As the Environmental Protection Agency works towards finalizing a few components of the Clean Power Plan, the agency will host public hearings over two days in Atlanta on November 19-20. The hearings in Atlanta are the final opportunity for the public to provide verbal input on the plan. Other hearings are being held in Pittsburgh, PA, Denver, CO, and Washington, DC.
The Clean Power Plan, released in August and officially published in October, is EPA’s historic effort to finally curb carbon dioxide emissions from fossil-fuel fired power plants.
The Clean Power Plan sets emission reduction goals that each state must meet by 2030, based on that state’s historic generation and unique energy portfolio. States are given a wide range of compliance options and ample time to craft state specific compliance plans that are flexible, economically viable and protect grid reliability.
The hearings are an opportunity for the public to provide verbal input to EPA on several key parts of the Clean Power Plan – the Proposed Federal Rule and Model Training Rules and the Clean Energy Incentive Program. The official public comment period for these pieces ends on January 21, 2016, but EPA is hosting public hearings early for those who want to provide input before the deadline.
The Clean Energy Incentive Program
The Clean Energy Incentive Program (CEIP) is the voluntary early action opportunity that states can participate in to achieve either emission allowances or emission reduction credits (ERCs) before the official Clean Power Plan compliance timeline begins in 2022. [1 allowance = 1 ton of CO2 under a mass-based compliance plan; 1 ERC = 1 mega-watt hour of avoided fossil-fuel generation under a rate-based compliance plan]. The CEIP rewards early investments in renewable energy generation or in demand-side energy efficiency measures that reduce end-use energy demand for low-income communities in 2020 or 2021.
The CEIP aims to jump start job opportunities in the ever-growing clean energy sector and provide benefits, in the form of lower utility bills, for communities that have historically suffered from air pollution and other ills of the fossil-fuel industry. The specifics of the CEIP are still up for debate, but it remains clear that EPA intends to offer early action credits for states who want to begin work on renewable energy generation projects and low-in
come energy efficiency programs before 2022. EPA has already begun to reach out to stakeholders for input on the CEIP and will continue to engage throughout the public comment period. For more information on the specifics of the CEIP that EPA is taking input on, click here.
Proposed Federal Plan and Model Trading Rules
In its effort to make compliance with the Clean Power Plan as straight-forward as possible for states, EPA has released a Proposed Federal Plan that serves as the model for a potential federal plan that EPA would implement if any state failed to submit an approvable state plan of its own. The Proposed Federal Plan is a bit of a misnomer, as it is consists of two different plan types, one mass-based and one rate-based, both of which include model trading rules – resulting in four discrete proposed actions. A state compliance plan that adheres to the model trading rule provisions will be presumptively approvable when a state submits its final plan to EPA for review.
Although the Proposed Federal Plan includes both rate- and mass-based proposals, EPA intends to finalize a single plan type for every state in which it finalizes a federal plan. EPA will only finalize a federal plan for a state that fails to either submit a plan at all or submits a plan that does not include all requirements under the Clean Air Act. Even when a federal plan is put in place, however, the state retains the option of submitting a state plan that would allow the state to exit the federal plan if the state plan is approved.
We will continue to keep you informed on all the Clean Power Plan developments as we continue to work to reduce dangerous carbon emissions and increase clean energy and energy efficiency resources across the Southeast. For more specifics on the upcoming hearings or to register, click here.