EPA’s proposed carbon pollution standards for existing gas power plants would apply only to large plants running at annual capacity factors higher than 50%. Annual averaging of capacity factors provides signficant flexibility to these plants to ramp output to meet operational needs while still staying below proposed thresholds for pollution standard coverage. This short analysis discusses three examples of recent extreme weather events during which an existing gas power plant could operate at 100% and remain under the proposed 50% capacity factor threshold through averaging.
This resource was commissioned by or produced by staff of the Center for Applied Environmental Law and Policy before the organization rebranded as Ridgeline Center for Law and Policy in 2026.