In a recent interview on E&E TV’s OnPoint, RAP senior associate Ken Colburn encourages state regulators to take a nontraditional approach to assessing compliance with the U.S. Environmental Protection Agency’s proposed Clean Power Plan (CPP). In meeting the CPP’s anticipated requirements, regulators will have an unusually broad palette of compliance options from which to choose; the time frame to analyze these options is short, and states have limited resources to assess each option. Mr. Colburn recommends that states start by focusing on low-cost, “outside the fence” measures, such as energy efficiency.

“Any negawatt-hour – the kilowatt-hour that isn’t used and therefore doesn’t have to be generated in the first place – will take a load off any reliability issues and, at the same time, save money and reduce other pollutants,” Mr. Colburn notes. Even states that have taken considerable steps to reduce carbon emissions still have an untapped reserve of efficiency options.

He also highlights the value of communication between air regulators and public utility commissioners, collaboration between states, and outreach to independent system operators and regional transmission operators. Mr. Colburn noted that one benefit the CPP has had already is fostering cooperation between air regulators and public utility commissioners.

The interview touches on a recent RAP policy brief, Preparing for 111(d): 10 Steps Regulators Can Take Now, as well as Mr. Colburn’s initial guidance for regulators tackling the CPP. He provides concrete steps to support state energy regulators, environmental regulators, consumer advocates, and energy officers as they build the foundation for an effective, approvable state 111(d) plan.