111(d) Compliance Measures Outside EPA’s Four Building Blocks
The “3N Group,” comprised of the National Association of Regulatory Utility Commissioners (NARUC), the National Association of Clean Air Agencies (NACAA), and the National Association of State Energy Officials (NASEO), invited Ken Colburn to discuss Clean Power Plan compliance options that go beyond the four building blocks defined by the Environmental Protection Agency (EPA) in its proposal. EPA’s building blocks provide a consistent, legally-defensible way to determine state-specific rate targets, but are not intended to constrain states to those options alone. Mr. Colburn highlights numerous cost-effective technology and policy options outside of this framework that states could use to help comply with the Clean Power Plan. He recommends that states target the least-cost compliance options.