you’ve been and where you are going

12. Questions / Contact • Institute of Clean Air Companies • air pollution control and measurement technologies for stationary sources • Cleaning the air we breathe • www.icac.com • 1220 N. Fillmore St., #410 • Arlington, VA 22201 • (703) 812-4811