U.S. Environmental Protection Agency (EPA) administrator Gina McCarthy yesterday announced EPA’s long-awaited proposed rule to reduce greenhouse gas (GHG) emissions from existing power plants. Labeled EPA’s “Clean Power Plan,” the publication of the proposed rule in the Federal Register will commence the formal rulemaking process. A flood of comments is expected from all quarters.

RAP will review the draft rule and provide a synopsis with initial recommendations for state regulators in the near future. In the interim, RAP suggests that states:

1. Maintain a regular dialogue among their state environmental agency, public utility commission, state energy office, and consumer advocate on the proposed rule and the flexibility options it provides;
2. Engage with their utilities and advocates about compliance obligations and potential approaches;
3. Analyze existing and planned clean energy programs, including energy efficiency measures and renewable energy requirements, and quantify the associated GHG emissions reduction impact; and
4. Initiate, if they haven’t already, discussions with other states regarding possible approaches to compliance with the Clean Power Plan, including multi-state approaches.

Details on EPA’s plan will become much clearer in the weeks ahead. At first glance, it appears that the agency crafted a constructive approach, which avoids penalizing states that have taken early actions to cut GHG emissions, and allows other states to start fresh in developing, coordinating, and evaluating their own plans to reduce power sector emissions.

For additional guidance and background, RAP suggests the following resources:

• Tackling 111(d): Where to Begin?
• Tackling 111(d): Could Regional Approaches Rule?
• Further Preparing for EPA Regulations
• Incorporating Environmental Costs in Electric Rates
• Recognizing the Full Value of Energy Efficiency
• Greenhouse Gas Emission Reductions From Existing Power Plants: Options to Ensure Electric System Reliability