As states confront a plethora of options for compliance with the U.S. Environmental Protection Agency’s (EPA) Clean Power Plan, Janine Migden-Ostrander highlights 10 steps that regulators can take now as a foundation for an effective, approvable state plan for compliance. She encourages states to begin by reviewing and updating state energy efficiency and renewable energy programs, in order to assess their efficacy and determine whether additional value can be gained. Of equal importance is communication. Engagement with other state regulators, other states, regional EPA offices, and the independent system operator or regional transmission operator is paramount. States may also want to consider a multi-state approach to compliance to reduce cross-border issues.

In her address to the Mid-Ohio Regional Planning Commission’s (MORPC) Summit on Sustainability and the Environment, Ms. Migden-Ostrander also outlines the particular challenges faced by the state of Ohio. She explores the $1 billion in net benefits to customers from Senate Bill 221, which enacted Ohio’s energy efficiency resource standard (EERS), and the negative impact on that program by SB 310, passed by the legislature this summer. Based on the success of the original EERS program, she encourages Ohio regulators to leverage energy efficiency and renewable energy in the state energy plan, as well as to enact higher building code standards, and explore revenue regulation to break the link between energy consumption and utility revenue.