Regional and Modular Options for Complying with the Clean Power Plan 111(d) Rule
As the policy debate around the U.S. Environmental Protection Agency’s Clean Power Plan (CPP) continues, the ensuing uncertainty actually increases the need for states to forge ahead with their plans for compliance. Fortunately, the long-term planning that utilities and public utility commissions have routinely done for decades has laid solid groundwork for developing a compliance plan. In a presentation to the National Caucus of Environmental Legislators (NCEL), John Shenot explored why states should consider a regional approach to CPP compliance and the various options for doing so.According to studies conducted in both the Western and Eastern Interconnections, regional compliance is clearly less expensive. Three analyses prepared by grid operators and reliability experts determined that nearly 200 million Americans live in places that would profit from adopting a regional approach to CPP compliance. A good example of a successful multi-state model is New England’s Regional Greenhouse Gas Initiative (RGGI)—after just six years, the program achieved a 35 percent reduction in carbon emissions, saved consumers $460 million, added $1.3 billion in economic value to the region, and led to the creation of more than 14,000 new jobs. Mr. Shenot also outlines several “modular” options for compliance, such as an EE or renewable energy (RE) tracking system and possible credit trading, and coordinated dispatch of fossil-fuel units. A regional approach to CPP compliance, especially one leveraging EE, can help states meet plan requirements at a low cost and low risk.